Privacy Policy

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, phone number, and password when you register an account, plus the account identifier we assign to it.
• Business Information: Company name, registration number, address, banking details, and (for waste creators) an annual revenue range, for facility operators, collector companies, and creator companies.
• Driver Information: Details collector companies enter about their drivers for fleet management, including identity document or passport number, driving licence number and dates, notes, a driver portrait photo, and photos of the front and back of the driving licence.
• Operational and Transaction Records: Drop-off and collection records, waste-transfer manifests, and invoices (amounts, status, and line items) generated as you use the Services.
• Verification Documents: Business registration documents, permits, and other documents uploaded during onboarding.
• Digital Signatures: Signatures captured during drop-off completion.

2.2 Information Collected Automatically

• Location Data: With your permission, we collect precise or approximate location data (depending on the accuracy you grant) to verify facility presence during drop-offs and, for collection company users, to provide live trip tracking and real-time updates while the app is open and in use. Location is only accessed while the app is in the foreground; we do not track your location in the background.
• Camera Data: With your permission, we access your camera to scan QR codes at collection facilities and to capture photos of drop-offs, vehicles, verification documents, driver portraits, and driving licences. Photos you capture are stored as part of your operational records.
• Device Information: Device type, operating system, app version, and unique device identifiers for troubleshooting and analytics.
• Usage Data: How you interact with our Services, including features used, timestamps, and performance metrics.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain our Services.
• Process and manage waste collection drop-offs, including scheduling, arrival verification, and completion tracking.
• Generate invoices and manage billing between facilities, collectors, and creators.
• Track tank capacity and storage levels at collection facilities.
• Verify your identity and the identity of your business during onboarding.
• Send operational notifications (e.g. drop-off status updates, tank capacity alerts).
• Improve, personalise, and expand our Services.
• Comply with legal obligations and enforce our terms.

4. Data Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

• Between Platform Users: Facility operators, collector companies, and creator companies may see limited information about each other as necessary to coordinate waste collection operations. This includes company names, contact details, and drop-off schedules; a collector's live location during trips (shown to the facility and the customer awaiting the collection); completed manifest records (photos and digital signatures); and invoice details (amounts, status, and line items), which are visible to the companies involved in that transaction.
• Service Providers: We use third-party services for hosting (Microsoft Azure), document storage (Cloudflare), and authentication. These providers process data on our behalf under strict contractual obligations.
• Legal Requirements: We may disclose information if required by law, regulation, legal process, or governmental request.

5. Data Storage and Security

Your data is stored on secure servers hosted by Microsoft Azure in the South Africa North region. Documents are stored using Cloudflare R2 with encryption at rest. We implement industry-standard security measures including:

• Encrypted data transmission (TLS/SSL).
• Hashed and salted password storage.
• Role-based access controls.
• Regular security assessments.

While we strive to protect your information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide our Services. Business records (invoices, drop-off records, production data) are retained in accordance with applicable South African tax and regulatory requirements. You may request deletion of your account and personal data at any time by contacting us.

7. Your Rights

In accordance with the Protection of Personal Information Act (POPIA) and other applicable laws, you have the right to:

• Access the personal information we hold about you.
• Request correction of inaccurate information.
• Request deletion of your personal information.
• Object to the processing of your personal information.
• Withdraw consent for optional data collection (e.g. location tracking).
• Lodge a complaint with the Information Regulator of South Africa.

8. Device Permissions

Our mobile application may request the following permissions:

• Camera: Used for scanning QR codes at collection facilities and capturing photos of drop-offs, vehicles, verification documents, driver portraits, and driving licences.
• Location (Foreground): Used to verify your presence at a facility during drop-off sign-off and, for collection company users, to provide live trip tracking while the app is open and in use. The app only accesses your location while it is in the foreground; it does not track your location in the background.

All permissions are optional and can be managed through your device settings. The app will request permission before accessing any of these features.

9. Offline Data

Our mobile app stores limited data locally on your device to enable offline functionality. This includes cached operational data and queued actions that sync when connectivity is restored. Local data is cleared when you sign out.

10. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. Your continued use of the Services after changes constitutes acceptance of the updated policy.

12. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

• Email: contact@kulueco.com
• Website: www.kulueco.co.za