Your Privacy Matters

1. 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.

2. 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 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

3. 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 Applicants

• Ghana Card number or Voter ID
• Employment/income information
• Next-of-kin details
• Vehicle preference and financing details

4. 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)

5. Mobile App – Specific Practices

App Permissions Summary

• Location (Fine & Coarse) – station finder
• Camera – QR code scanning only
• Internet – required for all connected features
• Push Notifications – session & account alerts (optional)
• Storage – app cache only; no media files written to device

6. 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.

7. 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

8. 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.

9. 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:

• Access – request a copy of the personal data we hold about you
• Correction – request correction of inaccurate or incomplete data
• Deletion – request erasure of your data (subject to legal retention obligations)
• Objection – object to processing for direct marketing purposes
• Restriction – request that we limit how we use your data in certain circumstances
• Portability – receive your data in a structured, machine-readable format
• Withdraw Consent – where processing is based on consent, you may withdraw it at any time without affecting prior processing

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. You can find full details in our Cookie Policy. 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.