Privacy Policy

1. Introduction

This Privacy Policy explains how African Clean Energy ("ACE", "we", "us", or "our") collects, uses, shares, and protects personal information when you use the ACE Catch mobile application (the "App"). ACE Catch is an internal tool for ACE's field workforce - sales agents, delivery drivers, maintenance teams, and contracted gig workers - to record their work with customers across our markets. By using the App, you (the field worker) agree to the practices described in this Policy.

"ACE" in this Policy includes ACE Energy Holdings BV (incorporated in the Netherlands) and its subsidiaries and local operating entities in Uganda, Kenya, Lesotho, Cambodia, Senegal, and other markets where the App is available. Any of these entities may have access to your data for the purposes set out below.

This App is intended for ACE field workers only. If you are an ACE customer, please use the ACE Connect app and refer to the ACE Connect Privacy Policy. The general public cannot authenticate to ACE Catch.

If you are interested in working with ACE as a field agent, delivery driver, or gig worker, contact your country's ACE office through africancleanenergy.com.

2. Information We Collect

2.1 Information about you, the field worker

• Login identity - your assigned worker username (e.g. firstname.lastname), worker number, the team / hub / depot you are assigned to, and your worker role (sales agent, driver, maintenance technician, gig worker, etc.).
• GPS location - captured at the start of each customer visit, delivery, or maintenance call for visit-verification and territory-coverage analytics. Some worker roles (e.g. delivery drivers) generate more frequent location records than others (e.g. occasional surveyors).
• Work logs - every form you submit (Demo, KYC, Sale, Fuel Delivery, Maintenance Visit, Resolution Task) is recorded with your worker identity, a timestamp, and the GPS coordinates at the time of submission.
• Photos and signatures you capture in the course of your work (customer ID photos, customer signatures, before/after maintenance photos, proof-of-delivery photos).
• Mobile-money handle (for delivery drivers and gig workers paid via the App's earnings flow) - the phone number associated with your mobile money account. Used only to pay you for completed work.
• Device information - Firebase installation ID, device model, OS version, app version, network type. Used for crash reporting and targeted support.

2.2 Information you enter about customers

In the course of your work you enter personal information about ACE customers - their name, phone number, national ID number, location, photo, signature, household composition, occupation, income, energy use, and more. This data flows to ACE's central Salesforce system on the customer's record and is governed by the ACE Connect Privacy Policy which the customer agreed to at point of sale.

You are responsible for entering this data accurately and only with the customer's informed consent. The App displays the customer's consent status on each record.

2.3 Information collected automatically

• Crash reports and performance metrics (Firebase Crashlytics)
• Push notification tokens - for delivery-driver routing notifications and other operational alerts
• App usage analytics - which forms are completed, time-to-complete, error rates. Used to improve the App.

3. Why We Collect This Information

4. Who We Share Your Information With

We share information only with processors that support our operations, as necessary for the purposes in Section 3:

We do not sell worker or customer personal information to advertisers or data brokers.

We may also disclose information where required by law, court order, or to protect our legal rights.

5. International Data Transfers

Your data is processed and stored in multiple countries, including the Netherlands, the United States, and the country where you work as an ACE field worker. Where data is transferred outside your country, we rely on appropriate safeguards including standard contractual clauses and the privacy policies of our processors.

6. How Long We Keep Your Data

• Worker identity and work logs - retained for the duration of your employment, contractor, or gig relationship with ACE, plus the period required by local labour and tax laws (typically 5-7 years).
• Customer data you entered - retained according to the customer-side schedule in the ACE Connect Privacy Policy (typically the duration of the customer relationship plus the legal record-keeping period).

After the relevant retention period ends, we delete or anonymise the data unless we are required by law to retain it longer.

7. How We Protect Your Data

We use industry-standard measures to protect data, including:

• Encrypted connections between the App and our servers (HTTPS / TLS)
• OAuth-based authentication for login; no password stored on the device
• Access controls and authentication for our staff
• Regular security reviews of our platforms
• Physical and digital security controls at our data processors

No system is perfectly secure. If we become aware of a breach affecting your data, we will notify you in accordance with applicable law.

8. Your Rights

Depending on your country, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Restrict or object to certain processing (within the limits of your employment relationship with ACE)
• Withdraw consent where processing is based on consent
• Complain to your national data protection authority

To exercise these rights, contact us at the details in Section 11. We will respond within 30 days.

Note: your right to delete or port data is limited where the data forms part of your work record and is needed to demonstrate ACE's regulatory compliance.

9. Children

The App is not intended for use by anyone under 18. ACE only employs or contracts adults as field workers. We do not knowingly collect data from anyone under 18.

10. Carbon Credits and Customer Data

Customer usage data you record contributes to ACE's verified carbon credit generation. Each customer cedes the rights to their carbon credits to ACE at point of sale (see the ACE Connect Privacy Policy Section 10 and the customer's purchase contract). Your role as a field worker is to capture this data accurately; you have no personal claim to the carbon credits.

11. Contact Us

African Clean Energy
Email: info@africancleanenergy.com
Website: africancleanenergy.com

For data protection concerns specific to your country, you may also contact your national data protection authority.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be notified through the App and the latest version will always be available on our website. Continued use of the App after a change constitutes acceptance of the updated Policy.

ACE Catch Privacy Policy v1.00 · Effective 22 May 2026 · ACE Energy Holdings BV, KvK 98778013, Willem de Zwijgerlaan 13-3, 1056 JD Amsterdam, The Netherlands.