Privacy policy
Last updated: 11 November 2026 · Applies to the AgentBook app for mobile money agents.
Who we are
AgentBook is provided by [OPERATOR NAME], [POSTAL ADDRESS], email [CONTACT EMAIL]. We are registered with the Data Protection Commission of Ghana under number [DPC REGISTRATION NUMBER].
You, the agent, decide what to record about your customers, so you are the data controller for your customers' details under Ghana's Data Protection Act, 2012 (Act 843). We process that information only to run the app and its backup for you (we are a data processor).
What the app keeps
- On your phone: your transactions, opening and closing counts, expenses, debts, and the customer details you enter (name, phone number, ID type and number, notes). Personal fields are encrypted on the phone with a key held by the phone's secure hardware.
- Messages and photos: if you allow it, the app reads MoMo confirmation SMS or a photo of your basic phone's screen. This happens on your phone. Photos are never saved or sent anywhere; only the text you approve is kept.
Cloud backup (only if you turn it on)
- We store the email address or mobile number you sign in with, and a copy of your book, with Google Firebase.
- If you sign in with your mobile number, we send text messages to that number through Arkesel (an SMS company in Ghana): a sign-in code, a warning when another phone is added to your backup, and a notice if your account is deleted. Arkesel receives only your number and that message, never your records. Sign-in codes are stored only in scrambled (hashed) form and expire after 10 minutes.
- Customer names, phone numbers, ID numbers and notes are end-to-end encrypted: they are locked on your phone with a key that only your recovery passphrase can unlock. We cannot read them.
- Amounts, dates, transaction types and networks are stored readable so totals work. We do not look at them; our support tools show only counts (for example, how many records were backed up).
- For each phone signed in to your book we keep its model name, app version and when it last connected, so you can see your phones and sign out a lost one.
- If you add attendants, their names are end-to-end encrypted like customer names, so your other phones can show who entered each record. Their PINs never leave the phone they were set on. Outlet (kiosk) names you choose are stored readable.
- For AgentBook Plus we keep your plan and its end date. To give each person one free trial, we keep a scrambled (hashed) form of the number or email that started it, even after the account is deleted.
Loan statements a lender can check (only if you ask for one)
When you make a loan statement with a check code, we store what the statement shows: your business name, agent name and agent codes as printed, and each month's totals (money moved, number of records, commission, expenses). Anyone you give the code to can see exactly that on our website. It never shows your customers or your account. Deleting your account stops its statements checking out.
Google services in the app
- Camera text reader: reading a photo of your basic phone's screen uses Google ML Kit, which works on your phone. Google says ML Kit sends Google basic diagnostic and performance information, such as the phone model, Android version, app version and how fast it ran. It never sends the photo or what it says.
- Genuine-app check: the Google Play version asks Google Play whether the app is the real, unmodified AgentBook before it talks to the backup. This uses information about the app and phone, not your records.
- Firebase (Google) runs the sign-in and the backup, as described above.
Where the data is
Backups are stored in Google Cloud's Johannesburg, South Africa region (africa-south1). This is a transfer outside Ghana; the encryption above means the personal details in it can't be read by Google or by us. Two background tasks (usage counts, and carrying out deletions you have asked for) run in Google's Belgium region. They do not store your records there.
How long we keep it
Your backup stays until you delete your account. Records on your phone stay until you delete them or remove the app. Ghanaian rules may require agents to keep transaction and ID records for a minimum period: please check what applies to you before deleting. [CONFIRM MINIMUM RETENTION PERIOD]
Your choices and rights
- Use the app without cloud backup: everything stays on your phone.
- Delete your cloud account and backup at any time: in the app (Settings › Cloud backup › Delete my account) or on the account deletion page.
- If you signed in with your mobile number, deleting needs a text code and your recovery passphrase. If you have forgotten the passphrase, your backup is deleted after a 7-day wait, and we text you first.
- Ask us what we hold about you, or to correct it, at [CONTACT EMAIL]. You can also complain to the Data Protection Commission of Ghana.
Telling your customers
A simple way to explain it: "I keep a record of this transaction and your ID in my AgentBook app, as the network requires. It stays locked on my phone and in my encrypted backup. Nobody else can read it."
Security
PIN lock with lockout, optional fingerprint unlock, screenshot blocking, no phone backups to other services, encrypted exports only after your PIN, and remote sign-out of lost phones.
Changes
If we change this policy we will update the date above and tell you in the app.
AgentBook is independent and not affiliated with MTN, Telecel or AT.