PRIVACY POLICY

Trukkas Platform (www.trukkas.com)

1. INTRODUCTION

1.1 About Trukkas

Trukkas is a digital freight forwarding, trucking, logistics coordination, and transportation marketplace platform operated by Trukkas Global Logistics and Supply Ltd ("Trukkas", "Company", "we", "us", or "our").

The Platform connects freight forwarders, truck owners, drivers, logistics operators, corporate customers, and other stakeholders within the logistics ecosystem, enabling them to coordinate transportation services, manage logistics operations, process payments, monitor deliveries, and exchange logistics-related documentation electronically.

1.2 Commitment to Privacy

Trukkas Global Logistics and Supply Ltd is committed to protecting the privacy, confidentiality, integrity, and security of personal data entrusted to us. We recognise the importance of responsible data processing and are committed to complying with the requirements of the Nigeria Data Protection Act, 2023 ("NDPA"), applicable regulations issued by the Nigeria Data Protection Commission, and other relevant data protection laws.

1.3 Purpose of this Privacy Policy

This Privacy Policy explains how we collect, use, store, disclose, transfer, retain, and otherwise process personal data obtained through the Trukkas Platform and related services.

This Privacy Policy also outlines the rights available to Data Subjects and explains how such rights may be exercised.

1.4 Scope of Application

This Privacy Policy applies to personal data collected through:

(a) the Trukkas website located at www.trukkas.com;

(b) mobile applications operated by Trukkas;

(d) customer service and support channels;

(e) electronic communications;

(f) application programming interfaces (APIs); and

(g) any other services, products, or digital platforms operated by Trukkas Global Logistics and Supply Ltd.

1.5 Persons Covered by this Policy

This Privacy Policy applies to all individuals whose personal data is processed by Trukkas, including:

(a) Freight Forwarders;

(b) Truck Owners;

(d) Corporate Customers;

(e) Vendors and Service Providers;

(f) Business Partners;

(g) Website Visitors; and

(h) other users of the Platform.

1.6 Acceptance of this Privacy Policy

By accessing, registering on, or using the Platform, Users acknowledge that they have read, understood, and accepted the terms of this Privacy Policy.

2. DEFINITIONS

Unless the context otherwise requires, the following terms shall have the meanings assigned below:

"Account" means a registered user profile created on the Platform.

"Consent" means any freely given, specific, informed, and unambiguous indication of a Data Subject's wishes by which the Data Subject signifies agreement to the processing of personal data.

"Data Controller" means a person or organisation that determines the purposes and means of processing personal data.

"Data Processor" means a person or organisation that processes personal data on behalf of a Data Controller.

"Data Subject" means an identified or identifiable natural person whose personal data is processed.

"KYC Information" means information collected for customer identification, verification, anti-fraud, anti-money laundering, and regulatory compliance purposes.

"Location Data" means GPS coordinates, route information, geofencing data, movement records, and other location-related information generated through the use of the Platform.

"Logistics Data" means operational information relating to transportation, cargo movement, deliveries, trips, vehicles, routes, bookings, and logistics transactions.

"NDPA" means the Nigeria Data Protection Act, 2023, as amended, supplemented, or replaced from time to time.

"Personal Data" means any information relating to an identified or identifiable natural person.

"Personal Data Breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data.

"Platform" means the Trukkas website, mobile applications, dashboards, APIs, software systems, and related services.

"Processing" means any operation performed on personal data including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, transfer, restriction, deletion, or destruction.

"Sensitive Personal Data" means personal data classified as sensitive under applicable law, including financial information, biometric information, health information, precise location information, and other categories designated by law.

"Services" means the freight forwarding, trucking, logistics coordination, tracking, payment facilitation, document management, and related services offered through the Platform.

"User" means any individual or organisation that accesses or uses the Platform.

3. DATA CONTROLLER INFORMATION

For the purposes of the Nigeria Data Protection Act, 2023, the Data Controller responsible for the processing of personal data under this Privacy Policy is:

Trukkas Global Logistics and Supply Ltd

Platform: Trukkas

Website: www.trukkas.com

Registered Office: Lagos, Nigeria

Privacy Email: privacy@trukkas.com

General Legal Email: legal@trukkas.com

Trukkas Global Logistics and Supply Ltd determines the purposes and means of processing personal data collected through the Platform and is responsible for ensuring compliance with applicable data protection laws.

