Privacy Policy

Last updated: February 27, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application refers to Haffiri Freight, the software program provided by the Company.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to HAFFIRI LLC, 160 Alewife Brook Pkwy, Cambridge, MA 02138.
• Country refers to: Massachusetts, United States.
• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual. We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Description of the Service and Business Model

Haffiri Freight is a freight matching platform that connects shippers ("Shippers") with carriers ("Carriers") in West Africa. The Service facilitates the transportation of goods by enabling Shippers to post freight loads and Carriers to bid on and deliver those loads.

How the Platform Works:

• Shippers pay fees to post freight loads on the platform. These fees may include load posting fees, subscription fees, or other charges as described in the applicable terms of service.
• Carriers deliver freight loads posted by Shippers and receive delivery fees for their services. The Company may deduct a commission or service fee from the Carrier's delivery fee.
• The Company facilitates payment transactions between Shippers and Carriers through the platform, including through third-party payment processors such as Wave Mobile Money.

The Personal Data We collect is necessary to operate this freight matching marketplace, process payments, verify the identity of participants, and ensure the safety and reliability of freight deliveries.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Information regarding your location
• Pictures and other information from your Device's camera and photo library

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that you have already purchased or inquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• To process payments: To process and facilitate payment transactions between Shippers and Carriers, including load posting fees, delivery fees, commissions, and any applicable refunds or disputes.
• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyze the use of our Service, to process payments, to send communications on Our behalf, and to contact You.
• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your Personal Data with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your Personal Data with Our business partners to offer You certain products, services or promotions.
• With other users: If Our Service offers public areas, when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

Payment Processing

We use third-party payment processors to handle payment transactions on Our platform. When You make or receive payments through the Service, Your payment information is collected and processed by Our payment processor(s) in accordance with their respective privacy policies.

Wave Mobile Money

We use Wave (https://www.wave.com/en/) to process mobile money payments on Our platform, including load posting fees paid by Shippers and delivery fees paid to Carriers. When You initiate a payment through Wave, Wave may collect the following information:

• Your mobile phone number
• Transaction amounts and history
• Your Wave account information
• Device and network information related to the transaction

The information collected by Wave is governed by Wave's own privacy policy, available at: https://www.wave.com/en/. We encourage You to review Wave's privacy policy before making payments through the Service.

We do not store Your complete mobile money credentials or Wave PIN on Our servers. We may retain transaction records (including transaction IDs, amounts, dates, and the parties involved) for the purposes of dispute resolution, accounting, legal compliance, and platform integrity.

Email Communications

We use third-party email service providers to send transactional and marketing communications to You.

SendGrid (Twilio)

We use SendGrid, a Twilio company, to deliver email communications including account verification emails, password reset emails, transaction notifications, shipment updates, and promotional communications. When We send You an email through SendGrid, the following information may be processed:

• Your email address
• Your name (as used in email personalization)
• Email engagement data (such as whether an email was delivered, opened, or links were clicked)
• Device and browser information related to email interactions

SendGrid processes this information in accordance with Twilio's privacy policy, available at: https://www.twilio.com/en-us/legal/privacy.

You may opt out of promotional emails at any time by clicking the "unsubscribe" link in any promotional email or by contacting Us. Please note that You may not opt out of transactional emails related to Your account or active shipments.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:

Account Information

• User Accounts: retained for the duration of your account relationship plus up to 24 months after account closure to handle any post-termination issues or resolve disputes.

Customer Support Data

• Support tickets and correspondence: up to 24 months from the date of ticket closure to resolve follow-up inquiries, track service quality, and defend against potential legal claims.
• Chat transcripts: up to 24 months for quality assurance and staff training purposes.

Usage Data

• Application usage statistics: up to 24 months to understand feature adoption and service improvements.
• Server logs (IP addresses, access times): up to 24 months for security monitoring and troubleshooting purposes.

Payment and Transaction Data

• Transaction records (including amounts, dates, parties, and transaction IDs): up to 60 months (5 years) to comply with financial record-keeping requirements, tax obligations, and to resolve payment disputes.
• Payment processor references: retained for as long as the associated transaction records are retained.

Usage Data is retained in accordance with the retention periods described above, and may be retained longer only where necessary for security, fraud prevention, or legal compliance.

We may retain Personal Data beyond the periods stated above for different reasons:

• Legal obligation: We are required by law to retain specific data (e.g., financial records for tax authorities).
• Legal claims: Data is necessary to establish, exercise, or defend legal claims.
• Your explicit request: You ask Us to retain specific information.
• Technical limitations: Data exists in backup systems that are scheduled for routine deletion.

You may request information about how long We will retain Your Personal Data by contacting Us.

When retention periods expire, We securely delete or anonymize Personal Data according to the following procedures:

• Deletion: Personal Data is removed from Our systems and no longer actively processed.
• Backup retention: Residual copies may remain in encrypted backups for a limited period consistent with our backup retention schedule and are not restored except where necessary for security, disaster recovery, or legal compliance.
• Anonymization: In some cases, We convert Personal Data into anonymous statistical data that cannot be linked back to You. This anonymized data may be retained indefinitely for research and analytics.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and supplementary measures where appropriate. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Usage, Performance and Miscellaneous

We may use third-party Service Providers to maintain and improve our Service.

Google Places

Google Places is a service that returns information about places using HTTP requests. It is operated by Google. Google Places service may collect information from You and from Your Device for security purposes. The information gathered by Google Places is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

SendGrid (Twilio)

SendGrid is an email delivery service operated by Twilio Inc. We use SendGrid to send transactional and marketing emails on Our behalf. SendGrid may process Your email address, name, and email engagement data. The information gathered by SendGrid is held in accordance with Twilio's Privacy Policy: https://www.twilio.com/en-us/legal/privacy

Wave Mobile Money

Wave is a mobile money service used to process payments on Our platform. Wave may collect Your mobile phone number, transaction data, and device information. The information gathered by Wave is held in accordance with Wave's Privacy Policy: https://www.wave.com/en/

Your Privacy Rights Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)

If You are a California resident, You have specific rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, "CCPA"). This section describes Your rights and how to exercise them.

Categories of Personal Information Collected

In the preceding 12 months, We have collected the following categories of Personal Information:

• Identifiers: name, email address, phone number, mailing address, account name, IP address, mobile device ID.
• Personal information under Cal. Civ. Code §1798.80(e): name, address, telephone number.
• Commercial information: transaction history, load postings, delivery records, payment history, services purchased or considered.
• Internet or network activity: browsing history on Our Service, search history, interaction with Our Application.
• Geolocation data: precise or approximate location data collected through the Application with Your permission.
• Professional or employment-related information: business name, role (Shipper or Carrier), vehicle information for Carriers.
• Inferences: preferences, characteristics, and behavior patterns drawn from the above categories.

Sources of Personal Information

We collect Personal Information directly from You, automatically through Your use of the Service, and from third-party Service Providers such as payment processors and analytics providers.

Business or Commercial Purposes for Collection

We collect Personal Information for the purposes described in the "Use of Your Personal Data" section above, including providing the Service, processing payments, communicating with You, and improving the Service.

Sale and Sharing of Personal Information

We do not sell Your Personal Information for monetary consideration. We do not share Your Personal Information for cross-context behavioral advertising purposes. We have not sold or shared Personal Information of consumers in the preceding 12 months.

Your CCPA/CPRA Rights

As a California resident, You have the following rights:

• Right to Know: You have the right to request that We disclose the categories and specific pieces of Personal Information We have collected about You, the categories of sources, the business purposes for collection, and the categories of third parties with whom We share Your Personal Information.
• Right to Delete: You have the right to request deletion of Your Personal Information, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate Personal Information that We maintain about You.
• Right to Opt-Out of Sale/Sharing: Although We do not sell or share Your Personal Information, You have the right to opt out of such activities should Our practices change.
• Right to Limit Use of Sensitive Personal Information: You have the right to limit the use and disclosure of sensitive Personal Information to purposes necessary to provide the Service.
• Right to Non-Discrimination: We will not discriminate against You for exercising any of Your CCPA/CPRA rights.

