PRIVACY POLICY

Last Updated: April 22, 2025

1. INTRODUCTION

FleetFlow ("we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our fleet management and delivery logistics platform and related services (collectively, the "Services").

This Privacy Policy has been designed to comply with the Protection of Personal Information Act 4 of 2013 (POPIA) of South Africa, as well as international privacy standards including the General Data Protection Regulation (GDPR) and the UK Privacy and Electronic Communications Regulations (PECR).

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services.

2. INFORMATION WE COLLECT

We collect several types of information from and about users of our Services, including:

2.1 Personal Information

Personal information refers to information that identifies you as an individual or relates to an identifiable individual. We may collect the following categories of personal information:

Identity Information: Full name, username or similar identifier, title, date of birth, gender, profile picture
Contact Information: Email address, telephone numbers, physical address, business address
Account Information: Login credentials, password, account preferences, billing information
Financial Information: Payment card details, bank account information, transaction history
Employment Information: Job title, employer information, employee ID
Vehicle Information: Vehicle registration, make, model, year, insurance details
Location Information: GPS data, route information, delivery locations, geolocation data
Communication Information: Records of your communications with us, feedback, survey responses
Technical Information: IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information

2.2 Usage Information

We may collect information about how you use our Services, including:

Pages or screens you view
Links you click
Actions you take within the Services
Time spent on certain pages
Referring website address
Access times and dates
App performance data

2.3 Cookies and Similar Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities and to distinguish you from other users of our Services. For detailed information about the cookies we use, please see our Cookie Notice.

3. HOW WE COLLECT YOUR INFORMATION

We collect information through:

3.1 Direct Interactions

Information you provide when you:

Create an account
Fill in forms on our platform
Subscribe to our services
Request marketing materials
Provide feedback or contact us
Upload content to our platform

3.2 Automated Technologies

Information collected automatically through:

Cookies and similar tracking technologies
Server logs
Mobile device identifiers
Location technologies
Analytics tools

3.3 Third Parties

Information we receive from third parties, such as:

Business partners
Service providers
Payment processors
Public databases
Social media platforms (if you choose to link your account)

4. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

4.1 Provision of Services

To provide and maintain our Services
To process and complete transactions
To manage user accounts
To optimise delivery routes and logistics
To track deliveries and provide status updates
To facilitate communication between drivers, businesses, and customers

4.2 Improvement and Development

To improve our Services
To develop new features, products, or services
To conduct data analysis and testing
To monitor usage patterns and performance

4.3 Communication

To communicate with you about your account or transactions
To provide customer support
To send service-related notices and updates
To respond to your comments, questions, and requests

4.4 Marketing and Promotion

To send promotional communications (with your consent where required by law)
To deliver relevant content and advertisements
To measure the effectiveness of marketing campaigns
To invite you to events or participate in surveys

4.5 Safety and Security

To verify your identity
To detect and prevent fraud, abuse, and security incidents
To debug and repair errors
To protect the rights, property, or safety of our users, employees, or others

4.6 Legal Compliance

To comply with applicable laws, regulations, and legal processes
To enforce our terms of service and other agreements
To protect our rights, privacy, safety, or property

5. LEGAL BASIS FOR PROCESSING

Under South African law (POPIA) and applicable international privacy laws, we process your personal information based on one or more of the following legal grounds:

5.1 Performance of a Contract

Processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.

5.2 Legitimate Interests

Processing is necessary for our legitimate interests or the legitimate interests of a third party, provided these interests are not outweighed by your rights and interests.

5.3 Compliance with Legal Obligations

Processing is necessary for compliance with our legal obligations.

5.4 Consent

You have given consent to the processing of your personal information for one or more specific purposes. Where we rely on consent, you have the right to withdraw your consent at any time.

5.5 Protection of Vital Interests

Processing is necessary to protect your vital interests or those of another person.

6. DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to the following categories of recipients:

6.1 Service Providers

Third-party vendors, consultants, and other service providers who perform services on our behalf, such as:

Cloud storage providers
Payment processors
Customer service providers
Analytics providers
IT and system administration providers
Professional advisers

6.2 Business Partners

Business partners with whom we jointly offer products or services, or whose products or services may be offered on our platform.

6.3 Affiliated Companies

Our subsidiaries, parent companies, and affiliates, if applicable.

6.4 Business Transfers

In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

6.5 Legal Requirements

When we believe in good faith that disclosure is necessary to:

Comply with laws, regulations, or legal processes
Protect our rights, property, or safety
Protect the rights, property, or safety of others
Investigate fraud or respond to a government request

6.6 With Your Consent

To any other third party with your prior consent.

7. INTERNATIONAL TRANSFERS

We may transfer your personal information to countries outside South Africa. When we do so, we ensure appropriate safeguards are in place to protect your information and to comply with applicable data protection laws.

These safeguards may include:

Transferring to countries that have been deemed to provide an adequate level of protection
Implementing appropriate contractual mechanisms, such as standard contractual clauses
Obtaining your explicit consent for the proposed transfer

8. DATA SECURITY

We have implemented appropriate technical and organizational measures to protect your personal information from accidental loss, unauthorized access, use, alteration, and disclosure. These measures include:

Encryption of sensitive information
Secure user authentication
Regular security assessments
Access controls and authorization procedures
Staff training on data protection
Physical security measures for our facilities

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

9. DATA RETENTION

We will retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period, we consider:

The amount, nature, and sensitivity of the personal information
The potential risk of harm from unauthorized use or disclosure
The purposes for which we process the information and whether we can achieve those purposes through other means
Applicable legal requirements

When personal information is no longer necessary, we will securely delete or anonymize it.

10. YOUR RIGHTS

Depending on your location, you may have certain rights regarding your personal information:

10.1 Under South African Law (POPIA)

Right to Access: You have the right to request access to your personal information.
Right to Correction: You have the right to request correction of your personal information.
Right to Deletion: You have the right to request deletion of your personal information.
Right to Object: You have the right to object to the processing of your personal information.
Right to Withdraw Consent: You have the right to withdraw consent previously given.
Right to Complain: You have the right to lodge a complaint with the Information Regulator.

10.2 Under EU/UK Law (GDPR/UK GDPR)

Right to Access: You have the right to request access to your personal information.
Right to Rectification: You have the right to request correction of your personal information.
Right to Erasure: You have the right to request deletion of your personal information.
Right to Restrict Processing: You have the right to request restriction of processing of your personal information.
Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format.
Right to Object: You have the right to object to the processing of your personal information.
Rights Related to Automated Decision-Making: You have rights related to automated decision-making and profiling.

To exercise any of these rights, please contact us using the details provided in the "Contact Us" section below.

11. CHILDREN'S PRIVACY

Our Services are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we will take steps to remove that information from our servers.

12. THIRD-PARTY LINKS AND SERVICES

Our Services may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy does not apply to such third-party services. We recommend reviewing the privacy policies of any third-party services before providing any information to them.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last Updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

If we make material changes to this Privacy Policy, we will notify you either through the email address you have provided to us or by placing a prominent notice on our website or application.

14. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

FleetFlow
Email: info@fleetflow.co.za
Phone: 087 265 2153
Phone: 072 617 4839
Address: 87 Marjoram Avenue, Sinoville
Pretoria, 0129
South Africa

Information Regulator (South Africa)
If you believe that we have not addressed your concern adequately, you have the right to lodge a complaint with the Information Regulator:

Website: https://www.justice.gov.za/inforeg/
Email: inforeg@justice.gov.za