Privacy Policy

1. Introduction

FrigX (“FrigX”, “we”, “us” or “our”) is committed to protecting the privacy and personal information of our customers, suppliers, drivers, equipment operators, business partners and other users. This Privacy Policy explains how FrigX collects, uses, stores, protects and shares personal information when you access or use the FrigX website, web application, mobile application, communication channels and related services (collectively, the “Platform”).

FrigX operates a technology-enabled marketplace connecting customers with verified suppliers, drivers, equipment owners and service providers for services including construction-material delivery, water delivery, septic/waste services, transportation, machinery and equipment hire and related services.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Our Data Protection Responsibilities

FrigX will process personal information in accordance with applicable laws of the Republic of Ghana, including the Data Protection Act, 2012 (Act 843) and applicable requirements of the Data Protection Commission. Where FrigX is required to register as a data controller, FrigX will comply with the applicable registration and compliance requirements of the Data Protection Commission.

The Data Protection Act provides requirements concerning the processing of personal data, including the purposes of processing, categories of data subjects, recipients, possible international transfers and security measures.

3. Information We Collect

We collect information that is reasonably necessary to operate FrigX and provide our services.

3.1 Customer Information

Depending on how you use FrigX, we may collect:

• Full name
• Telephone number
• Email address
• Account details
• Password or authentication information
• Delivery address
• Delivery location
• Order information
• Payment transaction information
• Communication records
• Reviews and ratings
• Customer-service records
• Information voluntarily provided by you

3.2 Provider Information

Providers may be required to provide additional information because FrigX needs to verify businesses, suppliers, drivers and operators before allowing them to provide services through the Platform. This may include:

• Full name
• Telephone number
• Email address
• Residential or business address
• Ghana Card or other identification information
• Business registration information
• Driver’s licence information
• Vehicle registration information
• Vehicle ownership or authorisation documents
• Insurance information
• Operating licences and permits
• Equipment and machinery information
• Bank account or mobile-money details
• Business photographs
• Vehicle photographs
• Verification documents
• Service and pricing information

4. Location Information

Location information is important to the operation of a logistics marketplace. FrigX may process location information when necessary to:

• Identify the Customer’s delivery location
• Provide directions to a Provider
• Coordinate deliveries
• Facilitate transportation
• Confirm delivery or service completion
• Improve logistics
• Detect suspicious or fraudulent activity
• Provide location-based services

Future GPS Tracking

Where FrigX introduces real-time GPS or vehicle-tracking functionality, the Platform will provide appropriate notices and permissions. Depending on the feature, location information may be collected while an Order is active. FrigX will not use continuous location tracking beyond what is reasonably necessary for the applicable service unless the user has been appropriately informed and the processing is otherwise lawful.

Users may control location permissions through their device settings. However, disabling location permissions may prevent certain FrigX services from functioning correctly.

5. Order and Transaction Information

When you request or provide a service through FrigX, we may collect:

• Order number
• Service requested
• Product or material type
• Quantity
• Price
• Delivery location
• Date and time
• Customer information
• Provider information
• Payment status
• Delivery status
• Cancellation information
• Refund information
• Complaints and dispute information
• Proof-of-delivery information

This information allows us to facilitate and maintain an accurate record of Transactions.

6. Payment Information

FrigX may facilitate payments through authorised third-party payment providers. Depending on the payment method, payment information may be processed directly by the relevant payment provider. FrigX may receive information such as:

• Amount paid
• Transaction reference
• Payment status
• Payment date
• Refund status
• Payment method

Where payment-card information is processed directly by a payment provider, FrigX does not intend to store complete card details on its own systems unless necessary and lawfully permitted.

7. Provider Verification

FrigX may conduct verification before allowing a Provider to operate on the Platform. Verification may include:

• Identity verification
• Business verification
• Vehicle verification
• Equipment verification
• Licence verification
• Permit verification
• Insurance verification
• Document verification
• Other reasonable checks required for safety, fraud prevention and Platform integrity

Verification information will be accessed only by authorised personnel or service providers who require it for legitimate business, compliance or operational purposes. A Provider’s verification status does not mean that FrigX guarantees every aspect of that Provider’s services.