How to Exercise Your Rights

To exercise any of the rights described above, You may contact Us by email at contact@haffiri.com. We will verify Your identity before processing Your request. You may also designate an authorized agent to make a request on Your behalf. We will respond to Your request within 45 days, or inform You if We need an extension of up to an additional 45 days.

Retention

We retain each category of Personal Information for the periods described in the "Retention of Your Personal Data" section above.

California Online Privacy Protection Act (CalOPPA) Compliance

CalOPPA requires commercial websites and online services that collect personally identifiable information from California consumers to post a conspicuous privacy policy. In accordance with CalOPPA:

• Conspicuous Posting: This Privacy Policy is accessible from Our Application and any associated website via a conspicuous link.
• Information Collected: We describe the categories of personally identifiable information collected and the categories of third parties with whom it may be shared in the sections above.
• Policy Changes: We will notify You of material changes to this Privacy Policy via email and/or a prominent notice on Our Service before the changes take effect.
• Do Not Track Signals: Our Service does not currently respond to "Do Not Track" browser signals. If a uniform standard for responding to such signals is adopted, We will update this policy accordingly.
• Third-Party Tracking: Third-party Service Providers (such as analytics and payment processors) may track Your activity on Our Service. We encourage You to review their privacy policies.
• Account Management: Registered users may review and update their personally identifiable information through their account settings or by contacting Us.

General Data Protection Regulation (GDPR) — Rights of European Economic Area (EEA) and United Kingdom (UK) Residents

If You are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, You have certain rights under the General Data Protection Regulation (GDPR) and the UK GDPR. This section supplements the rest of this Privacy Policy and applies only to residents of these regions.

Data Controller

HAFFIRI LLC is the data controller responsible for Your Personal Data. You can contact Us at contact@haffiri.com.

Legal Bases for Processing

We process Your Personal Data only where We have a lawful basis to do so. The legal bases We rely on include:

• Contractual necessity: Processing is necessary to perform Our contract with You (e.g., providing the freight matching Service, processing payments, managing Your account).
• Legitimate interests: Processing is necessary for Our legitimate business interests (e.g., improving the Service, preventing fraud, ensuring platform security), provided those interests are not overridden by Your rights and freedoms.
• Consent: Where You have given Us specific consent to process Your Personal Data for a particular purpose (e.g., location tracking, marketing communications). You may withdraw consent at any time.
• Legal obligation: Processing is necessary to comply with a legal obligation to which We are subject.

Your GDPR Rights

Under the GDPR, You have the following rights:

• Right of Access: You have the right to request a copy of the Personal Data We hold about You.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete Personal Data.
• Right to Erasure ("Right to Be Forgotten"): You have the right to request deletion of Your Personal Data, subject to certain legal exceptions.
• Right to Restriction of Processing: You have the right to request that We restrict the processing of Your Personal Data under certain circumstances.
• Right to Data Portability: You have the right to receive Your Personal Data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Right to Object: You have the right to object to the processing of Your Personal Data based on Our legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, You have the right to withdraw Your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in the EEA Member State of Your habitual residence, place of work, or place of the alleged infringement.

International Data Transfers

Your Personal Data may be transferred to and processed in the United States and other countries outside the EEA/UK. When We transfer Personal Data outside of these regions, We rely on appropriate legal mechanisms such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other safeguards permitted by applicable law, to ensure Your data receives an adequate level of protection.

How to Exercise Your Rights

To exercise any of the rights described above, please contact Us at contact@haffiri.com. We will respond to Your request within one (1) month, or inform You if We require an extension of up to two (2) additional months due to complexity or volume of requests.

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: contact@haffiri.com