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ACE CONNECT

Privacy Policy

Effective 18 April 2026 · Version 1.00

This English version is the authoritative version. Translations may be provided for convenience.

1. Introduction

This Privacy Policy explains how African Clean Energy ("ACE", "we", "us", or "our") collects, uses, shares, and protects your personal information when you use the ACE Connect mobile application (the "App"). By using the App, you 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.

2. Information We Collect

2.1 Information you provide

  • Full name, date of birth, and gender
  • Phone number and alternative contact number
  • National ID number (where required for credit verification)
  • Home and sales location (GPS coordinates)
  • Photograph and signature (captured at point of sale)
  • Proof-of-purchase and contract details

2.2 Information collected from your stove

  • Stove serial number and controller ID
  • Stove usage data: fan hours, cooking sessions, sync timestamps
  • Credit status and firmware version
  • Diagnostic logs

2.3 Information collected automatically

  • Device identifiers (IMEI, Firebase installation ID)
  • App version and operating system version
  • Network connection type (used for zero-rating routing)
  • Crash reports and performance metrics
  • Push notification tokens

2.4 Payment information

  • Mobile money transaction references (amount, date, provider, masked phone number)
  • Loan repayment history
  • Fuel order history

We do not collect or store your mobile money PIN or full account credentials. Payments are processed directly by your mobile money provider.

3. Why We Collect This Information

Purpose Data used
Create and manage your customer accountName, phone, ID, photograph, signature
Service your loan and process repaymentsLoan contract, payment history, ID
Enable stove operation and diagnosticsStove serial, usage data, credit status
Deliver fuel ordersPhone, location, order history
Calculate and verify carbon creditsStove usage data, location, stove ID
Provide customer supportContact details, support history
Send notifications (payments, fuel, general)Firebase token, phone
Improve the App and fix bugsCrash reports, analytics, device info
Comply with legal and regulatory obligationsAll of the above, as required

4. Who We Share Your Information With

We share your information with the following categories of third parties, only as necessary for the purposes in Section 3:

Recipient Role Data shared
Salesforce (salesforce.com Inc., USA)Our customer relationship management platformAll account, loan, payment, and usage data
Google Firebase (Google LLC, USA)Push notifications, crash reporting, analyticsDevice tokens, crash logs, usage events
Google BigQuery (Google LLC, USA)Analytics data warehouseAggregated stove usage data
Mobile money providers (including MTN, Safaricom, Vodacom, Wave, ABA Bank)Payment processingTransaction amount, reference, phone
Third-party loan financiers (such as, historically, Kiva Microfunds)Funding of customer loans where applicableLoan details, name, photo, location, story
Carbon credit registries (such as Gold Standard)Carbon credit certificationAggregated stove usage and location
ACE subsidiaries and local operating entitiesLocal sales, maintenance, and supportAll relevant account and service data

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

We may also disclose your 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 in which you purchased your stove. Where your 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

We retain your personal data for as long as you remain a customer of ACE, including for the duration of any active loan, stove servicing relationship, or carbon programme participation. After the customer relationship ends, we may continue to retain your data where required by law (for example, financial record-keeping obligations), after which we will delete or anonymise it.

7. How We Protect Your Data

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

  • Encrypted connections between the App and our servers (HTTPS/TLS)
  • 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
  • Delete your data (subject to our legal retention obligations)
  • Restrict or object to certain processing
  • Port your data to another provider
  • Withdraw consent you previously gave
  • Complain to your national data protection authority

To exercise these rights, contact us at the details in Section 13. We will respond within 30 days.

9. Children

The App is not intended for use by children under 18. We do not knowingly collect data from children. If you believe a child has provided us with personal information, please contact us and we will delete it.

10. Carbon Credits and Your Usage Data

A key purpose of the App is to enable the generation of verified carbon credits from your use of the ACE One stove. By purchasing an ACE stove and using the App, you cede the rights to any carbon credits generated from your stove usage to ACE, as set out in your stove purchase contract and our Biofuel Terms and Conditions. These credits are sold to third parties and the proceeds fund ACE's continued operations, including stove and fuel distribution. Your stove usage data is shared with carbon registries in a form that complies with registry requirements.

11. Language Versions

This Privacy Policy is published in English as the authoritative version. Translations into French, Portuguese, Khmer, Sesotho, and other languages may be provided for your convenience within the App or on our website. In case of any discrepancy between the English version and a translation, the English version shall prevail.

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.

13. Contact Us

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

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