Privacy Policy

This Policy explains how Exluma (Pty) Ltd, registration number 2026/354697/07 ("EXLUMA", "we", "us"), collects, uses, stores and protects personal information in the Transint service, formerly called WaybillGO (the "Service"), in line with the Protection of Personal Information Act 4 of 2013 ("POPIA"). Transint is a business tool used by transport companies (our "Customers"), their drivers and staff, the cargo owners they work for ("Corporate Clients"), and the people who count or receive loads.

1. Who is responsible for your information

• Records captured on a Customer's account — trips, photos, locations, counts, seals, fuel fills, confirmations and documents — belong to that Customer. The Customer is the responsible party. EXLUMA is its operator: we process that information only to provide the Service, on the Customer's instructions.
• Account, billing and support information about our Customers and Corporate Clients: EXLUMA is the responsible party.
• A Corporate Client that views trips linked to its own contracts is responsible for how it uses what it sees.

2. Where your information is stored

Customer records and files are stored in South Africa. The database, all photos and documents, the server functions that handle them, and our secret keys run on Google Cloud in the africa-south1 (Johannesburg) region.

Some supporting services are not tied to South Africa. These providers may process data outside South Africa. We list each one and what it receives:

• Sign-in accounts (Google Firebase Authentication). To let people sign in we hold each user's email address or phone number, a one-way scrambled form of the password (never the password itself), the display name and sign-in times.
• Phone verification (Google). When a receiver confirms a delivery with a one-time PIN, Google sends the SMS and runs an automated bot check (reCAPTCHA) in the browser.
• Password-reset emails (Google Firebase Authentication). When you ask to reset a password, Google sends the email. It receives your email address.
• Push notifications (Google Firebase Cloud Messaging). Alerts carry no trip details, quantities or names — only a short line such as "open Transint to see it".
• Website delivery (Google Firebase Hosting). Delivers the app's code and public pages. It does not store your records.
• Scheduled-job timer (Google Cloud Scheduler — Doha, Qatar). Only triggers our Johannesburg billing and housekeeping jobs at set times. It holds no personal information.
• Email delivery (Resend — United States). Invitations, password-setup emails, Customer Service messages and alerts when a receiver reports a difference go through Resend. Resend receives the recipient's email address and the message. A difference alert includes the trip reference, site, quantities, seal numbers, the receiver's name and any notes.
• Card payments (Paystack). You type card and bank details on Paystack's own page. Paystack handles them under its own privacy policy. Transint never receives or stores them. Paystack receives the billing email, the amount and a reference to your account.
• App code libraries (Google gstatic, esm.sh, jsDelivr, cdnjs, unpkg). When a Transint page opens, your browser downloads code from these services. They see your IP address and browser details, not your records.
• Maps (OpenStreetMap, Google Maps). The dashboard map loads map images from OpenStreetMap, which sees the manager's IP address and the area shown. If someone taps a "Google Maps" link, Google receives that location.

We send information across borders only as POPIA section 72 allows: where it is needed to provide the Service you signed up for, and where the recipient is bound by law or by binding agreements (including Google Cloud's data processing terms) to protect it to a standard substantially similar to POPIA.

3. Information we collect

• Fleet managers and Customer staff — name, work email, phone number, company name, role and the settings you choose; the Terms version you accepted and when; invitations you send; a device token if you allow push alerts; and any corrections or confirmations you make.
• Drivers — name, email, assigned truck, and everything captured on a trip: photographs (documents, seals, weighbridge slips, loads and, where the Customer's client requires it, security-escort photos at the origin and at the destination), counts, weights, seal numbers, times, and location (see section 4). While a trip is active the app also records the phone's battery level, network type and whether the app is open, so the office can tell a quiet phone from a lost signal.
• Route points — while a trip is active and the app is open, the phone sends its position to the trip about every 2 minutes for the route line. The last 40 points are kept with the trip, with the latest position and a short device snapshot (battery, network, whether the app is open, the last few positions).
• Stored documents — each PDF Transint issues for a finished step, with its fingerprint and the date it was issued.
• Demurrage and escort records — site arrival and departure times, how each time was set, and managers' corrections with their reasons; escort photos and certificates.
• Fuel fills — the truck, the odometer reading and a photo of the odometer (or the driver's reason why no photo was possible), litres, total cost, card or cash, yard or station, a photo of the fuel slip and the time it was taken, and — only if the phone allows it — where the slip photo was taken. Managers' review notes and corrections on a fill are kept with it.
• Corporate Client users and bay clerks — name, work email, role, the sites they are assigned to, and the counts and seal numbers they record.
• Receivers — name, company (optional), verified phone number, the quantity and seal numbers they confirm, whether seals were intact, and any notes they add.
• Public links and scan times — the QR links printed on documents and fuel slips, and the time each link was opened (see section 6).
• Audit and export logs — who corrected, confirmed, reviewed, revoked or exported what, and when.
• Billing — billing email and the payment reference / reusable authorisation token Paystack returns. Never card or bank numbers.
• Location consent records — who agreed, for which trip, when, and which version of the notice they saw.
• Support messages — the name, company, email, phone and message you send through the Customer Service page, and requests for a copy of your data.
• Technical data — error and security logs needed to run, secure and fix the Service, the last few app error messages from the phone, and a check of the phone's clock against our server's time (see section 4).

