Privacy Policy

Escrow Africa is a company incorporated under the laws of the Republic of Ghana (Company Number CS141320625), with its registered office at 36 Golden Glade Street, Tse Addo, Accra, Ghana. Escrow Africa operates an online escrow platform accessible at https://new.myescrow.africa/legal and through its mobile application (the "Platform").

This Privacy Policy explains how Escrow Africa collects, uses, stores, shares, and protects your personal information when you access or use the Platform. It also explains your rights regarding that information under the Data Protection Act, 2012 (Act 843) of Ghana.

By registering on or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal information as described herein.

We collect the following categories of personal information:

Full legal name, date of birth, and nationality

Ghana Card (front and back image or PDF), National Identity Document, or valid passport (for foreign nationals)

Proof of address documents (such as a utility bill or bank statement issued within the last three months)

KYC verification status and associated compliance records

Email address

Phone number (including mobile number used for SMS communications)

Physical address

Mobile money account details

Card payment details (processed by our payment partners; we do not store full card numbers)

Bank account details where applicable

Escrow transaction records, including amounts, milestones, parties, and status

IP address, browser type, and device identifiers

Pages visited, session duration, and interaction logs

Login timestamps and authentication records

Messages exchanged between parties through the in-platform communication tools

Dispute submissions and supporting documentation

Customer support correspondence

We use the personal information we collect for the following purposes:

To verify your identity in accordance with our Know Your Customer (KYC) obligations

To facilitate, monitor, and complete escrow transactions

To hold and release escrowed funds in accordance with uploaded agreements and milestone confirmations

To manage dispute resolution processes

To comply with the Anti-Money Laundering Act, 2020 (Act 1044), the Banking and Specialised Deposit-Taking Institutions Act, 2016 (Act 930), the Payment Systems and Services Act, 2019 (Act 987), and other applicable Ghanaian laws and regulations

To report suspicious or unlawful activity to the Financial Intelligence Centre or other relevant regulatory authorities

To maintain records as required by applicable law

To send transactional and operational notifications, including one-time passcodes (OTP), account alerts, and transaction status updates

To send security notifications in the event of suspicious activity

To respond to customer support inquiries

To detect, investigate, and prevent fraudulent activity, unauthorised access, and other misuse of the Platform

To maintain audit logs of all critical platform events

To analyse usage patterns and improve the functionality and user experience of the Platform

Important SMS privacy notice Important: Personal data, including phone numbers, collected during the opt-in process will not be shared with or sold to third parties for marketing purposes.

Escrow Africa uses SMS communications solely for the following operational purposes:

One-time passcodes (OTP) for account sign-in and transaction confirmation

Transaction alerts, including escrow funded, milestone confirmed, and disbursement completed notifications

Account security alerts, including login notifications and verification status updates

We do not send marketing or promotional SMS messages.

OTP messages: one message per login or transaction confirmation request

Transaction alerts: one message per qualifying transaction event

Account alerts: as required by the relevant account or security event

Message and data rates may apply. Escrow Africa is not responsible for any charges applied by your mobile network operator.

You may opt out of SMS communications at any time by replying STOP to any message. To receive assistance, reply HELP. Where SMS communications are not available or preferred, you may elect to receive notifications by email through your account settings.

Your phone number is used solely to deliver the SMS communications described in this section. It will not be shared with or sold to third parties for any marketing purpose.

We do not sell your personal information to any third party. We share your information only in the following circumstances:

We share personal information with third-party service providers who assist us in delivering the Platform and our services. These include:

Fidelity Bank Ghana -- banking partner responsible for holding escrowed funds

Dojah -- identity verification and KYC processing

Smile ID -- identity verification services

OrangExt -- mobile money (MoMo) payment processing

CyberSource -- card payment processing

Paystack -- marketplace subscription payment processing

Twilio -- SMS communications delivery

All service providers are contractually required to process personal data only for the purposes for which it was shared and to maintain appropriate security standards.

Where a dispute is referred to the Ghana Arbitration Centre in accordance with our Terms and Conditions, relevant transaction records and supporting documentation may be shared with that body as required to facilitate the arbitration process.

We may disclose personal information to regulatory authorities, law enforcement agencies, or courts where required by applicable law, including our obligations under the Anti-Money Laundering Act, 2020 (Act 1044). We will notify you of such disclosure only where permitted or required by law.

In the event of a merger, acquisition, or sale of all or part of our business, the personal information we hold may be transferred to the relevant successor entity, subject to equivalent data protection obligations.

Some of our service providers are based outside Ghana, including in the United States of America. When we transfer personal data outside Ghana, we take appropriate steps to ensure that such data is afforded a level of protection consistent with the Data Protection Act, 2012 (Act 843), including through contractual safeguards with those providers.

We retain your personal information for as long as is necessary to fulfil the purposes set out in this Privacy Policy and to comply with our legal obligations. Specific retention periods are as follows:

Transaction and escrow records: a minimum of seven (7) years following the completion or cancellation of a transaction, in compliance with anti-money laundering regulations

Identity and verification documents: for the duration of your registered account plus seven (7) years following account closure

Platform usage and audit logs: three (3) years

Customer support records: three (3) years following resolution of the relevant inquiry

Where retention is no longer necessary and no legal obligation requires it, we will securely delete or anonymise your personal information.

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. These include encrypted data storage, access controls, audit logging of all critical platform events, and secure payment processing through PCI-compliant partners.

If you have been given or have created a password for access to the Platform, you are responsible for keeping it confidential and for notifying us immediately if you believe your account has been compromised.

No method of electronic transmission or storage is entirely secure. While we take our security obligations seriously, we cannot guarantee the absolute security of personal information transmitted through the internet.

Under the Data Protection Act, 2012 (Act 843) of Ghana, you have the following rights in relation to your personal information:

Right of access: you may request a copy of the personal information we hold about you

Right of correction: you may request that we correct any inaccurate or incomplete personal information

Right of deletion: you may request that we delete your personal information where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations

Right to object: you may object to the processing of your personal information in certain circumstances

Right to data portability: you may request that we provide your personal information in a structured, machine-readable format where technically feasible

To exercise any of these rights, please contact us at the address set out in section 11 below. We will respond to your request within a reasonable time and in accordance with applicable law.

Please note that certain rights may be limited where we are required to retain your information to comply with a legal obligation or to defend a legal claim.

The Platform uses cookies and similar tracking technologies to maintain session state, improve performance, and analyse usage. The following types of cookies are used:

Strictly necessary cookies: required for the Platform to function, including session authentication and security

Analytics cookies: used to understand how users interact with the Platform in order to improve functionality

You may configure your browser settings to refuse or delete cookies. Please note that disabling strictly necessary cookies may affect your ability to use certain features of the Platform.

Escrow Africa reserves the right to update this Privacy Policy at any time. Where we make material changes, we will notify you by email or through an in-Platform notification. The current version of this Privacy Policy is always available at myescrow.africa/legal/privacy-policy. Your continued use of the Platform following the publication of an amended Privacy Policy constitutes your acceptance of the amended terms.

If you have any questions, concerns, or requests in relation to this Privacy Policy or the processing of your personal information, please contact us at:

Escrow Africa (Data Controller)

36 Golden Glade Street, Tse Addo, Accra, Ghana

Email: legal@myescrow.africa

You also have the right to lodge a complaint with the Data Protection Commission of Ghana if you believe we have failed to handle your personal information in accordance with applicable law.