Last Updated: December 29, 2025

Polygon Holding (Private) Limited (“Polygon”, “we”, “us”, or “our”) cares about privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal data when you use the Govi Transporter mobile application (“App” or “Service”). Govi Transporter is used by authorized transporters/drivers to pick up products from the CoDi system and deliver them to customers.

This Policy applies to drivers, couriers, contractors, employees, and other authorized users of the App (collectively, “Users”). It also explains how we handle customer delivery information that Users access while performing deliveries.

1. Scope & Who We Are

Govi Transporter is developed, operated, and administered by Polygon Holding (Private) Limited. The App is intended for use by authorized transport personnel and is distributed under managed distribution. This Policy covers data processed in connection with the App and related backend services.

Contact:
Polygon Holding (Private) Limited
Forbes & Walkers Building 2, No. 46/42, Colombo 02, Sri Lanka
Email: info@polygon.lk
Website: https://polygonagro.lk

2. Key Definitions

• Personal Data — information that identifies or can reasonably identify an individual (e.g., name, phone number).
  
  

• Usage Data — technical and usage information generated automatically while using the App (e.g., device identifiers, logs).
  
  

• Recipient / Customer Data — delivery recipient’s name, phone, address, and delivery instructions provided through CoDi that transporters use to complete deliveries.

3. Lawful Basis & Purpose of Processing

We process Personal Data only for legitimate, relevant purposes, including:

• Fulfilling delivery and logistics tasks assigned through CoDi (performance of contract / service obligations).
  
  

• Verifying and authorizing transporter access.
  
  

• Managing routes, scheduling, and operational coordination.
  
  

• Communication with Users and recipients (e.g., status updates, delivery confirmation).
  
  

• Fraud prevention, safety, and security (including investigation of incidents).
  
  

• Improving App functionality, analytics, and debugging.
  
  

• Complying with legal, tax, audit, and regulatory obligations.
  
  

Where required by applicable law, we rely on consent, contractual necessity, or Polygon’s legitimate business interests to process data.

4. Types of Data Collected

a. From Transporter / App Users

• Identity & Contact: Full name, work email, phone number.
  
  

• Verification Documents: Government ID, driver’s license, vehicle registration, and any certificates required for onboarding (with explicit consent).
  
  

• Employment Info: Job title, contractor status, company/partner affiliation.
  
  

• Device & Usage Data: Device type, operating system and version, app version, device identifiers, IP address, log-in timestamps, interaction logs, diagnostic/crash reports.
  
  

• Location Data: Real-time GPS location while performing deliveries (if permitted) and route history for operational purposes.
  
  

• Camera & Storage Access: Photos of delivered items, proof-of-delivery images, or documents uploaded for job purposes (with consent).
  
  

b. Recipient / Customer Data (accessed during delivery)

• Recipient name, delivery address, phone number, delivery instructions, signature or photo proof of delivery.
  
  

c. Optional / Voluntary Data

• Preferences, notes, or other information you choose to provide (e.g., availability, vehicle details).

5. How We Use Location & Camera Permissions

• Location: Used to navigate, record routes, confirm pickups/deliveries, and for operational safety. Location tracking is active only while you are on an assigned delivery task, unless you explicitly enable background tracking.
  
  

• Camera & Storage: Used to capture proof-of-delivery images, scan documents, or upload delivery-related files. Stored images are used solely for operational verification and dispute resolution.
  
  

You may be prompted to grant these permissions during onboarding or when required by a feature. You can withdraw permission at any time via your device settings, though withdrawing required permissions may limit your ability to use the App.

6. Sharing & Disclosures

We do not sell or lease Personal Data for marketing. Data may be shared as follows:

• Internal Access: Authorized Polygon personnel, operations, logistics, and support teams.
  
  

• Service Providers: Trusted third-party vendors who provide cloud hosting, analytics, communication, mapping/navigation, payment, or identity verification services under contract and confidentiality obligations.
  
  

• CoDi System: Where needed to coordinate pickups and delivery assignments between CoDi and Govi Transporter.
  
  

• Legal & Safety: When required by law, regulation, or to protect safety, rights, property, or operations (e.g., subpoenas, investigations).
  
  

• Mergers & Business Transfers: In the event of reorganization, sale, or transfer of assets, Personal Data may be transferred subject to confidentiality and this Policy.
  
  

If we transfer data across borders, we will ensure appropriate protections (e.g., standard contractual clauses or equivalent safeguards) are in place.

7. Data Retention

We retain Personal Data only as long as necessary to:

• Provide the App and fulfill operational needs (e.g., 2–7 years for accounting, audit, or dispute resolution)
  
  

• Comply with legal obligations
  
  

• Enforce agreements and protect legal rights
  
  

Retention periods may vary by data type and applicable law. When no longer required, data is securely deleted or anonymized.

8. Security

We implement reasonable administrative, technical, and physical safeguards to protect Personal Data (access controls, encryption in transit and at rest where feasible, secure hosting, logging and monitoring). However, no system is perfect; in the unlikely event of a data breach that creates a real risk to affected individuals, we will notify impacted parties and regulators as required by law.

9. User Rights & Controls

Depending on your jurisdiction and status (employee/contractor/driver), you may have rights including:

• Access to personal data we hold about you.
  
  

• Correction or update of inaccurate or incomplete data.
  
  

• Deletion of personal data (subject to legal or operational retention requirements).
  
  

• Restriction or objection to certain processing.
  
  

• Portability of data you provided in a structured, machine-readable format.
  
  

• Withdrawal of consent where processing is based on consent.
  
  

To exercise these rights, contact the App administrator or email info@polygon.lk. We may ask for verification before fulfilling requests. Some requests may be limited by legal or operational needs (for example, retention required for audits, tax, or dispute resolution).

10. Minors

The App is intended for adult transporters aged 18 years or older. We do not knowingly collect or retain information from persons under 18 for App use. If you believe a minor’s data has been collected, contact us and we will take steps to remove it.

11. Third-Party Integrations & Links

The App may integrate with third-party services (e.g., maps, messaging, cloud storage). These services have their own privacy policies — we recommend you review them. We are not responsible for third-party practices.

12. Marketing & Communications

We may send operational messages, service notifications, and occasional updates about App changes. Promotional communications (if any) will be sent only with your consent and you can opt out at any time.

13. Changes to This Policy

We may update this Policy to reflect product or legal changes. The “Last Updated” date at the top will change when we publish updates. Significant changes will be communicated via in-App notices or internal channels.

14. Contact & Complaints

Questions, requests, or complaints about this Policy or our data practices should be directed to:

Polygon Holding (Private) Limited
Email: info@polygon.lk

If you remain unsatisfied you may bring a complaint to your local data protection authority where applicable.

15. Additional Operational Notes (for Administrators)

• Onboarding: Collect only necessary verification documents and store them securely.
  
  

• Access Controls: Grant App backend access on a least-privilege basis and maintain audit logs.
  
  

• Incident Response: Maintain a documented incident response plan with breach notification timelines.
  
  

• Record of Processing: Maintain internal records of processing activities linked to Govi Transporter for audit/compliance.