4. Location information

Before a trip starts, the driver sees a location notice and must agree. Location recording starts only when the driver has agreed for that trip and the trip is active. While the trip is active and the app is open on the driver's screen, the app reads the phone's position to record arrival and departure at sites, time waiting on site, and the route the truck took. Each photo also records the position at the moment it was taken. Recording stops when the trip ends, when the driver changes truck or job, or signs out. The app does not ask for location while it is closed.

The transporter chooses to use Transint and can see these records. As the employer, the transporter must tell its drivers that Transint records location, photos and activity during trips.

How site waiting time is measured

• During an active trip the app keeps location points on the driver's phone only — points accurate to 100 m or better, at most one every 10 seconds. They are used to work out when the truck entered a site's boundary and when it left.
• These site-timing points never leave the phone. Only the worked-out arrival and departure times, how each time was set (boundary entry or exit, the driver's tap, or a manager's correction) and whether a time is approximate are added to the trip. (Route points are separate — see section 3.)
• The points are deleted from the phone when the trip's last site visit has been timed, when the driver signs out, and in any case after 72 hours.
• Near a site, while the app is open, it may keep the phone's screen on so the visit can be timed accurately. This stops after departure or when the app is closed.
• The app compares the phone's clock with our server's time. If the phone's clock is more than two minutes out, the visit is flagged for the manager to review. Times are never changed automatically.

Fuel fills

No location is used in any fuel calculation or fuel check. If the phone shares its location when the slip photo is taken, that position is stored with the photo as information only.

5. Why we use information

• To keep a dated record of each trip for transporters and their customers, available later for disputes, claims, billing and contract questions — performance of the contract with our Customer, and the Customer's legitimate interest.
• To provide the Service: capture, sync, cross-check (bay clerk, driver and receiver), display and export delivery records and documents — performance of the contract with our Customer.
• To time site visits and produce standing-time (demurrage) reports, and to let managers correct or confirm a time with a recorded reason — the Customer's legitimate interest in accurate billing records.
• To check fuel fills (for example a lower odometer reading, more kilometres than the time allows, or efficiency far from the truck's own normal) and flag them for the Customer's review. A flag is a prompt to check, never a finding of wrongdoing — the Customer's legitimate interest in controlling its fuel costs.
• To keep each company's data separate and each driver's work private from other drivers — security and legitimate interest.
• To run the account: sign-in, notifications, billing for active trucks and support — contract.
• To read location during an active trip — the driver's consent, and the Customer's legitimate interest in a record of delivery.
• To prevent fraud and abuse and keep the Service secure — legitimate interest.
• To meet legal obligations, such as tax and accounting records — legal obligation.

We do not sell personal information, use it for advertising, or run advertising or analytics trackers in the Service.

6. Who can see what

• The Customer's managers see their own company's records. Companies never see each other's records.
• Drivers see only their own trips and their own truck — never another driver's work, and never past fuel fills.
• A Corporate Client sees only trips linked to its own contracts: delivery records, documents, site arrival and departure times with standing time, the route line on the Route Proof document, and whether locations were verified. It never sees drivers' contact details, the location points used to time a site visit, fuel records, or escort photos and certificates (only whether an escort was logged, and when).
• Bay clerks see only the trucks to be counted at their own sites. Receivers see only the delivery they are confirming.
• Public links. Anyone holding a printed Transint document can open its QR links without signing in:
  • a document link opens the stored PDF and its fingerprint;
  • a trip link shows the trip's key facts: company, trip reference, vehicle, driver's name, seal numbers and status;
  • a fuel slip link shows the slip photo, slip number and date.
  The fleet manager can revoke a fuel slip link; documents issued after that use a new link. When a link is opened, Transint logs only the time (at most once a minute) — no location and no device details. Like most web services, our hosting provider also keeps standard technical request logs, which include the IP address and browser type, for 30 days for security.
• We may disclose information when the law requires it, or to protect the rights and safety of users or the public.

7. How long we keep information

• Each record, photo and document is kept for 7 years from the day it was created, then deleted automatically. This includes billing records and support messages.
• Corrections make a new version. When a finished trip is corrected, the document is issued again as a new version. The old version stays for 7 years from its own date, and its link points to the newer version.
• Linked items stay as long as the document. Anything a stored document links to — for example a fuel slip photo opened by its QR, or the documents listed on a Trip Summary — is kept until that document's 7 years are up.
• Interim documents are not stored. A Trip Summary while the trip is still running, or a fuel book for a month that is not closed, is marked INTERIM, has no QR code and is not kept.
• Re-downloads. A stored document is the same file every time it is downloaded.
• Account details and settings (company, team, trucks, sites, routes and contracts) are kept while the account is open, and deleted with the account.
• On the driver's phone: location points for at most 72 hours (see section 4); unfinished drafts, including their photos, until they are submitted or for at most 7 days; captures waiting to upload, until they have uploaded.
• Receiver confirmation links work for 3 hours. The receiver's phone sign-in is deleted once the confirmation is filed (or after 24 hours if it never is); the verified number stays with the confirmation.
• Deleting an account. The account owner can delete the account in the app once anything owed for services already used is settled. The transporter's records, photos, documents and sign-ins are then deleted. Copies of documents a corporate customer received stay until that corporate deletes its own account or the copy's 7 years are up, whichever comes first; their QR links keep working until then. A billing record (who the customer was and its payments) and the billing facts of trips billed to a corporate customer are kept for 7 years, as tax and accounting law requires, then deleted automatically.
• When a user is removed from a team, their sign-in is disabled immediately. Drivers, clerks and receivers can ask our Information Officer to delete their sign-in or data (section 9).

8. Security

Data is encrypted in transit (HTTPS) and at rest by our hosting provider. Access requires sign-in; security rules enforce company and driver separation on every request; sensitive photos (such as security escorts) are released only through short-lived signed links; secret keys are kept in a managed secret store in Johannesburg. Once a step has been saved, its photos and site times can no longer be changed or removed from the phone; a manager's correction is added alongside the original with a reason and is audit-logged. No system is perfectly secure. If we become aware of a security compromise affecting personal information, we will notify the affected Customer and, where POPIA requires, the Information Regulator and affected people, as soon as reasonably possible.

9. Your rights

Under POPIA you may ask to see the personal information held about you, ask for it to be corrected, object to its use, or ask for it to be deleted. Send your request to our Information Officer (section 12). Where the information was captured on a Customer's account, we will also tell that Customer, because it is the responsible party. We answer within 30 days.

Some records may be kept for the full 7 years after a request, because the transporter, its customers or the law may need them.

You may withdraw location consent for future trips at any time; a trip then cannot be run in the app, so speak to your fleet manager.

10. Information stored on your device

The driver and clerk apps store data on the device so they keep working without signal: captures waiting to upload, unfinished drafts (so a reload or a switch to the camera never loses work), the location points described in section 4, the signed-in session and app settings. This is needed for the Service to work; we do not use advertising cookies. Each kind of data is removed as set out in section 7.

11. Children

Transint is a business service for adults and is not intended for anyone under 18.

12. Information Officer, PAIA and complaints

The Information Officer of Exluma (Pty) Ltd can be reached at privacy@exluma.co.za or support@exluma.co.za, or through our Customer Service page. Exluma's physical address and other company information are set out in our PAIA manual. If you are not satisfied with our response, you may complain to the Information Regulator (South Africa) — see inforegulator.org.za.

13. Changes to this Policy

We may update this Policy as the Service or the law changes. We show the date and version at the top, keep earlier versions available, and tell Customers about material changes through the Service or by email before they take effect.

What changed in version 2026-10-29: WaybillGO is now called Transint; one 7-year period for every record, photo and document, then automatic deletion (section 7); corrected documents, interim copies and re-downloads (section 7); corporate copies after an account is deleted (section 7); route points sent during a trip (section 3); public links and what is logged (section 6); the full list of outside services (section 2).