PART A: PRIVACY POLICY
Important note: This Privacy Policy is a working business draft prepared for publication and operational use. It should be reviewed by Ghana-qualified legal counsel and aligned with the company’s Data Protection Commission registration details before publication.
1. Introduction
This Privacy Policy explains how Logistics Connect Limited, trading under or operating the Kargonet brand, collects, uses, stores, shares and protects personal information when customers, recipients, employees, riders, corporate clients, agents and other users access or use the Kargonet Application, Client Portal and related online services. For purposes of this Privacy Policy, 'Kargonet', 'we', 'us' and 'our' refer to Logistics Connect Limited. 'You' refers to any person who uses the app, website, client portal, rider tools, tracking pages, customer service channels, or any related service.
2. Scope of This Privacy Policy
This Policy applies to personal data processed through:
- Shipment booking, pickup, sorting, storage, delivery and return services.
- The Kargonet app, client portal, online tracking pages, rider/driver tools, and administrative dashboards.
- Customer service, complaints, claims, compensation, insurance, billing and account support.
- Notifications sent by SMS, email, phone, WhatsApp or other approved communication channels.
- Security, audit, compliance, fraud prevention and incident management activities.
3. Data Controller and Contact Details
The data controller for the services is Logistics Connect Limited, a company operating in Ghana. Before publication, insert the company’s registered office address, Data Protection Commission registration number if applicable, and the official privacy contact email.
- Company: Logistics Connect Limited / Kargonet
- Address: Suit A5, 4th Floor TDC Towers, Tema – Community Two
- Privacy Contact: support@mykargonet.org
- Telephone: +233244112403
- Data Protection Commission Registration Number: Not available now
4. Personal Data We Collect
Depending on your role and the service used, we may collect the following categories of personal data:
- Identity and contact details: full name, phone number, email address, company name, department, job title and user ID.
- Sender and recipient details: sender name, sender address, recipient name, recipient address, delivery location, phone number and email address.
- Shipment details: tracking number, barcode, parcel description, declared value, weight, dimensions, service type, special handling instructions, pickup and delivery notes.
- Proof records: proof of pickup, proof of delivery, signatures, recipient confirmation, delivery notes, call attempts, timestamped scans and delivery photos where required.
- Account and login data: username, role, permissions, authentication records, password reset records, session information and audit logs.
- Operational records: dispatch assignments, rider/driver ID, vehicle assignment, route information, status updates, failed delivery reason codes, cancellation notes, returns and incident reports.
- Payment and billing records: invoice details, service charges, payment reference, account status and approved invoicing information. Riders do not collect cash or mobile money for deliveries unless a separate written company process is approved.
- Customer support records: inquiries, complaints, claims, feedback, documents submitted, resolutions, escalation history and communications.
- Technical data: device type, browser, IP address, login time, app version, crash logs, cookies and similar identifiers.
- Location data: approximate or precise location data where this is enabled for rider dispatch, delivery verification, route monitoring or security.
5. How We Collect Personal Data
- Directly from customers, senders, recipients, employees, riders, corporate clients and account administrators.
- Through the app, client portal, booking forms, tracking pages, ERP modules, rider tools and customer service channels.
- From scans, barcodes, delivery notes, signatures, photographs, route updates and system-generated status events.
- From third parties involved in the service, such as corporate clients, insurers, logistics partners, payment providers, email/SMS providers, cloud hosting providers, regulators and law enforcement agencies where applicable.
6. Why We Use Personal Data
We process personal data for legitimate courier, logistics, technology, compliance and customer service purposes, including to:
- Create shipments, barcodes, tracking numbers and customer accounts.
- Collect, sort, store, dispatch, deliver, return or reattempt shipments.
- Verify sender and recipient details, delivery addresses and proof of delivery or pickup.
- Provide real-time or near real-time shipment tracking and customer notifications.
- Operate the ERP, client portal, rider application, dashboards, reports and audit trails.
- Communicate about pickup windows, delivery windows, failed delivery attempts, rescheduling, complaints, claims and service updates.
- Investigate lost, damaged, delayed, cancelled, suspicious or disputed shipments.
- Process compensation claims, insurance requests, invoices, refunds, credits and account statements.
- Protect parcels, customers, staff, facilities, vehicles, systems and company assets.
- Prevent fraud, unauthorized access, misuse of accounts, falsified scans and security incidents.
- Comply with Ghanaian law, regulatory obligations, court orders, law enforcement requests and applicable courier/postal requirements.
- Improve our services, app performance, operational reporting, route planning and customer experience.
7. Lawful Basis for Processing
We process personal data only where we have a lawful basis. Depending on the activity, this may include:
- Performance of a contract: to provide courier, pickup, delivery, tracking, billing and support services requested by the customer or corporate client.
- Legal or regulatory obligation: to comply with applicable laws, regulators, records, tax, insurance, security, incident reporting and dispute requirements.
- Legitimate business interest: to operate a secure, traceable and reliable courier service, prevent fraud, maintain audit records, protect parcels and resolve disputes.
- Consent: where required for optional communications, optional insurance, location features, marketing or use of data for purposes not covered by the original service request.