Where required by law, Trukkas may appoint a Data Protection Officer or designated privacy representative whose details shall be published on the Platform.

4. CATEGORIES OF PERSONAL DATA COLLECTED

Depending on the nature of the Services used and the User's interaction with the Platform, Trukkas may collect and process the following categories of personal data:

4.1 Information Provided Directly by Users

(a) full name;

(b) telephone number;

(d) residential address;

(e) business address;

(f) company information;

(g) Corporate Affairs Commission registration information;

(h) tax identification information;

(i) employment or professional information; and

(j) other information voluntarily submitted by Users.

4.2 Identity Verification and KYC Information

To comply with regulatory, security, and operational requirements, Trukkas may collect:

(a) National Identity Number (NIN);

(b) driver's licence information;

(d) voter identification information;

(e) business registration documents;

(f) proof of address documentation;

(g) vehicle ownership documents;

(h) insurance certificates; and

(i) other information required for verification purposes.

4.3 Financial and Transaction Information

We may collect:

(a) bank account details;

(b) wallet information;

(d) payment records;

(e) transaction histories;

(f) settlement information; and

(g) other financial information necessary for the operation of the Services.

4.4 Vehicle and Logistics Information

Trukkas may collect:

(a) vehicle registration details;

(b) fleet information;

(d) vehicle insurance information;

(e) cargo information;

(f) delivery records;

(g) route information; and

(h) transportation-related operational data.

4.5 Technical Information

When Users access the Platform, we may automatically collect:

(a) internet protocol (IP) addresses;

(b) device identifiers;

(d) operating system information;

(e) application usage information; and

(f) activity and system logs.

4.6 Location Information

The Platform may collect and process:

(a) GPS coordinates;

(b) real-time location information;

(d) trip movement data; and

(e) time-stamped transportation events.

5. SOURCES OF PERSONAL DATA

Trukkas may obtain personal data from a variety of sources, including:

5.1 Information Provided Directly by Users

Personal data provided during registration, onboarding, verification, communications, transactions, and general use of the Platform.

5.2 Information Generated Through Platform Activity

Information generated through bookings, transportation activities, payments, communications, location tracking, document management, and use of Platform features.

5.3 Third-Party Verification Providers

Information obtained from identity verification providers, compliance service providers, fraud prevention providers, and similar third-party service providers.

5.4 Financial Service Providers

Information received from banks, payment processors, wallet providers, escrow service providers, and other financial institutions involved in Platform transactions.

5.5 Regulatory and Public Sources

Information obtained from regulatory authorities, public registers, government databases, court records, and publicly available sources where legally permitted.

5.6 Business Partners and Service Providers

Information obtained from logistics partners, insurance providers, fleet managers, transportation service providers, and other organisations involved in the provision of Services.

6. PURPOSES OF PROCESSING PERSONAL DATA

6.1 General Purposes

Trukkas Global Logistics and Supply Ltd processes personal data for legitimate business, operational, legal, regulatory, and security purposes in connection with the operation of the Platform and the provision of Services.

6.2 Account Registration and User Management

Personal data may be processed for the purpose of:

(a) creating and managing user accounts;

(b) verifying user identities;

(d) providing access to Platform features and functionalities; and

(e) administering user relationships.

6.3 Identity Verification and Regulatory Compliance

Personal data may be processed to:

(a) conduct Know Your Customer (KYC) procedures;

(b) verify identities and business credentials;

(d) comply with anti-money laundering requirements and other regulatory obligations; and

(e) satisfy requests from competent authorities where required by law.

6.4 Freight Booking and Logistics Operations

Personal data may be processed to:

(a) facilitate freight booking and transportation services;

(b) match freight forwarders with truck owners and drivers;

(d) manage logistics operations and cargo movements; and

(e) support transaction execution through the Platform.

6.5 Driver, Vehicle, and Fleet Verification

Personal data may be processed for:

(a) verification of driver qualifications;

(b) validation of vehicle ownership and registration;

(d) fleet management activities; and

(e) maintenance of operational records.

