SUMAMI Privacy Policy

Privacy Policy

Sumami ("we," "us," or "our") is committed to protecting the privacy of our Store Partners, Delivery Partners (Drivers), and the Customers they serve. This policy outlines our practices in accordance with the Ghana Data Protection Act (Act 843), the African Union Malabo Convention, and the EU General Data Protection Regulation (GDPR).

1. Data Collection: What We Collect

We collect data necessary to facilitate a secure and efficient "bidding-to-delivery" ecosystem:

• For Drivers: Full name, phone number, selfie with Government-issued ID, driver’s license, vehicle details (type, photo, license plate, registration documents), real-time geolocation (while active), and Mobile Money (MoMo) payment details.

• For Store Partners: Business name, registration number, business license photo, owner’s Government ID, store front photo, store geolocation (Plus Codes), and contact details.

• For Customers: (Provided via the Store) Name, delivery address (Plus Codes), phone number, and order history.

• Technical Data: IP address, device identifiers, app telemetry, and cookies.

2. Lawful Basis for Processing

We process data based on the following pillars:

• Performance of Contract: To connect Stores and Drivers and fulfill delivery requests.

• Legitimate Interests: To prevent fraud, ensure vehicle safety, and improve the bidding algorithm.

• Legal Obligation: Compliance with Ghanaian and regional tax, transport, and anti-money laundering (AML) laws.

• Consent: For marketing communications and continuous background location tracking.

3. How We Use Your Data

• Bidding Facilitation: Using geolocation and load details to allow Drivers to bid on local opportunities.

• Verification: Using photos and IDs to ensure that "the right driver takes the right goods."

• Automated Processing: We may use automated systems to sort bid opportunities by proximity; however, the final selection remains at the Store’s discretion.

• Operational Safety: Real-time tracking of "In Transit" goods to protect all parties.

4. Data Storage, Security & GDPR Benefits

Your data is stored on secure, encrypted cloud servers compliant with ISO/IEC 27001.

• GDPR Protection: Even for users outside the EU, we apply GDPR-standard "Privacy by Design." This includes pseudonymizing data where possible and conducting regular Data Protection Impact Assessments (DPIAs).

• Retention: Data is kept for the duration of your account plus a statutory period (usually 6 years in Ghana) for tax and legal defense purposes. Accounts deleted by users will be purged within 30 days, barring legal holds.

5. Sharing and Disclosure

We operate on a "Need-to-Know" basis:

• The Match: Stores see the Driver’s ID, vehicle photo, and rating. Drivers see the Store's location and the Customer's delivery destination.

• Payment Providers: Necessary data is shared with telecommunications partners to facilitate MoMo settlements.

• No Sale of Data: We never sell personal data to third-party advertisers.

6. Your Rights

Regardless of your location, Sumami grants you the following rights:

• Right to Withdraw Consent: Disable location tracking or marketing at any time.

• Right to Portability: Request your data in a machine-readable format.

• Right to Erasure ("Right to be Forgotten"): Request account deletion (note: subscriptions are non-reimbursable).

• Right to Human Intervention: If an automated decision (like an account suspension) affects you, you have the right to a manual review by our team.

7. Contact Us

Data Protection Officer (DPO)

Email:privacy@sumami.delivery

Address: Sumami, J1160 Garden Road, Somanya, Ghana, EY00005352

Regulatory Body: You have the right to lodge a complaint with the Ghana Data Protection Commissionor your local regional authority.