- Vital interests or public interest: where urgent safety, emergency, security, crime prevention or lawful authority requirements apply.
8. Sharing and Disclosure of Personal Data
We do not sell personal data. We may share personal data only where necessary and lawful, including with:
- Authorized employees, riders, drivers, dispatchers, hub personnel, managers, customer service and finance staff based on role-based access.
- Senders, recipients and corporate clients for shipment status, delivery confirmation, claims and service support.
- Technology providers that host, secure, maintain or support the app, ERP, cloud database, email/SMS notification tools, analytics and backup systems.
- Payment processors, banks, insurers and licensed insurance partners where payment, refund, claim or insurance processing is required.
- Professional advisers, auditors and consultants under confidentiality obligations.
- The Postal and Courier Services Regulatory Commission, Data Protection Commission, Cyber Security Authority, National Insurance Commission, tax authorities, courts, law enforcement or other public authorities where required or permitted by law.
- A successor entity in the event of a merger, restructuring, acquisition, sale of business or transfer of operations, subject to appropriate confidentiality and data protection safeguards.
9. International Data Transfers and Cloud Hosting
Our technology systems may use cloud infrastructure and service providers that store or process data outside Ghana. Where personal data is transferred outside Ghana, we will take reasonable steps to ensure that appropriate contractual, technical and organizational safeguards are in place and that the transfer complies with applicable data protection requirements.
10. Data Security
We use reasonable technical and organizational measures to protect personal data from unauthorized access, misuse, loss, alteration or disclosure. These measures may include:
- Role-based access controls and user permissions.
- Password protection, authentication controls and account monitoring.
- Encryption in transit and, where available, encryption at rest.
- System logs, audit trails and tracking of key operational events.
- Restricted access to customer records, delivery records, claims files and management reports.
- Backups, incident response processes and device-loss escalation procedures.
- Staff and rider training on confidentiality, customer data protection and proper system use. No online system is completely risk-free. Users must protect their login credentials, avoid sharing passwords and promptly report suspected unauthorized access.
11. Data Retention
We retain personal data only for as long as necessary for the purposes for which it was collected, including service delivery, legal compliance, audit, tax, insurance, security, claims and dispute resolution. Our general retention approach is:
- Package, shipment, pickup, delivery and proof records: normally retained for a minimum of five (5) years for operational, legal, audit and dispute resolution purposes.
- Insurance, claims and compensation records: normally retained for at least five (5) years or longer where required by law, insurer requirements or active disputes.
- Customer interaction and complaint records: retained for the duration necessary to manage the customer relationship, improve service quality and defend legal claims, unless deletion is required by law.
- CCTV/security footage: retained according to facility security policy, unless needed for an investigation, incident, claim or legal requirement.
- Account and audit logs: retained for security, compliance and system integrity purposes for a reasonable period based on risk and legal requirements. At the end of the retention period, personal data may be securely deleted, anonymized or archived where lawful and necessary.
12. Your Data Protection Rights
Subject to applicable law and verification of identity, you may have rights to:
- Request access to personal data we hold about you.
- Request correction of inaccurate or incomplete personal data.
- Request deletion, blocking or restriction of certain personal data where lawful.
- Object to processing in certain circumstances.
- Withdraw consent where processing is based on consent.
- Request information about how your personal data is used and shared.
- File a complaint with the Data Protection Commission of Ghana if you believe your rights have been violated. To exercise your rights, contact us using the contact details in Section 3. We may request information to verify your identity and may refuse or limit a request where permitted by law, including where records must be retained for legal, claims, safety, regulatory or fraud-prevention reasons.
13. Cookies and Similar Technologies
Our website, app and portal may use cookies, local storage or similar technologies to support login sessions, improve security, remember preferences, analyze performance and maintain the reliability of the service. You may be able to control cookies through your browser settings, but disabling cookies may affect login, tracking and portal functionality.
14. Marketing Communications
We may send service-related communications that are necessary for the operation of shipments, accounts, tracking, delivery and claims. We will seek consent where required before sending promotional or marketing messages. You may opt out of marketing messages, but you may still receive operational messages related to active shipments, accounts, billing, security or legal notices.
15. Children and Minors
Our services are not directed at children. Where a minor is a recipient or beneficiary of a delivery, personal data must be provided by a parent, guardian, school, organization or other responsible adult with authority to provide the information.
16. Third-Party Links and Services
The app or website may link to third-party platforms, payment pages, maps, messaging tools or external websites. We are not responsible for the privacy practices or content of third-party services. Users should review the privacy notices of those services before providing personal data.
17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Updated versions will be published through the app, website, client portal or other appropriate channels. Material changes may be communicated by email, SMS, in-app notice or other reasonable methods.
18. Contact and Complaints
For privacy questions, complaints or requests, contact:
- Logistics Connect Limited / Kargonet
- Address: Suit A5, 4th Floor TDC Towers, Tema – Community Two
- Email: support@mykargonet.org
- Telephone: +233244112403 You may also contact the Data Protection Commission of Ghana if you are not satisfied with how your concern has been handled.
