Privacy Policy

Last updated: 7 July 2026

Overview

Padlok is a peer-to-peer escrow app that lets people in Ghana buy and sell with confidence: a buyer’s payment is held in escrow until delivery is confirmed, and the seller is paid the moment the deal is done. This Privacy Policy explains what information we collect to run that service, how we use and protect it, and who — if anyone — we share it with.

Information we collect

We collect information in the following categories:

Account & profile information

Name, email address, phone number, username, password, and optional profile details you choose to add such as a bio, a free-text location field, and a profile photo. We do not collect precise GPS location — the “location” field is just text you type in, and it is not a structured or verified mailing address. The proof-of-address document collected for Tier 2 verification (see below) is stored as an image, not parsed into an address record.

Identity verification (KYC) information

Padlok uses a tiered verification system to keep the marketplace trustworthy and to meet anti-fraud and financial regulatory obligations:

• Tier 1 — Identity: a photo of the front and back of your Ghana Card, and a selfie of you holding it.
• Tier 2 — Trusted: a bank statement and a proof-of-address document.
• Tier 3 — Business: your business name, website, and social profiles.

These documents are only reviewed by staff with the specificverify_kyc permission on our internal admin system, and every access is recorded in an audit log.

Payment & financial information

To fund escrow, withdraw, or add a payout method, we store the provider (e.g. bank or mobile network), account/holder name, and either the last four digits of a card or a bank/mobile money account number. We never see or store your full card number or PIN — card payments are handled directly by Moolre’s secure infrastructure. We also keep a record of your wallet balance and funding/withdrawal history.

Transaction & escrow information

Item details and photos, price, escrow status, delivery milestones (e.g. dispatched, out for delivery, delivered), counterparty contact details needed to complete the deal, ratings left after a transaction, and any evidence submitted if a dispute is raised.

Security credentials

Your password and app PIN are stored as one-way hashes and verified server-side — we cannot read them back. If you enable two-factor authentication, we store the encrypted TOTP secret and one-time recovery codes. Face ID / Touch ID processing happens entirely on your device via Apple’s Secure Enclave — Padlok only ever receives a “biometric enabled” flag, never your face or fingerprint data.

Device & technical information

Device type and OS version, app version, a push-notification token (used only to deliver notifications to your device), and security audit logs of account activity such as logins and PIN attempts. Your IP address is processed transiently for rate-limiting and fraud prevention (e.g. blocking repeated failed login/PIN attempts) — it is not linked to your profile for marketing or analytics purposes, and is not retained outside of short-lived security logs.

Communications

Support requests you send us, in-app notifications, and correspondence related to a dispute.

What we don’t collect

Padlok does not track your precise GPS location — delivery progress is reported through milestones (e.g. dispatched, in transit, delivered), not live device tracking. We also do not use any third-party analytics or advertising SDKs: our push-notification provider (Firebase Cloud Messaging) is configured with Analytics and Ads modules explicitly disabled, and no advertising identifiers are collected.

How we use your information

• Operate escrow, wallet, and withdrawal functionality
• Verify your identity and prevent fraud
• Process deposits and withdrawals through Moolre or MTN Mobile Money
• Send account, security, and transaction notifications
• Investigate and resolve disputes between buyers and sellers
• Maintain security logs and detect suspicious activity
• Meet legal and financial record-keeping obligations
• Maintain and improve the reliability of the app

How we share your information

We do not sell your personal data, and we do not share it with third parties for their own marketing or advertising purposes. The only circumstances in which information leaves Padlok are:

• Payment processors (Moolre, MTN Mobile Money) receive only the data required to complete a specific deposit, withdrawal, or payment.
• Push-notification delivery(Firebase Cloud Messaging, operated by Google) receives only a device token used to deliver notifications — not your profile or transaction data.
• Transactional email (our email delivery provider) receives only the email address and content needed to send you account and security emails.
• Your counterparty in a deal sees the limited contact details needed to complete that specific transaction, the same as in any marketplace.
• Legal & safety: if required by law, a valid court order, or to protect against fraud, or to enforce our Terms & Conditions.
• Business transfers: if Padlok is ever involved in a merger or acquisition, your information would remain protected under the commitments in this policy.

Every service provider we use is contractually restricted to processing data solely to provide their service to Padlok — never for their own independent purposes.

How we secure your information

• Data is encrypted in transit (TLS) and at rest
• Passwords and PINs are stored as one-way hashes, never in plain text
• Login tokens are stored in your device’s secure Keychain, not app storage
• Biometric data never leaves your device
• Staff access to identity and financial data is role-based — only permissions like verify_kyc or view_usersunlock specific views — and every admin action is written to an audit log

Data retention

We retain account and transaction data for as long as your account is active, and for a further period afterward where needed to meet financial record-keeping obligations, resolve disputes, or comply with the law. Identity verification documents are retained only as long as necessary for these purposes and are then securely deleted.

Your rights & choices

You have rights over your information, including access, correction, and deletion. See the dedicated Your Privacy Choices page for how to exercise them.

Children’s privacy

Padlok is a financial escrow service and is not directed at, nor knowingly used to collect information from, anyone under 18 years of age. If we learn that we have collected information from a minor, we will delete it.

International data transfers

Our infrastructure providers may process or store data outside Ghana. Where this happens, we require providers to protect your information to a standard consistent with this policy and Ghana’s Data Protection Act, 2012 (Act 843).

Changes to this policy

We may update this policy as Padlok evolves. Material changes will be reflected here with an updated effective date.

Contact us

Questions about this policy, or requests relating to your data, can be sent to our data protection officer at hello@padlokit.com. If you are not satisfied with our response, you may also contact Ghana’s Data Protection Commission.