1. Introduction
Grubbex Logistics Limited ("Grubbex," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, disclose, and safeguard your information when you use our logistics application, website, and services (collectively, the "Services").
We are transparent about our data practices and accountable for the personal information we hold. This policy reflects our commitment to these principles.
2. Information We Collect
We may collect and process the following categories of personal data:
a. Information You Provide to Us
- Account Information: Name, email address, phone number, business name, and password when you create an account.
- Profile Information: Business address, Tax Identification Number (TIN), and other details you provide to complete your profile.
- Order and Delivery Information: Pickup and delivery addresses, package details, special instructions, and recipient contact information.
- Payment Information: Payment method details, billing address, and transaction history (processed through our secure payment partners).
- Communications: Any information you provide when contacting our support team or submitting feedback.
b. Information We Collect Automatically
- Usage Data: IP address, device information, browser type, operating system, access times, and pages viewed.
- Location Data: Real-time location information when you use our delivery tracking features (with your consent).
- Log Data: Server logs, error reports, and performance data.
c. Information from Third Parties
- Service Providers: Payment processors, mapping services (e.g., Google Maps), and communication platforms.
- Public Sources: Information available from public databases or social media platforms (where applicable).
3. How We Use Your Information
We use your personal data for the following purposes:
| Purpose | Legal Basis |
|---|---|
| To provide, maintain, and improve our Services | Contractual necessity |
| To process and fulfill delivery orders | Contractual necessity |
| To process payments and prevent fraud | Contractual necessity and legitimate interest |
| To communicate with you about your orders, account, and updates | Contractual necessity |
| To send you marketing communications (with your consent) | Consent |
| To personalize your experience and recommend services | Legitimate interest |
| To ensure security, detect fraud, and comply with legal obligations | Legal obligation and legitimate interest |
| To analyze usage and improve our Services | Legitimate interest |
4. Legal Basis for Processing (GDPR/NDPR Compliance)
We process your personal data based on one or more of the following legal grounds:
- Contractual Necessity: Processing is necessary for the performance of a contract with you (e.g., to deliver your orders).
- Consent: You have given explicit consent for specific processing activities (e.g., marketing communications).
- Legal Obligation: Processing is necessary to comply with legal requirements (e.g., tax and regulatory obligations).
- Legitimate Interests: Processing is necessary for our legitimate business interests, provided these do not override your rights and freedoms.
6. International Data Transfers
Grubbex may transfer your personal data to countries outside your jurisdiction of residence. When we do so, we ensure appropriate safeguards are in place, such as:
- Standard Contractual Clauses approved by relevant data protection authorities.
- Adequacy Decisions where the recipient country is recognized as providing an adequate level of protection.
7. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These include:
- Encryption: Data is encrypted in transit (TLS/SSL) and at rest.
- Access Controls: Strict access controls and authentication mechanisms.
- Regular Audits: Security assessments and vulnerability scans.
- Employee Training: Staff are trained on data protection and security best practices.
8. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law.
- Account Data: Retained for the duration of your account and for a reasonable period thereafter for legal and regulatory purposes.
- Transaction Data: Retained as required by tax and accounting laws (typically 5-7 years).
- Usage Data: Retained for analytics and service improvement for up to 24 months.
9. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data:
| Right | Description |
|---|---|
| Right to Access | Request a copy of the personal data we hold about you. |
| Right to Rectification | Request correction of inaccurate or incomplete data. |
| Right to Erasure | Request deletion of your personal data, subject to legal obligations. |
| Right to Restrict Processing | Request restriction of processing in certain circumstances. |
| Right to Data Portability | Request transfer of your data to another service provider. |
| Right to Object | Object to processing based on legitimate interests or direct marketing. |
| Right to Withdraw Consent | Withdraw consent at any time where processing is based on consent. |
To exercise any of these rights, please contact us at info@grubbex.com.ng.
11. Children's Privacy
Our Services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware of such data, we will take steps to delete it promptly.
12. Third-Party Links
Our Services may contain links to third-party websites or services. This privacy policy does not apply to those third parties. We encourage you to review their privacy policies before providing any personal data.
13. Changes to This Privacy Policy
We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:
- Posting the updated policy on our website with a new "Last Updated" date.
- Sending an email notification (where required).
We encourage you to review this policy periodically.
14. Contact Us
Appendix: OpenChain-Aligned Principles
While the OpenChain Project focuses on open source compliance, its core principles of transparency, accountability, and user empowerment are embedded throughout this policy:
- Transparency: We clearly explain what data we collect, why we collect it, and how we use it (Sections 2–3).
- Accountability: We implement robust security measures and require our partners to protect your data (Sections 5, 7).
- User Empowerment: We provide clear mechanisms for you to access, correct, and delete your data (Section 9).