8. How We Collect Information

We may collect information:

1. Directly from you;
2. When you create an account;
3. When you place or accept an Order;
4. When you submit Provider documentation;
5. When you communicate with FrigX;
6. Through payment transactions;
7. Through use of the Platform;
8. Through cookies and similar technologies;
9. From other users involved in a Transaction;
10. From authorised verification providers;
11. From payment providers and technology partners; and
12. From publicly available business or regulatory information where appropriate.

9. Why We Use Your Information

FrigX may process your personal information for the following purposes:

9.1 Providing Services

To:

• Create and manage accounts
• Process Orders
• Connect Customers and Providers
• Coordinate deliveries
• Facilitate payments
• Process refunds
• Provide customer support
• Confirm service completion

9.2 Provider Verification

To verify:

• Identity
• Business status
• Vehicles
• Equipment
• Licences
• Permits
• Insurance
• Other information necessary for Provider onboarding

9.3 Safety and Fraud Prevention

To:

• Detect fraudulent activity
• Investigate suspicious Transactions
• Prevent misuse
• Protect Customers and Providers
• Investigate complaints
• Protect FrigX systems
• Enforce our Terms and Conditions

9.4 Improving FrigX

To:

• Analyse Platform performance
• Improve features
• Develop new services
• Understand usage patterns
• Improve customer experience
• Identify technical problems

9.5 Legal Compliance

To comply with applicable laws, regulations, court orders, lawful government requests and other legal obligations.

10. Lawful Processing

FrigX will process personal information only where there is a lawful basis to do so. Depending on the circumstances, this may include:

• Your consent;
• Providing a service you have requested;
• Performing a contract;
• Complying with a legal obligation;
• Protecting legitimate business interests;
• Preventing fraud and protecting safety;
• Establishing or defending legal claims; or
• Another lawful basis recognised under applicable law.

Where consent is required, FrigX will request it appropriately.

11. Information Shared with Customers and Providers

FrigX may share limited information between the parties to a Transaction when necessary to provide the requested service. For example, a Provider may receive:

• Customer name;
• Contact information;
• Delivery location;
• Order details; and
• Relevant delivery instructions.

A Customer may receive appropriate Provider information necessary to identify and coordinate with the Provider. FrigX will seek to limit information shared to what is reasonably necessary for the Transaction.

12. Third-Party Service Providers

FrigX may use trusted third parties to help operate the Platform. These may include providers of:

• Payment processing
• Cloud hosting
• Database infrastructure
• Mapping
• GPS/location services
• SMS
• WhatsApp or messaging services
• Email
• Analytics
• Identity verification
• Document verification
• Cybersecurity
• Customer support
• Technical development

Where these providers process personal information on behalf of FrigX, FrigX will take reasonable steps to require appropriate privacy and security protections.

13. International Data Processing

Some FrigX technology or service providers may process information outside Ghana. Where personal information is transferred or processed outside Ghana, FrigX will take reasonable steps to ensure that the transfer and subsequent processing comply with applicable data-protection requirements. Where required, the relevant international processing arrangements will be reflected in FrigX’s data-protection compliance records.

14. Cookies

FrigX may use cookies and similar technologies to:

• Keep users signed in;
• Remember preferences;
• Maintain security;
• Improve Platform performance;
• Understand Platform usage;
• Analyse traffic; and
• Improve the user experience.

You may control cookies through your browser settings. Some Platform functions may not operate correctly if certain cookies are disabled.

15. Communications

FrigX may communicate with you through:

• Email
• Telephone
• SMS
• WhatsApp
• In-app notifications
• Other communication channels supported by the Platform

Service-related communications may include:

• Order confirmations
• Provider assignment
• Delivery updates
• Payment notifications
• Account notifications
• Security alerts
• Customer-support communications

These communications are necessary for operating the service and may continue even if you opt out of promotional messages.

16. Marketing Communications

Where permitted by applicable law, FrigX may send promotional information concerning:

• New services
• Promotions
• FrigX features
• Provider opportunities
• Business opportunities
• Events
• Platform announcements

You may opt out of marketing communications at any time through the unsubscribe mechanism provided or by contacting FrigX.

