1. Who we are and what this policy covers
Lode is a logistics management platform built and operated by Load Factor Group (Pty) Ltd, registration number 2021/429913/07 ("LFG", "we", "us"). LFG is a hub-to-hub airfreight consolidator based in South Africa.
This policy explains how we collect, use, share and protect personal information through Lode, including the website and app at lode.mobi, our shipment tracking messages, and our billing and accounts functions. It applies to our customers and their staff, consignors and consignees, suppliers and airline partners, website visitors, and LFG's own users of Lode.
We are the responsible party under the Protection of Personal Information Act 4 of 2013 (POPIA). That means we decide why and how your personal information is processed, and we're accountable for doing it lawfully.
Where Lode holds information about a juristic person (a company), POPIA protects that too. In this policy, "personal information" covers both.
2. Our Information Officer
Our Information Officer is responsible for making sure Lode complies with POPIA and for handling your requests and complaints.
| Field | Details |
|---|---|
| Information Officer | Brandon Van Wyk |
| privacy@loadfactor.co.za | |
| Phone | +27 72 942 7588 |
| Physical address | 154 Forest Road, Benoni, 1509, South Africa |
| Postal address | 154 Forest Road, Benoni, 1509, South Africa |
3. What personal information we collect
We only collect what we need to move, track and bill freight. We don't collect special personal information (such as health, religion or biometric data) through Lode.
| Who | What we collect |
|---|---|
| Customers (couriers, freight forwarders) and their staff | Company name, registration and VAT numbers, contact names, job titles, email addresses, phone and WhatsApp numbers, physical and billing addresses |
| Consignors and consignees | Names, contact numbers, delivery and collection addresses, and shipment references linked to them |
| Shipments | Waybill and AWB numbers, piece counts, weights, dimensions, routes, flight details, status updates and delivery confirmations |
| WhatsApp groups | Names, phone numbers and messages of group members, where messages relate to shipment uplifts, delays and tracking |
| Billing and accounts | Invoices, quotes, payment history, account balances, credit terms, and bank details for refunds or supplier payments |
| Suppliers and airline partners | Contact names, email addresses, phone numbers and account references |
| Lode users | Name, email address, login credentials (handled by Firebase Authentication), user role, and an activity log of changes made in Lode |
| Website and app technical data | IP address, device and browser type, login times and error logs |
4. How we collect it
Most information comes directly from you or your company when you book a shipment, open an account, or contact us.
We also collect information:
- From our partners: airlines (such as SAA Cargo), ground handlers and road transport partners send us uplift confirmations, flight details and delivery updates.
- From WhatsApp: Lode reads messages in shipment groups we belong to (for example, supplier cargo groups) to pick up uplift confirmations and delays automatically. Lode also sends tracking updates to customer groups, and may record reactions to those messages as an acknowledgement. Lode only uses messages for shipment tracking. It doesn't read private chats that aren't related to our operations.
- Automatically: when you use lode.mobi, our systems log technical data needed to keep the platform secure and working.
If you give us information about someone else (for example a consignee), please make sure they know you're sharing it with us for delivery purposes.
5. Why we use it, and our lawful grounds
POPIA section 11 says we need a lawful reason for every use of personal information. Ours are:
| Purpose | Lawful ground (POPIA s11) |
|---|---|
| Booking, consolidating, moving and delivering freight | Needed to perform our contract with you (s11(1)(b)) |
| Sending tracking updates and delay alerts by WhatsApp or email | Contract (s11(1)(b)) and our legitimate interest in keeping customers informed (s11(1)(f)) |
| Reading WhatsApp shipment groups for uplift confirmations | Legitimate interest in accurate, timely tracking (s11(1)(f)) |
| Quoting, invoicing, collecting payment and keeping accounts | Contract (s11(1)(b)) and legal obligations, including tax and VAT (s11(1)(c)) |
| Meeting customs, aviation security and airline requirements | Legal obligation (s11(1)(c)) |
| Managing user accounts and keeping Lode secure | Legitimate interest (s11(1)(f)) |
| Improving Lode and reporting on volumes and service | Legitimate interest (s11(1)(f)), using aggregated data where possible |
| Telling existing customers about similar services | See section 11 (direct marketing) |
You can object to processing based on legitimate interest at any time (s11(3)). We'll stop unless the law allows us to continue.
