Privacy Policy
Last Updated: January 1, 2026
Your Privacy Matters: This Privacy Policy explains how Africoin and Africa Railways collect, use, disclose, and protect your personal information when you use our Services.
1. Introduction
Africoin ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy applies to all users of the Africoin platform, Africa Railways ticketing system, Sentinel Portal, OCC Dashboard, and related services (collectively, the "Services").
By using our Services, you consent to the collection and use of your information as described in this Privacy Policy.
2. Information We Collect
2.1 Personal Information
We collect information that identifies you as an individual, including:
- Account Information: Name, email address, phone number, date of birth
- Payment Information: Mobile money account details, transaction history
- Identification: Government-issued ID for verification purposes
- Travel Information: Route preferences, travel history, ticket purchases
2.2 Blockchain Data
When you interact with our blockchain services, we collect:
- Wallet Addresses: Public blockchain addresses
- Transaction Data: NFT minting records, ticket purchases
- Smart Contract Interactions: On-chain activity logs
- IPFS Metadata: Ticket metadata stored on IPFS
2.3 Technical Information
We automatically collect technical data, including:
- Device Information: Device type, operating system, browser type
- Usage Data: Pages visited, features used, time spent
- IP Address: Internet Protocol address and location data
- Cookies: Session cookies and tracking technologies
- USSD Sessions: USSD code interactions and session data
2.4 Communication Data
We collect information from your communications with us:
- Customer support inquiries
- Feedback and survey responses
- SMS and push notifications preferences
3. How We Use Your Information
3.1 Service Provision
We use your information to:
- Process ticket purchases and issue NFT-based tickets
- Facilitate gasless blockchain transactions
- Verify ticket authenticity and prevent fraud
- Provide USSD-based ticketing for feature phones
- Manage your account and preferences
3.2 Platform Operations
We use your data to:
- Monitor system health and performance
- Detect and prevent security threats
- Analyze usage patterns and improve Services
- Maintain blockchain infrastructure
- Optimize gas policy and transaction costs
3.3 Communication
We may use your information to:
- Send ticket confirmations and travel updates
- Provide customer support
- Send service announcements and notifications
- Deliver marketing communications (with your consent)
3.4 Legal Compliance
We process your data to:
- Comply with legal obligations
- Respond to law enforcement requests
- Enforce our Terms of Service
- Protect our rights and property
4. Data Sharing and Disclosure
4.1 Service Providers
We share data with third-party service providers:
| Service Provider |
Purpose |
Data Shared |
| Alchemy |
Blockchain infrastructure |
Wallet addresses, transaction data |
| Pinata (IPFS) |
Metadata storage |
Ticket metadata, images |
| M-Pesa / Mobile Money |
Payment processing |
Phone number, payment details |
| Twilio / Africa's Talking |
SMS notifications |
Phone number, message content |
| Google Cloud Platform |
Cloud hosting |
Usage data, logs |
4.2 Blockchain Transparency
Important: Blockchain transactions are public and permanent. Your wallet address and transaction history on Polygon and Sui blockchains are publicly visible and cannot be deleted.
4.3 Legal Requirements
We may disclose your information when required by law or to:
- Comply with legal processes or government requests
- Enforce our Terms of Service
- Protect the rights, property, or safety of Africoin, our users, or the public
- Investigate fraud or security issues
4.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.
5. Data Security
We implement industry-standard security measures to protect your information:
- Encryption: Data encrypted in transit (TLS/SSL) and at rest
- Access Controls: Role-based access to sensitive data
- Monitoring: 24/7 security monitoring via OCC Dashboard
- Audits: Regular security audits and penetration testing
- Blockchain Security: Multi-signature wallets and gas policy controls
However, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.
6. Data Retention
We retain your information for as long as necessary to provide Services and comply with legal obligations:
- Account Data: Retained while your account is active
- Transaction Records: Retained for 7 years for tax and legal compliance
- Blockchain Data: Permanent and immutable on public blockchains
- Usage Logs: Retained for 90 days for security and analytics
7. Your Rights
Depending on your location, you may have the following rights:
- Access: Request a copy of your personal data
- Correction: Update or correct inaccurate information
- Deletion: Request deletion of your data (subject to legal requirements)
- Portability: Receive your data in a machine-readable format
- Objection: Object to processing of your data
- Withdrawal: Withdraw consent for marketing communications
To exercise these rights, contact us at privacy@africarailways.com.