17. Reviews and User Content

Customers and Providers may be permitted to submit:

• Reviews
• Ratings
• Photographs
• Comments
• Feedback
• Complaints

Users must not submit content that is unlawful, fraudulent, abusive, threatening, discriminatory or misleading. FrigX may use reviews and feedback to operate, monitor and improve the Platform, subject to applicable law.

18. Data Retention

FrigX will retain personal information for no longer than reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law. Information may be retained for purposes including:

• Transaction records
• Accounting and financial records
• Tax requirements
• Dispute resolution
• Fraud prevention
• Legal claims
• Regulatory compliance
• Security investigations
• Enforcement of agreements

When information is no longer required, FrigX will take reasonable steps to securely delete, anonymise or dispose of it.

19. Data Security

FrigX will take reasonable technical and organisational measures to protect personal information. These measures may include:

• Access controls
• Authentication
• Role-based permissions
• Secure hosting
• Encryption where appropriate
• Audit logs
• Security monitoring
• Backups
• Staff confidentiality requirements
• Secure handling of Provider documents

No internet-based system can be guaranteed to be completely secure. Users are responsible for protecting their passwords, devices and account credentials.

20. Data Breaches

Where FrigX becomes aware of a personal-data security incident, we will take reasonable steps to:

1. Investigate the incident;
2. Contain and mitigate the incident;
3. Assess the potential impact;
4. Take appropriate corrective measures; and
5. Notify affected persons or the relevant authority where required by applicable law.

21. Your Privacy Rights

Subject to applicable law, you may have rights concerning your personal information, including rights to:

• Request access to personal information held about you;
• Request correction of inaccurate information;
• Request deletion where legally applicable;
• Object to certain processing;
• Request restriction of certain processing;
• Withdraw consent where processing is based on consent; and
• Exercise other rights available under applicable data-protection law.

Some rights may be subject to lawful limitations. FrigX may request reasonable identification or verification before processing a request involving personal information.

22. Requesting Access or Correction

To request access to, correction of, or information concerning your personal data, contact:

Your request should include enough information for FrigX to identify your account and understand the nature of your request. FrigX will handle requests within the applicable legal requirements.

23. Account Deletion

You may request the closure of your FrigX account. Where legally permissible, FrigX may delete or anonymise information associated with the account. However, some information may need to be retained because of:

• Legal obligations;
• Accounting requirements;
• Tax requirements;
• Fraud prevention;
• Dispute resolution;
• Security requirements; or
• Pending legal proceedings.

24. Children

FrigX’s Platform is intended primarily for adults and businesses capable of entering legally binding agreements. FrigX does not knowingly collect personal information from children where such collection is prohibited by applicable law. If you believe a child has provided personal information to FrigX improperly, contact us so that the matter can be investigated.

25. Third-Party Websites

The Platform may contain links to third-party websites or services. FrigX does not control the privacy practices of those third parties. Users should review the privacy policies of third-party services before providing personal information.

26. Business Transfers

If FrigX is involved in a merger, acquisition, investment, restructuring, sale of assets or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law and appropriate privacy safeguards.

27. Changes to this Privacy Policy

FrigX may update this Privacy Policy periodically. The Last Updated date will be changed whenever material revisions are made. Where required by law, FrigX will provide additional notice or obtain consent before implementing material changes.

28. Governing Law

This Privacy Policy shall be governed by the applicable laws of the Republic of Ghana, including applicable data-protection legislation.

29. Data Protection Commission

FrigX recognises the role of Ghana’s Data Protection Commission (DPC) in regulating the processing of personal data in Ghana. The DPC is the statutory body responsible for enforcing Ghana’s data-protection framework under the Data Protection Act, 2012 (Act 843).

FrigX will take reasonable steps to comply with applicable DPC requirements, including registration and compliance obligations applicable to its activities. The DPC’s compliance requirements may include information concerning the organisation, categories of data subjects, purposes of processing, recipients, countries outside Ghana where data may be processed and security measures.

30. Contact FrigX

For privacy questions, complaints or requests relating to personal information: