Mtyana Tracker is a fleet-monitoring platform. It shows a vehicle owner where their vehicles are and whether anything is wrong with them. This notice explains what data the platform handles, why, and what rights people have over it under Uganda’s Data Protection and Privacy Act, 2019.
1. Who is responsible
The Mtyana Tracker platform is operated by Vaig Consulting. Where a fleet owner uses the platform to monitor their own vehicles and drivers, that fleet owner decides what is collected and why, and is the data controller for their drivers’ data. Vaig Consulting processes that data on their behalf as a data processor. During the current beta, Vaig Consulting operates its own fleet on the platform and acts in both roles.
2. What the mobile app collects from your phone
Nothing. The Mtyana mobile app requests no permissions. It does not read your phone’s location, contacts, camera, microphone or photos. It contains no analytics, advertising or tracking libraries, and no crash-reporting SDK. It does not create an account or ask you to sign in.
The only thing the app stores on your device is a copy of the most recent fleet status, so the map is not blank when you open it without a network connection, and the address of the server it connects to. Both stay on the phone and are removed when you uninstall the app.
The locations shown in the app come from tracking hardware fitted to vehicles and sent over the network. They are not derived from the phone running the app.
3. What the platform processes
Tracking devices fitted to vehicles send the platform readings of the vehicle’s state. Depending on the device and how it is installed, these include:
- Position and movement — latitude and longitude, speed, heading, and fix quality (satellite count, HDOP), with the time the device recorded them
- Vehicle state — ignition on or off, motion, odometer, engine hours, engine RPM and coolant temperature where the device reads them
- Fuel — tank level as a percentage and in litres, where a fuel probe is fitted
- Device health — external and backup battery voltage, GSM signal strength, and the device’s own identifier (IMEI)
- Events — harsh braking, harsh acceleration, harsh cornering, speeding, fuel drain or refuelling, power disconnection, panic or SOS, and entering or leaving a defined zone
- Assignment — which driver a fleet owner has recorded against a vehicle, and that driver’s name and contact number where the fleet owner has entered them
4. Drivers
Vehicle location is personal data when it can be linked to an identifiable driver, and driving-behaviour events are personal data about that driver’s conduct at work. We treat them as such.
A fleet owner using this platform is responsible for telling their drivers, before monitoring begins, that vehicles are tracked, what is recorded, and why. Monitoring a worker without informing them is not something this platform is intended to support.
Where driver-behaviour scores are produced, they are advisory. Any consequence for a driver is decided by a person, not automatically by the platform.
5. Why we process it
Vehicle telemetry is processed so a fleet owner can locate their vehicles, detect theft of fuel or of the vehicle itself, know when a tracking device has failed or been tampered with, keep records of trips and distance, and improve driving safety. The lawful basis is the legitimate interest of the vehicle owner in protecting their property and operating their business, and, for driver data, the performance of the employment or engagement relationship.
We do not sell data, and we do not use it for advertising or profiling for advertising.
6. Who else sees it
A fleet owner’s data is visible to that fleet owner and to the people they authorise. We share it with no one else, except:
- the infrastructure providers who host the servers and database on our behalf
- the mobile network operator carrying the tracking device’s data
- where we are legally required to disclose it, for example under a court order
Map imagery is served by third-party map providers. Loading a map tile discloses the map area being viewed to that provider, in the ordinary way that any web map works.
7. Where it is stored and for how long
Data is held in a managed database and retained for as long as the fleet owner’s account is active, so that historical trips and reports remain available. A fleet owner may ask us to delete their data at any time. TestFlight beta builds and their associated data are removed when the beta ends.
Where data is stored outside Uganda, we do so on the conditions the Data Protection and Privacy Act, 2019 sets for transfers of personal data outside the country.
8. Your rights
Under the Data Protection and Privacy Act, 2019 you may:
- ask what personal data we hold about you and receive a copy
- have inaccurate data corrected
- ask for your data to be deleted
- object to processing, or ask that it be restricted
- complain to the Personal Data Protection Office (PDPO) at NITA-U
If you are a driver, address requests to the fleet owner who monitors your vehicle in the first instance, since they decide what is collected. Write to us at the address below and we will pass the request on and support them in answering it.
9. Security
Access to fleet data requires authorisation. Only tracking devices we have registered are accepted by our ingestion service. Our database and message broker are not exposed to the public internet. No system is perfect, and we do not claim otherwise; if a breach affects your data we will notify those affected and the regulator as the law requires.
10. Children
Mtyana Tracker is a tool for businesses that operate vehicles. It is not directed at children and we do not knowingly process children’s data.
11. Changes to this notice
The platform is in active development and this notice will change as it does. The date at the top shows when it was last revised. Material changes will be communicated to fleet owners directly.
12. Contact
Questions about this notice, or a request to exercise any right above, go to vaigconsulting@gmail.com.