Last updated: 1 January 2025. This policy applies to both the EMoto website and the EMoto mobile application.
01
Overview
EMoto LTD ("EMoto", "we", "us", "our") is committed to protecting the privacy of everyone who uses our website (emotoghana.com) and our mobile application (the "EMoto Charge App"). This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and your rights under Ghana's Data Protection Act, 2012 (Act 843).
By using our website or App, you agree to the practices described in this policy. If you do not agree, please discontinue use and contact us to have your data removed.
02
Who We Are
EMoto LTD is the data controller responsible for your personal information. We assemble, sell, and service electric 2 and 3 wheelers and operate DC fast charging and battery swapping infrastructure across Ghana.
- Registered in Ghana under the Companies Act, 2019 (Act 992)
- Registered with the Data Protection Commission of Ghana
- Principal place of business: Accra, Greater Accra Region, Ghana
03
Data We Collect
We collect different types of information depending on how you interact with us.
3.1 Website Visitors
- Name, email address, and phone number (contact forms)
- Browser type, IP address, and pages visited (analytics)
- Cookie and usage data (see Section 11)
3.2 Mobile App Users
| Data Type | Examples | Purpose |
|---|---|---|
| Identity | Full name, phone number, email, profile photo | Account creation & verification |
| Location | GPS coordinates (foreground & background) | Locate nearby charging & swap stations |
| Payment | Mobile Money number, transaction reference | Process wallet top-ups and session payments |
| Device | Device ID, OS version, push token | App functionality & push notifications |
| Camera / QR | QR code scan data from charging piles | Initiate and authenticate charging sessions |
| Session | Start/end time, energy consumed (kWh), station ID | Display session history and billing records |
| Usage | Feature clicks, error logs, crash reports | App improvement & bug fixing |
3.3 Hire-Purchase & Rider Onboarding
- Ghana Card number or Voter ID — collected for identity verification purposes
- Driver's licence — collected to verify that you are legally authorised to ride a motorcycle in Ghana before any work arrangement or payment is processed
- Employment/income information
- Next-of-kin details
- Vehicle preference and financing details
Guarantor Information
As part of the hire-purchase process, we also collect the following details from your guarantor:
- Full name
- Ghana Card number
- Residential address
- Occupation
Ghana Card details are used solely for identification and to verify guarantor eligibility. Driver's licence details confirm riding eligibility and DVLA compliance. Neither is shared with third parties outside of regulatory checks or the specific finance arrangement.
04
How We Use Your Data
We process your data only where we have a lawful basis to do so:
- Contract performance — to provide services you request (sales, repairs, charging sessions, hire-purchase)
- Legitimate interests — to improve our services, prevent fraud, and ensure platform security
- Legal obligation — to comply with Ghanaian laws and regulatory requirements
- Consent — for marketing communications and optional analytics (you can withdraw consent at any time)
05
Mobile App — Specific Practices
Location Access — The App requests location permission to show nearby charging stations and battery swap points. You can grant or deny location access in your device settings at any time. Denying location will not prevent you from using payment or session monitoring features.
Camera / QR Code Scanning — Camera access is used exclusively to scan the QR code printed on EMoto charging piles. We do not capture photos, videos, or any image data beyond the QR code content required to start a charging session.
Charging Session Monitoring — While a session is active, the App polls our servers to display real-time state-of-charge (%), energy consumed, cost, and estimated completion time. This data is saved to your session history for billing and dispute resolution.
Push Notifications — We may send push notifications for session updates (charging complete, low battery alerts) and important account messages. You can disable notifications in your device settings without losing any core functionality.
App Permissions Summary
06
Payments & Financial Data
Payment processing in the EMoto Charge App is handled by Kowri (our Mobile Money payment partner). When you top up your wallet or pay for a charging session:
- Your Mobile Money number is transmitted securely to Kowri's servers over TLS-encrypted connections
- EMoto does not store your full Mobile Money PIN or card details
- We retain transaction references, amounts, timestamps, and status codes for billing records and dispute resolution
- Kowri's own privacy policy governs how they handle your payment data
All financial records are retained for a minimum of seven (7) years to comply with Ghana Revenue Authority requirements.
07
Sharing Your Data
We do not sell your personal data. We share it only in the following circumstances:
- Service providers — Kowri (payments), Arkesel (SMS/OTP), cloud hosting providers, and analytics tools that process data on our behalf under data processing agreements
- Charging pile vendors — session commands and authentication tokens are sent to the hardware API of the relevant charging station; no personal profile data is shared
- Hire-purchase partners — financing companies and agencies we work with receive only the data required to assess and manage your finance agreement
- Legal & regulatory — when required by Ghanaian law, court order, or a lawful request from a competent authority
- Business transfers — in the event of a merger or acquisition, your data may be transferred; we will notify you beforehand
08
Data Retention
- Account data — retained while your account is active, plus 2 years after closure
- Charging session history — 3 years
- Payment & financial records — 7 years (GRA requirement)
- Hire-purchase records — duration of finance agreement plus 5 years
- Marketing consent records — until consent is withdrawn
- Crash logs and usage analytics — 12 months
When data is no longer needed, it is securely deleted or anonymised.
09
Security
We implement industry-standard technical and organisational measures to protect your data:
- TLS 1.3 encryption for all data in transit
- Encrypted storage for sensitive fields (passwords hashed with bcrypt; tokens encrypted at rest)
- OTP verification via SMS (Arkesel) for account login and wallet top-ups
- Role-based access controls — staff access only the data necessary for their function
- Regular security reviews and vulnerability assessments
While we take every reasonable precaution, no system is completely secure. If you suspect unauthorised access to your account, contact us immediately at info@emotoghana.com.
10
Your Rights
Under Ghana's Data Protection Act, 2012 (Act 843), you have the right to:
To exercise any right, email info@emotoghana.com. We will respond within 21 days. You also have the right to lodge a complaint with the Data Protection Commission of Ghana.
11
Cookies & Tracking
Our website uses cookies and similar technologies. In summary:
- Essential cookies — required for the website to function (cannot be disabled)
- Analytics cookies — help us understand how visitors use the site (opt-out available)
- Preference cookies — remember your settings and language choices
The EMoto Charge App does not use browser cookies; it uses secure tokens stored in your device's protected storage.
12
Children's Privacy
Our services are intended for persons aged 18 and above. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, please contact us at info@emotoghana.com and we will delete the information promptly.
13
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our services, technology, or legal requirements. When we make material changes, we will:
- Update the "Last updated" date at the top of this page
- Send an in-app notification to registered users
- Post a notice on our website homepage for at least 30 days
Continued use of our website or App after the effective date constitutes acceptance of the revised policy.
14
Contact Us
Questions or concerns about this policy or how we handle your data? Reach us directly: