Privacy Policy
Republic of Ghana | Data Protection Act, 2012 (Act 843) Compliant | Luminex Logistics Ltd.
Committed to Confidentiality, Data Integrity & Physical Security
Luminex Logistics (“Luminex”, “we”, “us”, or “our”) understands that documents entrusted to us contain confidential, commercially sensitive, or personally identifiable information. Protecting that data is fundamental to our institutional operations across Ghana.
1. Who Is Responsible for Your Personal Information?
For personal information that Luminex collects directly and determines the purposes and means of processing, Luminex acts as the Data Controller.
Where Luminex provides logistics services to an institutional or corporate client and processes personal data strictly on that client’s instructions, Luminex acts as a Data Processor on behalf of that client. In those circumstances, the institutional client determines the purposes of processing, while Luminex securely processes that information in accordance with applicable law and contractual mandates.
Corporate Entity: Luminex Logistics Ltd.
Business Registration Number: CS120930824
Registered Address: H302 Sowah Larbi Ave, Accra, Ghana
Email: luminexlogisticsltd@gmail.com | Telephone: +233 59 646 4461
2. Information We Collect
Depending on how you interact with our services, we may collect the following categories of information:
Customer Information
- Full name, telephone number, email address;
- Residential, business, or digital Ghana Post GPS address;
- Identification details necessary for verification;
- Account credentials & company/organization details;
- Billing records, transaction logs, and customer support communications.
Sender & Recipient Information
- Names and active telephone contact numbers;
- Delivery addresses and handling instructions;
- Identification type for legitimacy verification;
- Signatures, OTP confirmations, and proof of receipt;
- Delivery-related photographic confirmations.
Delivery & Logistics Telemetry
- Pickup and destination geographic coordinates;
- Delivery dates, timestamps, and route milestones;
- Unique Consignment Security Numbers (CSN);
- Courier allocation, tracking states, and attempt logs.
Technology-Generated Data
- IP addresses, device identifiers, and browser types;
- Operating system, diagnostic logs, and platform activity;
- Approximate location data used strictly for dispatch.
Zero-Access Document Protocol
As a fundamental rule, Luminex does not read the contents of your documents. For high-security consignments, Luminex utilizes code-secured hardware safes (such as SentrySafe) during transit. The secure opening code is revealed ONLY TO THE AUTHORIZED CUSTOMER ON THE DAY OF DELIVERY via direct SMS or encrypted email, ensuring couriers and third parties have zero access to your physical documents.
3. How We Use Personal Information
We process personal information only for legitimate operational, security, and legal purposes:
We never use personal information for purposes incompatible with those disclosed, nor do we sell customer data to third-party advertisers.
4. AI Models & Automated Technologies
Luminex uses algorithmic optimization and artificial intelligence to enhance transit efficiency, courier allocation, ETA forecasting, security telemetry, and fraud detection.
AI systems assist our human dispatchers but never replace our legal duty to protect data. Where an automated process could materially impact an individual’s rights, Luminex enforces mandatory human review and intervention.
5. Confidential Documents Protection
We implement comprehensive physical, organizational, and technological controls designed to ensure confidential documents are:
- Collected strictly for authorized delivery purposes;
- Handled exclusively by vetted, credentialed couriers;
- Protected against physical tampering and unauthorized disclosure;
- Delivered strictly to intended, verified recipients; and
- Retained only for the duration reasonably necessary for transit auditability.
6. Legal Basis for Processing under Ghanaian Law
Under the Data Protection Act, 2012 (Act 843), we process personal data under the following lawful grounds:
- Contract Performance: Processing necessary to fulfill our logistics service contract with you;
- Pre-contractual Steps: Processing initiated at your request prior to scheduling a pickup;
- Legal Obligation: Compliance with statutory logistics licensing, taxation, or law enforcement mandates;
- Vital Interests: Protecting the immediate safety or vital interests of individuals;
- Legitimate Interests: Securing our fleet, preventing fraud, and optimizing operations, provided fundamental rights are not overridden; or
- Consent: Where expressly requested, which you may withdraw at any time without invalidating prior lawful processing.
7. Sharing Personal Information & Third-Party Processors
We share information only where reasonably required with vetted recipients:
Service Providers: Cloud infrastructure, telecommunications gateways (SMS/email notifications), mapping/telemetry providers, cybersecurity auditors, and identity verification partners operating under strict written confidentiality covenants compliant with Act 843.
Institutional Clients: When delivering on behalf of corporate partners, we supply transit logs, recipient confirmations, and Proof of Delivery according to agreed instructions.
Law Enforcement & Regulators: We disclose data strictly upon receipt of lawful warrants, court orders, or statutory regulatory demands from Ghanaian authorities.
8. International Data Transfers
Where technology platforms or cloud databases process data outside Ghana, Luminex ensures all transfers comply with Ghanaian data protection standards, including verified data transfer agreements and technical encryption safeguards.
9. Data Security, Incident Response & Breach Management
Our multi-layered security safeguards include strict role-based access control, cryptographic data protection, continuous server audit logs, courier identity verification, and mandatory staff security training.
Statutory Incident Notification Protocol (Act 843):
In the event of an actual or suspected security compromise involving personal data, Luminex will rapidly contain the incident, initiate technical forensics, restore systems, notify the Ghana Data Protection Commission, and inform affected clients and individuals as required by law.
10. Data Retention & Secure Disposal
Personal data is retained only for the timeframe necessary to complete courier dispatches, resolve customer service or refund claims, maintain statutory financial records, and satisfy legal audit mandates. When no longer required, records are permanently sanitized, deleted, or anonymized.
11. Your Statutory Data Protection Rights
Under the Data Protection Act (Act 843), Ghanaian citizens and corporate clients maintain statutory rights to:
13. Contact Our Data Protection Desk
To exercise any statutory right, lodge an inquiry, or discuss data protection compliance, contact our Compliance Office:
Compliance Officer: Luminex Logistics Data Protection Desk
Entity: Luminex Logistics Ltd. (Registration No. CS120930824)
Address: H302 Sowah Larbi Ave, Accra, Ghana
Telephone: +233 59 646 4461
You also have the statutory right under Ghanaian law to lodge a complaint directly with the Ghana Data Protection Commission (DPC) if you believe your personal data rights have been violated.