Blockchain Limitation: Data stored on public blockchains (Polygon, Sui) cannot be deleted or modified due to the immutable nature of blockchain technology.
8. Cookies and Tracking
We use cookies and similar technologies to:
- Maintain user sessions
- Remember preferences
- Analyze usage patterns
- Improve user experience
You can control cookies through your browser settings. Disabling cookies may limit functionality.
9. Third-Party Links
Our Services may contain links to third-party websites (e.g., blockchain explorers, payment gateways). We are not responsible for the privacy practices of these external sites.
10. Children's Privacy
Our Services are not intended for children under 18. We do not knowingly collect personal information from children. If you believe we have collected data from a child, please contact us immediately.
11. International Data Transfers
Your information may be transferred to and processed in countries outside your residence. We ensure appropriate safeguards are in place to protect your data in accordance with this Privacy Policy.
12. Data Protection Laws
12.1 GDPR Compliance (European Users)
If you are in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):
- Right to Access: Request copies of your personal data
- Right to Rectification: Correct inaccurate or incomplete data
- Right to Erasure: Request deletion of your data ("right to be forgotten")
- Right to Restriction: Limit how we use your data
- Right to Data Portability: Transfer your data to another service
- Right to Object: Object to certain types of processing
- Rights Related to Automated Decision-Making: Not be subject to decisions based solely on automated processing
Legal Basis for Processing: We process your data based on:
- Consent: When you explicitly agree (e.g., marketing communications, IDO participation)
- Contract: To fulfill our contractual obligations (e.g., ticket purchases, token sales)
- Legal Obligation: To comply with laws (e.g., KYC/AML requirements for IDO)
- Legitimate Interests: For business operations, fraud prevention, and system security
Data Protection Officer: You can contact our DPO at dpo@africarailways.com
Supervisory Authority: You have the right to lodge a complaint with your local data protection authority if you believe we have not complied with GDPR.
12.2 POPIA Compliance (South Africa)
We comply with the Protection of Personal Information Act (POPIA). You have rights under POPIA to access, correct, and delete your personal information.
12.3 IDO-Specific Data Processing
For participation in the AFRC Initial DEX Offering (IDO), we collect and process additional information:
- KYC/AML Information: Identity verification documents, proof of address, source of funds
- Wallet Information: Public wallet addresses for token distribution
- Investment Data: Contribution amounts, transaction hashes, vesting schedules
- Accreditation Status: Information to verify investor accreditation (where required)
- Tax Information: Tax identification numbers for regulatory compliance
Legal Basis: Processing of IDO data is based on:
- Contractual Necessity: To execute the token sale agreement
- Legal Compliance: To meet securities regulations, AML/CFT requirements, and tax laws
- Consent: For optional marketing and community communications
Data Retention for IDO: KYC documents and transaction records are retained for at least 7 years after the IDO to comply with financial regulations.
Third-Party KYC Providers: We use verified third-party KYC/AML service providers (e.g., Jumio, Onfido) who process your data according to their own privacy policies and security standards.
12.4 Cookie Consent (GDPR/ePrivacy)
We use cookies and similar tracking technologies. Upon visiting our website, you will be presented with a cookie consent banner allowing you to accept or reject non-essential cookies. You can modify your cookie preferences at any time through our Cookie Settings page.
Cookie Categories:
- Strictly Necessary: Required for website functionality (cannot be disabled)
- Analytics: Help us understand website usage (requires consent)
- Marketing: Used for targeted advertising (requires consent)
- Functional: Remember your preferences and settings (requires consent)
12.5 International Transfers & Data Localization
Your data may be transferred to and processed in countries outside your residence, including:
- Cloud Infrastructure: Google Cloud Platform (USA, EU regions)
- Blockchain Networks: Polygon (global), Sui (global)
- Payment Processors: Various jurisdictions based on payment method
- KYC Providers: Data centers in EU and USA
For transfers from the EEA to non-EEA countries, we rely on:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Adequacy decisions where applicable
- Privacy Shield Framework (for eligible US organizations)
12.6 Automated Decision-Making
We may use automated systems for:
- Fraud Detection: Automated screening for suspicious transactions
- Whitelist Approval: Automated preliminary screening (subject to manual review)
- Risk Assessment: Automated AML/CFT risk scoring
You have the right to request human review of any automated decision that significantly affects you.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. Continued use of the Services after changes constitutes acceptance of the updated policy.
14. Contact Us
For questions about this Privacy Policy or to exercise your rights, contact us:
15. Consent
By using the Africoin platform and Africa Railways services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.