Legal

Privacy Policy

Last updated: June 23, 2026

This Privacy Policy explains how Ironji Trade Ltd.(“Ironji”, “we”, “us”) collects, uses, shares and protects your personal data when you use our logistics services, our website at ironji.com, and our apps — the Ironji Driver app (com.ironji.driverapp) and our customer app. Our staff also use an internal dashboard to operate the service and process personal data on our behalf. It also describes your rights under Rwanda Law N° 058/2021 relating to the protection of personal data and privacy.

Who we are

The data controller responsible for your personal data is:

  • Ironji Trade Ltd. (trading as Ironji)
  • 4th floor, Fairview Building, KG622 Street, Kimihurura, Kigali, Rwanda
  • Company / TIN: 108377382
  • Privacy contact: [email protected]
We are working towards registration with Rwanda’s data protection supervisory authority and the designation of a Data Protection Officer, as required for organizations that carry out large-scale monitoring. Until then, all privacy requests are handled through [email protected].

Personal data we collect

Depending on how you use Ironji, we collect the following categories of personal data:

Everyone

  • Identity & contact data: name, phone number, email address.
  • Account & security data: hashed password, two-factor settings, and sign-in records.
  • Device & technical data: device identifiers, push notification token, IP address, browser/app user-agent and a derived device fingerprint used for sign-in security.
  • Usage data: pages/screens viewed, open/close events, and your activity history.

Drivers & truck owners

  • Identity documents: national ID or passport number, date of birth.
  • Driver & vehicle data: driving licence number and image, vehicle plate number, truck type, parking location, and uploaded documents (motor inspection certificate, vehicle insurance, yellow card).
  • Photos & documents: profile picture, delivery notes, and invoices captured during deliveries.
  • Location & movement data: precise GPS location (including in the background while on duty), speed, heading and movement type. See Location data.
  • Payment data: earnings, balances, and payment-reference details for settlements.

Customers

  • Shipment data: pickup and delivery addresses, recipient contact details, and cargo descriptions.
  • Billing data: invoice and payment details for the services you request.

How and why we use your data

We process your personal data only for lawful purposes connected to our logistics service, on the legal bases set out in Article 46 of Rwanda Law N° 058/2021:

PurposeLegal basis
Create and manage your account; provide the app and servicesPerformance of a contract
Assign, dispatch, track and complete shipments (incl. live location)Performance of a contract; legitimate interests
Process payments, settlements and invoicingPerformance of a contract; legal obligation
Verify identity, secure sign-in, prevent fraud and abuseLegitimate interests; legal obligation
Send service, security and operational notifications (SMS, email, WhatsApp, push)Performance of a contract; legitimate interests
Improve and analyze the serviceLegitimate interests (or consent where required)
Comply with tax, accounting and other legal requirementsLegal obligation

Location data

The Ironji Driver app collects precise GPS location, including in the background (while the app is closed), so that shipments can be tracked while you are on duty. The app shows a persistent notification while location is being collected.

Location is used to dispatch and track deliveries, share live progress with authorized dispatchers and customers, and confirm completed trips. You can stop background collection at any time through your device permission settings; doing so may limit the app’s functionality. Raw location fixes are retained for 30 days (see retention).

Who we share data with

We do not sell your personal data. We share it with service providers (sub-processors) who process it on our behalf under contract, and with authorized parties involved in your shipments (for example dispatchers and customers receiving live tracking). Our main sub-processors are:

ProviderPurposeDataOutside Rwanda
Google (Firebase: Analytics, Cloud Storage, Cloud Messaging, Firestore, Realtime DB)App analytics, push notifications, and storage of uploaded documents/photosDevice identifiers, app usage events, uploaded ID/vehicle documents and photosYes
MongoDB (database hosting)Primary storage of account, shipment and location dataAccount profile, shipments, location historyYes
intouchSMS (InTouch, Rwanda)Sending one-time passwords (OTP) and SMS notificationsPhone number, message contentNo
Migadu (SMTP email hosting)Account, security and transactional emailEmail address, message contentYes
WhatsApp messaging providerOperational notifications to driversPhone number, message contentYes
QuickBooks (Intuit)Accounting, invoicing and paymentsName, financial/payment records, tax identifiersYes
Cloudflare TurnstileBot/abuse protection on sign-inIP address, challenge tokensYes
Centrifugo (real-time delivery)Streaming live location to authorized dispatchers/customersLocation updates, short-lived auth tokensNo

International data transfers

Some of our sub-processors are located outside Rwanda, so your personal data may be transferred and stored abroad. Where this happens, we rely on the conditions for transfer permitted under Articles 48–50 of Rwanda Law N° 058/2021 (such as appropriate safeguards, your consent, or necessity for performing our contract) and take steps to ensure your data remains protected.

How long we keep data

We keep personal data only for as long as necessary for the purposes above (Article 52), and then delete or irreversibly anonymize it:

DataRetention period
Account & profile dataUntil you delete your account
Raw GPS location fixes30 days
Financial & accounting records10 years (Rwanda Tax Procedures Law, 2023), then anonymized
Security & sign-in audit logsLimited period for security/legal purposes, then anonymized
Message delivery logs (SMS / WhatsApp / email)Limited operational period at our messaging gateway

For details on deletion, see our Account & Data Deletion page.

Your rights

Under Rwanda Law N° 058/2021 you have the right to:

  • Access your personal data and information about how it is processed (Art. 18).
  • Object to certain processing (Art. 19).
  • Data portability — receive your data in a structured, readable format (Art. 20).
  • Restrict processing in certain cases (Art. 22).
  • Erasure — request deletion of your data (Art. 23).
  • Rectification — correct inaccurate or incomplete data (Art. 24).
  • Withdraw consent at any time, where processing is based on consent (Art. 8).

To exercise any of these rights, contact [email protected]. We will respond within 30 days.

How we protect your data

We apply appropriate technical and organizational measures to protect your data (Article 47), including encryption of data in transit, hashed passwords, two-factor authentication, access controls, and monitoring for unauthorized access. No system is completely secure, but we work to protect your information and to respond promptly to any incident.

Children's data

Our services are intended for adults (drivers, partners and business customers) and are not directed at children under 16. We do not knowingly collect the personal data of children. If you believe a child has provided us data, contact us and we will delete it.

Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version here and revise the “Last updated” date above. Significant changes will be communicated where appropriate.

Contact & complaints

For any privacy question or to exercise your rights, contact us at [email protected] or +250 783 889 601.

You also have the right to lodge a complaint with Rwanda’s data protection supervisory authority, the National Cyber Security Authority – Data Protection & Privacy Office (NCSA/DPP).