Privacy Policy

This privacy notice for STRRIA & Co. ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

Visit our website at http://www.strria.com, or any website of ours that links to this privacy notice
Download and use our mobile application (STRRIA), or any other application of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@strria.com.

Summary of Key Points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with STRRIA & Co. and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitive personal information, when necessary, with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what STRRIA & Co. does with any information we collect? Review the privacy notice in full.

What Information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

name
phone numbers
email addresses
mailing addresses
usernames
passwords
billing addresses

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

financial data

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Mobile Money. You may find their privacy notice link(s) here: http://www.strria.com.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
Location Data. If you allow location access in the STRRIA app, we ask for it only while you are using the app, and we use it to show delivery times and options near you and to understand which areas buyers want deliveries to. We keep only your town or area (and, where a feature needs it, a location rounded to about 1 km). We do not keep your precise location, altitude, speed or direction. We keep your latest location and no more than 30 days of history. You can turn location access off at any time in your device settings or in the app's settings; the app still works, but delivery estimates may be less accurate. Separately, we work out an approximate town and country from your IP address when you sign in, as described in "Signing in, devices and account security".

How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Develop and display personalized and relevant advertising content for our users
- Analyze how our Services are used so we can improve them to engage and retain users
- Support our marketing activities
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: Geo Location of Users; and other similar information. A full list of what we use information for can be found in this section and in the previous section titled "HOW DO WE PROCESS YOUR INFORMATION?". We obtain and store on your device ("cache") your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Notice.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third- party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

The STRRIA launch waitlist

In Short: If you join the waitlist on strria.com, we keep your email address only to tell you when STRRIA launches and to send a little launch news. We delete it 90 days after the launch email, or straight away if you unsubscribe.

What we collect. Your email address; the page you signed up on; which version of the sign-up wording you agreed to; and the date and time you signed up, were sent the welcome email and were sent the launch email. We do not ask for your name and we do not store your IP address with your sign-up.

Why, and our legal basis. We use your email address to send you a welcome email, an email when STRRIA launches, and a small number of launch updates in the weeks after. We rely on your consent, which you give by submitting the form. We do not use it for anything else, we do not combine it with other data to build a profile of you, and we never sell it.

Keeping the form safe from bots. The form uses Cloudflare Turnstile to check that a person, not a bot, is signing up. Turnstile looks at technical signals from your browser and device (such as your IP address and browser details) for this check only. Cloudflare's own privacy policy applies to that check. Our servers also count sign-up attempts per IP address for a short time to stop abuse; this count is kept in memory and is not linked to your email address.

Who handles it for us. Your email address is stored on our servers (hosted by DigitalOcean) and sent through our email delivery provider. These providers act on our instructions and may process data outside Ghana, with appropriate safeguards in place.

How long we keep it. We delete your email address 90 days after we send the launch email. If you unsubscribe, we delete it immediately. If you sign up twice, we keep one record and do not email you again.

Your choices and rights. Every email has an unsubscribe link, and you can also email us at info@strria.com. You can ask to see or delete what we hold about you at any time. If you are unhappy with how we have handled your data, you can complain to the Data Protection Commission of Ghana, or, if you live in the UK, to the Information Commissioner's Office (ICO). The waitlist is not intended for anyone under 18.

Signing in, devices and account security

In Short: To keep your account safe, we record which devices are signed in to it, roughly where they are, and when they were last used. Only you can see this list, and you can sign any device out.

What we record for each signed-in device. The device's name and model, its operating system and app version, its language setting, the IP address it signed in from, an approximate town and country worked out from that IP address, when it signed in, and when it was last active. We work out the approximate place ourselves, using a location database kept on our own servers; we do not send your IP address to anyone else to do this, and we never record a precise location from it. The location database we use is IP to City Lite by DB-IP, licensed under CC BY 4.0.

Why. So you can see where your account is signed in and sign out anything you don't recognise; so we can warn you about a sign-in from a new device; and to protect accounts against misuse and fraud. Our legal basis is our legitimate interest in keeping accounts and payments secure.

How long we keep it. While the device stays signed in, and for 30 days after it is signed out or expires, so that we can look into any suspicious activity. After that we delete it.

Staying signed in. You stay signed in on a device for up to 30 days. After that, or if your password is changed or reset, or you sign the device out from another device, we ask you to sign in again. When you sign out yourself, the app forgets your name and email address on that device.

New sign-in alerts. When your account is signed in to on a device we have not seen before, we tell you by push notification on your other signed-in devices and by email. The alert shows the device, its approximate town and country, and the time, so you can sign it out if it was not you.

Face ID and fingerprint. If you choose to lock the app with Face ID, your fingerprint or face, the check happens on your phone. We never receive or store your fingerprint or face data.

Passwords, PINs and codes. We never store your password or wallet PIN as you typed them; we only keep a secure, one-way scrambled form (a hash). You can also sign in with a one-time code sent to your verified email address or phone number instead of your password. Before you change your password, wallet PIN, email address or phone number, we send a one-time code to your verified phone number or email address to confirm it is you. When you change your password, we sign you out on all your other devices, keep you signed in on the device you used, and email you to confirm the change. After several wrong PIN attempts we lock the wallet PIN for a short time.

Deleting your account

In Short: You can delete your STRRIA account at any time from the app. We give you 30 days to change your mind, then we remove your personal information, apart from a small number of records the law requires us to keep, which we keep without your name.

How to delete it. In the STRRIA app, go to Account, then Sign-in and security, then Delete account. We will send a code to your phone or email to confirm it is you. If you no longer have the app, go to strria.com/delete-account and enter the email address or phone number on your account; we send a code to it to confirm it is you before acting on the request. You can also email support@strria.com, and we will confirm the request the same way.

Before you can delete it. You need to finish or cancel any open orders, returns or reported problems, and withdraw any money in your STRRIA wallet. The app shows you exactly what is left to do. Your listings are ended for you.

What happens next. We sign you out on every device straight away, hide your profile and listings, and stop all marketing emails. 30 days later we remove your personal information and anonymise what is left of your account, so it can no longer be linked to you. If you sign in during those 30 days you can choose to keep your account. We email you when you ask, and again when the deletion is complete.

What we delete. Your profile and photo, contact details, addresses, saved items, follows, settings, signed-in devices, location history, notification tokens and listings. Messages you wrote are removed; the people you talked to keep their own side of the conversation.

What we keep, and why. Records of orders, payments, refunds, payouts and wallet transactions, for as long as tax, accounting and financial laws require; and records needed to prevent fraud, handle disputes or enforce our terms, for as long as that need lasts. These records are no longer linked to your name or contact details where the law allows. Reviews you left stay visible, shown as written by a "Former member". Copies in our backups are deleted when those backups expire on their normal schedule.

Your rights. This is in addition to your right to ask us for a copy of your information or to correct it. If you are unhappy with how we handled your request, you can complain to the Data Protection Commission of Ghana, or, if you live in the UK, to the Information Commissioner's Office (ICO).

How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@strria.com.

What are your privacy rights?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can:

You can delete your account in the STRRIA app, or ask us to delete it if you no longer have the app. See "Deleting your account" for how it works, what we delete, and the limited records we must keep.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.

If you have questions or comments about your privacy rights, you may email us at info@strria.com.

Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do- Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

How can you contact us about this notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at info@strria.com, or contact us by post at:STRRIA & Co.

How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.