6.6 Trip Monitoring and Location Services

Location and logistics data may be processed for:

(a) trip tracking and monitoring;

(b) route management and optimisation;

(d) proof of movement and delivery; and

(e) security and operational oversight.

6.7 Payments and Financial Transactions

Personal data may be processed to:

(a) facilitate payments and settlements;

(b) operate wallet and escrow services;

(d) maintain transaction records; and

(e) prevent fraudulent financial activities.

6.8 Customer Support and Communications

Personal data may be processed to:

(a) respond to enquiries and complaints;

(b) provide customer support;

(d) conduct surveys and feedback exercises; and

(e) improve user experience.

6.9 Security, Fraud Prevention, and Risk Management

Personal data may be processed for:

(a) detecting and preventing fraud;

(b) monitoring suspicious activities;

(d) investigating incidents and disputes; and

(e) protecting users and business operations.

6.10 Business Improvement and Analytics

Personal data may be processed to:

(a) analyse platform usage patterns;

(b) improve services and functionality;

(d) develop new products and services; and

(e) support strategic business decisions.

6.11 Legal and Regulatory Compliance

Personal data may be processed where necessary to:

(a) comply with legal obligations;

(b) respond to lawful requests from regulators or authorities;

(d) establish, exercise, or defend legal claims; and

(e) comply with applicable industry standards.

7. LEGAL BASIS FOR PROCESSING

7.1 Performance of a Contract

Trukkas may process personal data where such processing is necessary for the performance of a contract to which a Data Subject is a party, or to take steps at the request of the Data Subject prior to entering into a contract.

This includes processing necessary for account creation, freight booking, logistics coordination, payment processing, trip management, and the provision of Services.

7.2 Compliance with Legal Obligations

Personal data may be processed where necessary to comply with legal, regulatory, tax, accounting, anti-money laundering, transportation, and other statutory obligations applicable to Trukkas.

7.3 Legitimate Interests

Trukkas may process personal data where such processing is necessary for its legitimate business interests, provided that such interests do not override the rights and freedoms of Data Subjects.

Such interests may include:

(a) fraud prevention;

(b) platform security;

(d) business administration;

(e) dispute resolution; and

(f) risk management.

7.4 Consent

Where required by applicable law, Trukkas shall obtain the consent of the Data Subject before processing personal data.

Where processing is based on consent, the Data Subject may withdraw consent at any time, subject to applicable legal and contractual restrictions.

7.5 Protection of Vital Interests

In exceptional circumstances, personal data may be processed where necessary to protect the vital interests of a Data Subject or another natural person.

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 Use of Cookies

The Platform may utilise cookies, web beacons, pixels, software development kits, and similar technologies to enhance functionality, improve user experience, maintain security, and analyse platform usage.

8.2 Types of Cookies Used

The Platform may use:

(a) essential cookies necessary for operation of the Platform;

(b) functional cookies that remember user preferences;

(d) security cookies designed to protect accounts and detect suspicious activities; and

(e) performance cookies used to improve platform efficiency.

8.3 Purpose of Cookies

Cookies may be used to:

(a) authenticate users;

(b) maintain user sessions;

(d) analyse user interactions;

(e) personalise user experiences; and

(f) enhance security measures.

8.4 Managing Cookie Preferences

Users may manage or disable cookies through browser or device settings. However, disabling certain cookies may affect the availability or functionality of parts of the Platform.

8.5 Third-Party Analytics Tools

Trukkas may utilise third-party analytics and performance monitoring tools that collect information regarding Platform usage in accordance with their respective privacy policies.

9. DATA SHARING AND DISCLOSURE

9.1 General Principle

Trukkas does not sell personal data. Personal data shall only be shared where necessary for legitimate business purposes, legal compliance, or the provision of Services.

9.2 Internal Access

Personal data may be accessed by authorised employees, contractors, consultants, and representatives of Trukkas strictly on a need-to-know basis.

9.3 Third-Party Service Providers

Personal data may be shared with:

(a) cloud hosting providers;

(b) payment processors;

(d) communication service providers;

(e) identity verification providers;

(f) fraud prevention providers; and

(g) technology and infrastructure providers.

9.4 Logistics and Business Partners

Where necessary to facilitate transportation and logistics services, personal data may be shared with freight forwarders, truck owners, drivers, fleet managers, logistics partners, and service providers involved in a transaction.

9.5 Professional Advisers

Personal data may be disclosed to auditors, legal advisers, consultants, insurers, and other professional advisers where reasonably necessary.

9.6 Legal and Regulatory Disclosures

Personal data may be disclosed to:

(a) regulatory authorities;

(b) law enforcement agencies;

(d) government agencies,

where required by applicable law or lawful request.

9.7 Corporate Transactions

Personal data may be transferred as part of a merger, acquisition, investment, restructuring, financing transaction, asset sale, or similar corporate transaction, subject to appropriate safeguards.

10. THIRD-PARTY SERVICES

10.1 Third-Party Integrations

The Platform may integrate with third-party services, software applications, payment gateways, mapping services, cloud infrastructure providers, communication providers, and other technology partners.

10.2 Independent Third Parties

Such third-party services operate independently and may be subject to their own privacy policies, terms of use, and contractual arrangements.

10.3 External Links

The Platform may contain links to websites, applications, or services operated by third parties. Trukkas does not control and is not responsible for the content, security, or privacy practices of such third parties.

10.4 Third-Party Privacy Practices

Users are encouraged to review the privacy policies of third-party service providers before providing personal data to such providers.

10.5 Limitation of Responsibility

Trukkas shall not be responsible for the collection, processing, storage, disclosure, or security of personal data by third-party services that operate independently of the Platform.

11. INTERNATIONAL DATA TRANSFERS

11.1 Cross-Border Processing

In the course of operating the Platform and providing the Services, Trukkas Global Logistics and Supply Ltd may transfer, store, process, or permit access to personal data outside the Federal Republic of Nigeria.

Such transfers may occur where Trukkas utilises cloud infrastructure providers, technology service providers, payment processors, communication service providers, analytics providers, or other business partners located in foreign jurisdictions.

11.2 Circumstances of Transfer

Personal data may be transferred internationally for purposes including:

(a) cloud hosting and data storage;

(b) disaster recovery and business continuity operations;

(d) customer support services;

(e) technology infrastructure management;

(f) fraud prevention and security monitoring; and

(g) other legitimate business operations necessary for the provision of the Services.

11.3 Safeguards for International Transfers

Where personal data is transferred outside Nigeria, Trukkas shall implement appropriate safeguards designed to ensure an adequate level of protection for personal data, including:

(a) contractual safeguards with data recipients;

(b) data processing agreements;

(d) transfer mechanisms recognised under applicable law; and

(e) any additional measures required under the Nigeria Data Protection Act, 2023.

11.4 Compliance with Applicable Law

All international transfers of personal data shall be carried out in accordance with the Nigeria Data Protection Act, 2023, regulations issued by the Nigeria Data Protection Commission, and any other applicable legal requirements.

12. DATA RETENTION

12.1 Retention Principles

Trukkas retains personal data only for as long as is reasonably necessary to fulfil the purposes for which the data was collected, including operational, contractual, legal, regulatory, security, audit, and dispute resolution purposes.

12.2 Retention Criteria

The duration for which personal data is retained may depend on factors including:

(a) the nature of the personal data;

(b) the purpose of processing;

(d) regulatory requirements;

(e) applicable limitation periods;

(f) litigation or dispute risks; and

(g) legitimate business needs.

12.3 Regulatory Retention Requirements

Certain categories of personal data and transaction records may be retained for longer periods where required by applicable laws, regulations, taxation requirements, transportation regulations, anti-money laundering obligations, audit requirements, or governmental directives.

12.4 Deletion and Destruction

Where personal data is no longer required for the purposes for which it was collected and there is no legal basis for continued retention, Trukkas shall take reasonable steps to securely delete, destroy, or permanently anonymise such data.

12.5 Archived Information

Personal data may be retained in secure archived systems where necessary for legal compliance, disaster recovery, historical record keeping, business continuity, or dispute resolution purposes.

13. DATA SECURITY

13.1 Commitment to Security

Trukkas Global Logistics and Supply Ltd implements appropriate technical, organisational, administrative, and physical measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, misuse, or access.

13.2 Security Measures

Security measures implemented by Trukkas may include:

(a) encryption of personal data during transmission and storage;

(b) role-based access controls;

(d) network security controls;

(e) firewall and intrusion detection systems;

(f) security monitoring tools;

(g) data backup procedures; and

(h) business continuity and disaster recovery mechanisms.

13.3 Access Controls

Access to personal data is restricted to authorised personnel, contractors, consultants, and service providers who require such access for legitimate business purposes and who are subject to appropriate confidentiality obligations.

13.4 Monitoring and Auditing

Trukkas may monitor, log, and audit access to systems and personal data to detect unauthorised activities, investigate incidents, and maintain security.

13.5 Security Limitations

While Trukkas takes reasonable measures to protect personal data, no method of transmission over the internet or electronic storage system can be guaranteed to be completely secure. Accordingly, Trukkas cannot guarantee absolute security of personal data.

14. DATA SUBJECT RIGHTS

14.1 Rights Under Applicable Law

Subject to applicable legal limitations and verification requirements, Data Subjects may exercise the rights available under the Nigeria Data Protection Act, 2023.

14.2 Right of Access

Data Subjects may request confirmation as to whether personal data relating to them is being processed and may request access to such personal data.

14.3 Right to Rectification

Data Subjects may request correction of inaccurate, incomplete, misleading, or outdated personal data.

14.4 Right to Erasure

Data Subjects may request deletion of personal data where:

(a) the data is no longer necessary for the purpose for which it was collected;

(b) consent has been withdrawn and no other legal basis exists for processing;

(d) applicable law otherwise permits deletion.

14.5 Right to Restriction of Processing

Data Subjects may request restriction of processing in circumstances recognised by applicable law.

14.6 Right to Data Portability

Where applicable, Data Subjects may request that personal data be provided in a structured, commonly used, and machine-readable format.

14.7 Right to Object

Data Subjects may object to the processing of personal data in circumstances permitted under applicable law.

14.8 Right to Withdraw Consent

Where processing is based on consent, Data Subjects may withdraw such consent at any time without affecting the lawfulness of processing conducted before withdrawal.

14.9 Right to Lodge Complaints

Data Subjects have the right to submit complaints to the Nigeria Data Protection Commission or any other competent authority where they believe their rights have been violated.

14.10 Exercising Rights

Requests relating to Data Subject rights may be submitted through the contact details provided in this Privacy Policy and shall be handled in accordance with applicable legal requirements.

15. AUTOMATED DECISION-MAKING

15.1 Use of Automated Systems

Trukkas may utilise automated systems, algorithms, analytics tools, and technology solutions to support operational activities on the Platform.

Such activities may include:

(a) freight matching;

(b) truck allocation;

(d) route optimisation;

(e) fraud detection;

(f) risk assessment; and

(g) compliance monitoring.

15.2 Purpose of Automated Processing

Automated processing may be used to improve operational efficiency, enhance service delivery, strengthen security measures, and optimise user experience.

15.3 Human Oversight

Where appropriate, Trukkas shall implement human oversight mechanisms in relation to significant automated decisions affecting Data Subjects.

15.4 Rights of Data Subjects

Where required under applicable law, Data Subjects may request information regarding automated decision-making processes and may request human review of decisions that significantly affect them.

16. CHILDREN'S PRIVACY

16.1 Platform Not Intended for Children

The Trukkas Platform and Services are intended solely for individuals who are eighteen (18) years of age or older and who possess the legal capacity to enter into binding contractual arrangements.

16.2 No Knowing Collection of Children's Data

Trukkas Global Logistics and Supply Ltd does not knowingly collect, solicit, process, or store personal data relating to children or minors under the age of eighteen (18) years.

16.3 Inadvertent Collection

Where Trukkas becomes aware that personal data relating to a child has been collected inadvertently or without appropriate authorisation, Trukkas shall take reasonable steps to investigate the matter and, where appropriate, delete such information in accordance with applicable legal requirements.

16.4 Parental or Guardian Notification

Where applicable law requires parental or guardian consent for the processing of personal data relating to minors, Trukkas reserves the right to request evidence of such consent before permitting access to any relevant services.

17. DATA PROCESSORS AND SUB-PROCESSORS

17.1 Engagement of Data Processors

Trukkas may engage third-party service providers, contractors, consultants, technology partners, cloud service providers, payment processors, communication service providers, and other entities to process personal data on its behalf in connection with the operation of the Platform and the provision of Services.

17.2 Due Diligence and Selection

Trukkas shall take reasonable steps to assess the suitability, reliability, competence, and security practices of Data Processors before engaging them to process personal data.

17.3 Contractual Safeguards

Where personal data is processed on behalf of Trukkas, appropriate contractual arrangements shall be implemented to ensure that such Data Processors:

(a) process personal data only on documented instructions from Trukkas;

(b) maintain appropriate confidentiality obligations;

(d) comply with applicable data protection laws; and

(e) assist Trukkas in meeting its legal and regulatory obligations where required.

17.4 Use of Sub-Processors

Data Processors engaged by Trukkas may appoint sub-processors where necessary for the provision of services, provided that appropriate safeguards are maintained and the protection of personal data is not diminished.

17.5 Oversight and Accountability

Trukkas shall maintain reasonable oversight mechanisms designed to monitor compliance by Data Processors and Sub-Processors with applicable contractual and legal obligations relating to personal data.

18. PERSONAL DATA BREACHES

18.1 Security Incident Management

Trukkas maintains policies, procedures, and response mechanisms designed to identify, investigate, contain, manage, and remediate actual or suspected Personal Data Breaches.

18.2 Detection and Investigation

Where a Personal Data Breach is suspected or identified, Trukkas shall take reasonable steps to:

(a) investigate the nature and scope of the incident;

(b) assess the categories of personal data affected;

(d) implement measures to contain and mitigate the impact of the incident.

18.3 Regulatory Notification

Where required by applicable law, Trukkas shall notify the Nigeria Data Protection Commission and other competent authorities of a Personal Data Breach within the timeframes prescribed by law.

18.4 Notification of Data Subjects

Where a Personal Data Breach is likely to result in a significant risk to the rights and freedoms of affected Data Subjects, Trukkas may notify affected individuals in accordance with applicable legal requirements.

18.5 Remedial Measures

Trukkas may implement corrective actions, security enhancements, recovery procedures, and other remedial measures designed to prevent recurrence and strengthen the protection of personal data.

19. CHANGES TO THIS PRIVACY POLICY

19.1 Right to Amend

Trukkas Global Logistics and Supply Ltd reserves the right to amend, modify, update, replace, or revise this Privacy Policy at any time to reflect changes in applicable laws, regulatory requirements, business operations, technology, industry standards, or data processing activities.

19.2 Notification of Changes

Where material changes are made to this Privacy Policy, Trukkas may provide notice through the Platform, email communications, mobile application notifications, website announcements, or any other reasonable means.

19.3 Continued Use of the Platform

Continued use of the Platform following the effective date of an updated Privacy Policy shall constitute acknowledgement of the revised Privacy Policy, subject to any consent requirements imposed by applicable law.

19.4 Effective Date

The most current version of this Privacy Policy shall be published on the Platform and shall indicate the date on which it became effective.

20. CONTACT INFORMATION

For questions, complaints, requests, concerns, or enquiries relating to this Privacy Policy or the processing of personal data, Data Subjects may contact:

Trukkas Global Logistics and Supply Ltd

Platform: Trukkas

Website: www.trukkas.com

Privacy Email: privacy@trukkas.com

Legal Email: legal@trukkas.com

Registered Office: Lagos, Nigeria

20.1 Data Subject Requests

Requests relating to access, correction, deletion, restriction, portability, objection, withdrawal of consent, or any other data protection right may be submitted through the contact details provided above.

20.2 Regulatory Complaints

Data Subjects who are dissatisfied with the manner in which their personal data has been processed may lodge a complaint with the relevant supervisory authority, including the Nigeria Data Protection Commission, without prejudice to any other legal rights or remedies available to them.

20.3 Response to Enquiries

Trukkas shall use reasonable efforts to respond to legitimate privacy-related enquiries and requests within the timelines prescribed by applicable law.