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How GoGoo Fleet collects, uses, shares and protects personal data across our fleet-intelligence platform, WhatsApp service and GPS hardware.
GoGoo Fleet ("GoGoo", "we", "us", "our") provides an AI-native fleet intelligence platform for commercial vehicles, accessed primarily through WhatsApp and through web dashboards, supported by GPS hardware devices fitted to vehicles.
For the purposes of this Privacy Policy, the data controller responsible for the personal data described below is:
Our operations in Ghana are currently carried out through a local operating partner, Mor-Lan Technologies (registered in Ghana, registration CS150602020, address Elite Street, Fise – Accra), which acts as our data processor and, on our behalf, installs hardware, provides local service delivery and support, engages locally, and collects payments. The local operating partner is registered with the Ghana Data Protection Commission as required by Act 843. GoGoo Fleet GmbH, as a controller of personal data originating from Ghana, also registers with the Commission as required.
This Policy is issued under, and intended to comply with, both:
Where the two regimes differ, we apply the higher standard of protection.
GoGoo operates a business-to-business service. Our role differs depending on whose data is being processed:
Where GoGoo acts as a processor, the fleet owner (our customer) is responsible for having a lawful basis to track its vehicles and drivers, for informing its drivers, and for obtaining any consents required under applicable law. That relationship is governed by a separate Data Processing Agreement (DPA), not by this Privacy Policy. See Section 13.
This Privacy Policy primarily describes the personal data for which GoGoo is the controller.
Through GPS hardware fitted to vehicles and connected systems, the platform processes data such as vehicle location, routes, trips, speed, mileage, driving behaviour (for example harsh braking or acceleration), engine/ignition status, and device status. Where this data can be linked to an identifiable driver, it constitutes personal data of that driver.
For most fleet customers, GoGoo processes this data as a processor on behalf of the fleet owner. The fleet owner is the controller and is responsible for the lawful basis and for driver transparency.
We do not seek to collect special category data (such as health, biometric or religious data) as defined under Article 9 GDPR. Please do not send us such data unless specifically requested. Vehicle and location data, while not "special category" data, is sensitive and is treated by us with heightened care.
Our service is intended for businesses and is not directed at children. We do not knowingly collect personal data from anyone under the age of 18. (In Germany, the digital-consent age under Article 8 GDPR is 16.)
Under GDPR we must have a lawful basis for each processing activity. The table below sets out the main purposes and bases. Under Ghana's Act 843, processing must in each case be lawful, fair, for a specified purpose, and not excessive, and we rely on consent or another lawful justification accordingly.
Scroll the table sideways to see all columns.
| Purpose | Lawful basis (GDPR) |
|---|---|
| Creating and administering your account; providing the platform and hardware you have ordered | Performance of a contract (Art. 6(1)(b)) |
| Billing, collecting payment, and keeping accounting records | Contract and legal obligation (Art. 6(1)(b), (c)) |
| Operating, securing, maintaining and improving the platform; preventing fraud and misuse; safeguarding our assets and yours | Legitimate interests (Art. 6(1)(f)) |
| Responding to your enquiries and providing support | Contract / legitimate interests (Art. 6(1)(b), (f)) |
| Sending service and transactional messages (e.g. via WhatsApp) | Contract / legitimate interests (Art. 6(1)(b), (f)) |
| Marketing communications to prospects and customers | Consent (Art. 6(1)(a)) or legitimate interests, as applicable, with an opt-out |
| Sharing data with channel partners (banks, insurers) at your request or with your consent | Consent / contract (Art. 6(1)(a), (b)) |
| Complying with law, regulators (including the Ghana DPC), and lawful requests | Legal obligation (Art. 6(1)(c)) |
Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms; you may ask us for further information about that balancing assessment, and you may object (see Section 8).
Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.
Our service is WhatsApp-first. When you interact with GoGoo through WhatsApp:
If you prefer not to use WhatsApp, contact us at hello@gogoofleet.com to discuss alternative channels where available.
The platform uses analytics and algorithmic ("AI") techniques to generate insights about fleet performance, driving behaviour and risk.
We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing without human involvement, except where:
Where channel partners (such as banks or insurers) use fleet or driving data to make their own decisions (for example about credit, pricing or eligibility), those decisions are made by the partner as a separate controller under its own terms, and you should review that partner's privacy notice. If any GoGoo feature would involve automated decisions with significant effects on an individual, we will identify it, explain the logic involved in general terms, and provide the right to obtain human intervention, to express a view, and to contest the decision (Article 22 GDPR).
Payments for the service may be collected via mobile money, bank transfer, card or other payment methods. Payment processing is carried out by third-party payment providers, mobile money operators and banks, who process your payment data as controllers under their own privacy notices. We retain transaction records (date, amount, reference) as needed to provide the service and to meet legal and tax obligations.
Subject to the conditions and exceptions in applicable law, you have the right to:
These rights reflect both GDPR (Articles 15–22) and the data-subject participation rights under Ghana's Act 843, including the right to access, to request correction, to withdraw consent, and to object to direct marketing.
How to exercise your rights: contact us at hello@gogoofleet.com. We will respond within one month (GDPR) and without undue delay. We may need to verify your identity. There is normally no fee, although we may charge a reasonable fee or refuse requests that are manifestly unfounded or excessive.
Where GoGoo is a processor (telematics/driver data — see Section 2): if you are a driver and wish to exercise rights over vehicle/driver data, please contact the fleet owner who is the controller; we will support that controller in responding.
GoGoo operates across Ghana and Germany. As a result, personal data is transferred between Ghana, the EEA, and — through our service providers — other countries including the United States.
You may request a copy of the relevant safeguards by contacting hello@gogoofleet.com.
We keep personal data only as long as necessary for the purposes described, then delete or anonymise it. In particular:
Our detailed retention schedule is available on request.
If you are a fleet owner / business customer, the processing of your vehicle and driver data by GoGoo as your processor is governed by a separate Data Processing Agreement that forms part of your contract with us. That DPA sets out our obligations under Article 28 GDPR and Act 843, including security, sub-processors, breach notification, and assistance with data-subject requests. Contact hello@gogoofleet.com to obtain the DPA.
We implement appropriate technical and organisational measures, including access controls, token-based authentication, encryption in transit, least-privilege access, staff confidentiality obligations, and a documented breach-response process. No system is completely secure, but we work to protect your data and to limit access to those who need it.
If a personal data breach occurs, we will:
We may update this Policy from time to time. We will post the updated version at www.gogoofleet.com with a revised "Last updated" date and, where changes are significant, notify you directly.
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