EcoCleanUp
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Privacy Policy

Effective date: [DD Month YYYY] · Last updated: [DD Month YYYY]

This policy explains what personal data EcoCleanUp collects, why, and what rights you have over it - whether you're a resident or business requesting a pickup, a collector working with us, a member of our ops team, or simply visiting this website.

1. Who we are

[EcoCleanUp Ltd. / legal entity name] ("EcoCleanUp", "we", "us") operates the EcoCleanUp waste-collection marketplace in Greater Accra, Ghana, comprising a mobile app for residents/businesses and collectors, an operations console used by our staff, and this website. For the purposes of Ghana's Data Protection Act, 2012 (Act 843), EcoCleanUp is the data controller for the personal data described in this policy. Our registered address is [registered business address], and our Data Protection Commission registration number is [DPC registration number, once registered].

2. Scope

This policy covers personal data we collect through:

  • the resident/business app - requesting and tracking pickups, and paying for organic collections;
  • the collector app - accepting jobs, verification documents, and receiving payouts;
  • the EcoCleanUp Operations Console - the internal tool our Admin and Super Admin staff use to run dispatch, verification, payments, and payouts; and
  • this public website.

It does not cover third-party sites we merely link to, or the separate privacy practices of payment, mapping, sign-in, or messaging providers we rely on - see Section 6.

3. Information we collect

3.1 From residents and businesses

  • Account details: name, phone number, and whether you're signing up as a resident or a business.
  • Pickup details: collection address, waste stream (organic or plastic) and, for plastic, grade; weight recorded at collection.
  • Payment-related data: the mobile money number and network used to charge an organic pickup or pay a plastic rebate, and the resulting transaction status - processed through Moolre (Section 6), not stored by us in raw form.
  • Communications: messages you send us (e.g. a dispute or support request) and the SMS updates we send you.

3.2 From collectors

  • Identity and vetting documents: Ghana Card, driver's licence, roadworthy certificate, and vehicle insurance, collected to verify you before you can accept jobs.
  • Operating details: name, phone number, vehicle and plate number, base zone, and vehicle capacity.
  • Location: your zone/area and, while online in the app, your approximate location, used to match you to nearby pickup requests.
  • Performance data: jobs completed, weight collected by stream, rating, and online/offline status.
  • Payout details: the mobile money number and network your weekly earnings are paid to.

3.3 From our own staff (Admins and Super Admins)

  • Name, work email address, and role, used to create and secure your Operations Console account.
  • Authentication/session data (kept only for the duration of your signed-in session).
  • An activity log of dispatch, verification, payment, payout, and settings actions taken through the console, kept for accountability and dispute resolution.

3.4 Collected automatically

  • Device and app diagnostics (device type, OS version, app version, crash logs) used to keep the app working.
  • Approximate or precise location from the mobile app, where you've granted location permission, used for pickup matching and coverage-zone accuracy.

3.5 From third parties

  • Google Sign-In - if you sign in with Google, we receive your name, email address, and profile photo from Google, per your Google account's own sharing settings.
  • Moolre - transaction status updates (success, pending, failed) for collections, disbursements, and payouts. Moolre, not EcoCleanUp, holds your underlying mobile money account credentials.

4. How we use it

  • Operate the marketplace: match pickups to nearby verified collectors, track a job from request to settlement, and calculate what's owed in either direction.
  • Move money: instruct Moolre to charge an organic pickup, pay a plastic rebate, collect a recycler offtake, or run a collector's weekly payout, and reconcile the result.
  • Verify collectors: review the documents in Section 3.2 before activating an account, and re-verify as needed.
  • Communicate: send pickup status updates, payment confirmations, and service notices by SMS or in-app notification.
  • Keep the platform safe and accountable: investigate disputes, detect fraud or abuse, and maintain the audit trail our ops team relies on.
  • Improve the service: understand usage patterns and fix problems (using diagnostic data, not the content of your pickups or payments).
  • Meet legal obligations: respond to lawful requests from regulators or law enforcement, and comply with our own record-keeping obligations.

We do not sell personal data, and we do not use it for third-party advertising.

Act 843 requires that personal data be processed lawfully, and only for a specified, compatible purpose (ss.17–26). In practice, we rely on one or more of the following for any given piece of data:

  • Your consent - for example, granting the app location access, or signing in with Google.
  • Performance of a contract with you - we can't match, complete, or pay for a pickup without your pickup, contact, and payment details.
  • A legal obligation - such as verifying a collector's identity documents, or retaining financial records.
  • Our legitimate interests - such as fraud prevention, service reliability, and dispute investigation - balanced against your right to privacy.

Where we rely on your consent, you can withdraw it at any time; see Section 9.

6. Who we share it with

We share personal data only where it's needed to run the service:

  • Moolre (payments and SMS) - processes collections, disbursements, bulk payouts, and delivers SMS notifications on our behalf.
  • Google - provides sign-in and mapping services used by the app.
  • Cloud hosting and infrastructure providers - store and run the app, console, and database on our behalf, under contract, and are not permitted to use your data for their own purposes.
  • Recycling and composting partners - receive collected material and aggregate weight/volume figures, not your personal details.
  • Our own staff - Admin and Super Admin users see the data needed to run dispatch, verification, payments, and support, through the Operations Console.
  • Regulators and law enforcement - where we're legally required to disclose information, or to establish, exercise, or defend a legal claim.
  • A future buyer or successor - if EcoCleanUp is ever involved in a merger, acquisition, or asset sale, personal data may transfer as part of that transaction, subject to this policy or a successor policy you'll be notified about.

7. How long we keep it

We keep personal data only as long as we need it for the purposes in Section 4, or as required by law - for example, financial and transaction records are typically kept for the period required by Ghanaian tax and financial regulations. Collector verification documents are kept for as long as the collector account is active, plus a retention period after deactivation to meet legal and dispute-resolution needs. When data is no longer needed, we delete or anonymise it. Specific retention periods: [to be finalised - e.g. transaction records: 7 years; verification documents: active account + 2 years; support/dispute records: 3 years].

8. How we protect it

In line with Act 843's security-safeguard principle (s.28), we apply technical and organisational measures appropriate to the sensitivity of the data - including encrypted connections, access controls limiting console access by staff role (Admin vs Super Admin), authenticated sessions, and never storing raw mobile money credentials ourselves; that responsibility sits with Moolre. No system is completely secure, and we can't guarantee absolute security, but we work to prevent unauthorised access, disclosure, alteration, or destruction of your data, and we notify affected individuals and the Data Protection Commission of any security compromise as required by s.31.

9. Your rights

As a data subject under Act 843, you have the right to:

  • Access the personal data we hold about you (s.35);
  • Correct personal data that's inaccurate or incomplete (s.33, s.44);
  • Object to, or request we stop, processing that's causing you unwarranted damage or distress (s.39);
  • Object to direct marketing at any time (s.40);
  • Not be subject to a purely automated decision that significantly affects you, without the chance for human review (s.41);
  • Request rectification, blocking, erasure, or destruction of personal data processed in breach of the Act (s.44);
  • Withdraw consent at any time, where processing is based on consent, without affecting processing that already happened;
  • Claim compensation for damage suffered as a result of a contravention of the Act (s.43); and
  • Lodge a complaint with the Data Protection Commission - see Section 14.

To exercise any of these rights, contact us using the details in Section 14. We'll respond within the timeframe required by the Act - currently 21 days for most requests.

10. Children

EcoCleanUp's app and services are intended for adults who can enter into a contract - we don't knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we'll delete it.

11. International transfers

Some of the providers in Section 6 (for example, cloud hosting, Google) may process data outside Ghana. Where that happens, we require appropriate contractual safeguards to protect your data to a standard consistent with Act 843, including where the receiving jurisdiction's own data protection law applies (s.18(2)).

12. Cookies on this website

This website (the one you're reading this policy on) does not currently set analytics, advertising, or tracking cookies. It loads fonts from Google Fonts, which involves your browser making a request to Google's servers for those font files. If we add analytics or other cookies in the future, we'll update this section and, where required, ask for your consent first.

13. Changes to this policy

We may update this policy as the product changes. We'll update the "Last updated" date above, and for material changes, we'll take reasonable steps to notify you - such as an in-app notice or a message to the contact details on your account - before the change takes effect.

14. Contact & complaints

To ask a question, exercise a right in Section 9, or raise a concern, contact us at:

[Data Protection contact name / Data Protection Officer]
Email: privacy@ecocleanup.example
Postal address: [registered business address]

If you're not satisfied with our response, you have the right to lodge a complaint with Ghana's Data Protection Commission (dataprotection.org.gh).