TEDLA MINI MART ("we", "us", or "our") operates the LumaCash mobile application and related services. We take your privacy seriously and are committed to protecting the confidentiality and security of your personal information. This Privacy Policy describes how we collect, use, store, protect, and disclose your personal information when you use LumaCash, our website, and related digital finance services in Ghana.
We adhere to the principle of data minimization, collecting only the information necessary to provide and improve our loan and financial services. All personal data is encrypted during transmission and stored securely using industry-standard security measures. We will never sell your personal information to any third party for commercial purposes.
By accessing or using LumaCash, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, please refrain from using our services.
Information We Collect
When you use LumaCash, we may collect the following categories of information. All data is encrypted during transmission and stored on protected servershttps://www.lumacreditapp.com.
With your explicit consent, we may access SMS messages on your device. This is used exclusively to analyze financial-related messages such as bank transaction alerts, loan notifications, credit card reminders, and mobile payment confirmations. We do not access or store private personal messages unrelated to financial activities. You may revoke SMS permission at any time in device settings, though this may affect credit evaluation.
We may collect installed app metadata (app name, package name, install/update time, version) to identify financial apps for fraud prevention and risk assessment. We do not collect content from those apps or access contacts, calendar, or other personal data on your device. Data is encrypted and deleted or anonymized after analysis where appropriate.
We may collect approximate location (city or region from network, IP, or coarse location permission). We do not collect precise GPS location. This is used for account security, fraud detection, and regional compliance. Data is retained only as necessary and then deleted or anonymized.
We may collect device model, brand, OS version, screen resolution, battery status, advertising identifiers (GAID/AAID), unique device identifiers, IP address, and network type. This supports app stability, fraud prevention, secure authentication, and performance optimization. We do not sell this data or use it for unrelated advertising.
With your permission, the camera is used only to capture government-issued ID documents and complete facial verification for KYC. Images are encrypted during transmission and storage and retained only for compliance and anti-fraud purposes before secure deletion.
We may use privacy-preserving advertising attribution provided by the Android system to measure ad performance and understand how users discover LumaCash. Attribution data is processed in a privacy-preserving manner and does not include personally identifiable information beyond platform measurement data.
Personal Information You Provide
During registration and loan application, you may provide:
- Mobile Number — Registration and communication
- Full Name — Identity verification and account management
- National ID Number — KYC and regulatory compliance
- Residential Address — Eligibility and verification
- Education Level — Credit scoring enhancement
- Employment Type — Loan eligibility assessment
- Marital Status — Risk assessment and limit determination
- Income / Salary Level — Repayment capacity assessment
- Bank or Mobile Money Account — Disbursement and repayment
- Emergency Contact — Verification when required
- WhatsApp Contact — Communication when provided
How We Use Your Information
We use your information solely for legitimate purposes and in accordance with applicable privacy laws in Ghana:
- Account Registration and Management — Create and maintain your LumaCash account
- Identity Verification and KYC — Verify identity and prevent identity theft
- Credit Assessment — Evaluate creditworthiness and loan eligibility
- Risk Control and Fraud Prevention — Detect fraudulent activity
- Loan Disbursement and Repayment — Process funds and repayment schedules
- Customer Support — Respond to inquiries and resolve issues
- Service Improvement — Improve LumaCash and user experience
- Legal Compliance — Comply with laws, regulations, and court orders
Automated Decision-Making
We may use automated processes, including credit scoring models, to assess eligibility, determine loan amounts and terms, and detect fraud. You may request human review by contacting us (see Section 9).
Data Minimization: We only collect and process personal information that is necessary, adequate, accurate, and kept up to date.
Information Sharing and Disclosure
We do not sell, rent, lease, or exchange your personal information for commercial purposes.
We may share necessary data only in these circumstances:
- Service Partners — Licensed financial partners, payment processors, credit agencies, and fraud providers under confidentiality agreements
- Service Providers — Cloud hosting, analytics, and technical support who process data only on our behalf
- Legal Requirements — When required by law, regulation, or valid requests from authorities
- Protection of Rights — To prevent fraud or protect users and public safety
There is no form of information trading. Technical service providers operate under strict confidentiality and may not use your data for other purposes.
Information Security
- Transmission Encryption — TLS/SSL protects data in transit
- Storage Encryption — AES encryption for data at rest on secure servers
- Access Control — Authorised personnel only; access is logged and monitored
- Secure Authentication — Multi-factor authentication and secure sessions
- Security Reviews — Regular assessments and vulnerability management
While we take reasonable measures, no system is completely secure.
Data Retention and Storage
- Active Accounts — Retained while your account is active or services are provided
- Closed Accounts — Deleted or anonymised within 30 days unless law requires longer retention
- Loan Records — Retained as required by financial, tax, and AML regulations
- Risk Data — SMS, device, app list, and location data retained only for risk control and compliance
After retention expires, data is securely deleted or anonymised using industry-standard methods.
Your Rights and Choices
- Right of Access — Confirm whether we hold your data and how it is processed
- Right to Rectification — Request correction of inaccurate information
- Right to Erasure — Request deletion in permitted circumstances
- Right to Object — Object to processing based on your situation
- Withdraw Consent — Revoke permissions in device settings (some features may stop working)
Contact us to exercise these rights. You may also lodge a complaint with the relevant data protection authority.
Children's Privacy
LumaCash is only for users aged 18 and above. We do not knowingly collect data from minors. If we discover a user under 18, we will terminate the account and delete collected information.
Policy Updates
We may update this policy periodically. Material changes will be notified via in-app notice, website update (with revised date), or email where available. Continued use after changes constitutes acceptance. You can access the latest version at:
privacy.html (on-site) · Public URL: https://www.lumacreditapp.com/privacy.html
Account Deletion & Contact Us
You may request account deletion at any time. Requests are processed within 30 business days. Ensure all loans are repaid before deletion. Submit your request via the online deletion form.