6. Who we share it with
We never sell personal information. We share it only where needed to deliver our service or comply with the law.
| Recipient | Why |
|---|---|
| Airlines (such as SAA Cargo) and ground handlers | To book space, uplift and track your cargo |
| Road transport and delivery partners | To collect and deliver shipments |
| Google Cloud and Firebase (Google LLC) | Hosting, database, file storage and login services for Lode |
| Meta (WhatsApp) | Carrying tracking messages to and from WhatsApp groups |
| Our accountants and auditors | Bookkeeping, tax and statutory audits |
| Banks (such as ABSA and Standard Bank) | Processing payments and refunds |
| SARS, customs and other authorities | Where the law requires it |
| Professional advisers | Legal advice or enforcing our rights |
Service providers that process information for us are operators under POPIA. We require them, by written agreement or their binding terms, to keep the information confidential and secure and to use it only on our instructions (POPIA s20 and s21).
7. Information stored outside South Africa
Lode's servers and database are hosted by Google Cloud in Belgium (europe-west1), and Firebase and WhatsApp may process data in other countries. This means your personal information is transferred outside South Africa.
Under POPIA section 72, we only make these transfers where the recipient is bound by law, binding corporate rules or a binding agreement that gives protection substantially similar to POPIA. Google Cloud's EU hosting is subject to the EU General Data Protection Regulation (GDPR), and Google's data processing terms include contractual safeguards. Transfers are also needed to perform our contract with you (s72(1)(c)).
8. How we protect it, and what happens if something goes wrong
We take reasonable technical and organisational measures to protect personal information (POPIA s19), including:
- Encryption of data in transit (HTTPS) and at rest on Google Cloud
- Secure logins through Firebase Authentication, with access limited by user role
- A private code repository and controlled deployments
- Activity logs showing who changed what in Lode
- Regular backups of the Lode database
- Confidentiality obligations on LFG staff and operators
Security compromises. If we have reasonable grounds to believe your personal information has been accessed or acquired by someone unauthorised, we'll notify the Information Regulator and you as soon as reasonably possible (POPIA s22). Since 1 April 2025, all such reports to the Regulator must go through its eServices Portal. We'll tell you in writing what happened, what information was involved, what we're doing about it, and what you can do to protect yourself.
If a breach happens at one of our operators, they must tell us immediately so we can notify you.
9. How long we keep it
We keep personal information only as long as we need it or the law requires (POPIA s14). After that, we delete it, destroy it, or de-identify it so it can't be linked back to you.
| Record | How long |
|---|---|
| Invoices, payments and accounting records | At least 5 years (Tax Administration Act and VAT Act); 7 years for company records under the Companies Act |
| Shipment and waybill records | 2 years after the shipment, for claims and audits |
| WhatsApp tracking messages captured by Lode | 3 months, then deleted or de-identified |
| Customer and supplier contact details | For the life of the relationship, plus 2 years |
| Lode user accounts | Until the account is closed, plus 12 months for activity logs |
| Technical and error logs | 90 days |
We may keep information longer if needed for a legal claim, a regulator's request, or with your consent.
10. Your rights
Under POPIA you have the right to:
- Know whether we hold personal information about you, and ask for a copy (s23)
- Correct information that is inaccurate, out of date or incomplete (s24)
- Delete information we no longer have a lawful reason to keep (s24)
- Object to processing based on our legitimate interest, or to direct marketing (s11(3))
- Withdraw consent where we rely on it, without affecting what we did before
- Not be subject to decisions made purely by automated means that have legal effects on you (s71)
- Complain to the Information Regulator
To use any of these rights, email our Information Officer at privacy@loadfactor.co.za. We may ask you to verify your identity first. We'll respond within a reasonable time, and we won't charge you to confirm whether we hold your information. A prescribed fee may apply for copies of records, as set out in our PAIA Manual.
Complaints. Please contact us first so we can try to fix the problem. If you're still not happy, you can complain to the Information Regulator:
| Detail | Contact |
|---|---|
| Address | Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191 |
| Phone | 010 023 5200 / toll-free 0800 017 160 |
| Complaints email | POPIAComplaints@inforegulator.org.za |
| General enquiries | enquiries@inforegulator.org.za |
| Website | inforegulator.org.za |
11. Marketing, cookies and children
Direct marketing. We only send electronic marketing (email, SMS, WhatsApp) to existing customers about our own similar services, or to people who have opted in (POPIA s69). Every marketing message tells you how to opt out, and opting out is free. Shipment tracking updates are service messages, not marketing.
Cookies. lode.mobi uses essential cookies and similar technology to keep you logged in and keep the platform secure. We don't use advertising or tracking cookies. If we add analytics cookies, we'll update this policy and ask for your consent where needed.
Children. Lode is a business platform. It isn't meant for anyone under 18, and we don't knowingly collect children's personal information.
12. Changes to this policy
We'll update this policy when Lode or the law changes. The date at the top shows when it was last updated. For significant changes, we'll notify customers by email or in Lode before they take effect.
Questions? Contact our Information Officer at privacy@loadfactor.co.za.