This is the privacy policy of Cabconect which describes our policies and procedure on collection of information, use and disclosure of such information in the course of using our services. This private policy also tells you about your privacy rights and how the law and data protection rules work to protects you and everyone. It tells you things like what information we use to provide you with our transportation services, how we use your information provided, how the information is kept safe.

We use your personal data to provide and improve the Services rendered by Cabconect. By agreeing to use our services, you subscribe to the collection and use of information in accordance with this privacy policy provided herein under seriatim.

1. Introduction/Interpretation and Definition of Relevant Terminologies

   For the purpose of this privacy policy the words herein are defined thus:

   1. In this privacy policy the words: You, He, She, Yours refers to drivers/dispatcher, passenger or client. And the words: We, Us, Ours refers to Cabconect Services.

   2. Cabconect is a limited liability company registered under Part B of Companies and Allied Matters Act, 2020. Cabconect is a subsidiary of the Beniko group of companies, a Nigerian group of companies incorporated under the Companies and Allied Matters Act, 2020. Unless stated herein otherwise, Cabconect is the controller of all that data and information provided on its platform.

      
      

   3. Services provided by Cabconect, a subsidiary of the Beniko group of companies includes: Provision of support services to clients and or passengers and drivers, in-app calls and messages between drivers and passengers and or clients who use the app, Maintenance of Cabconect app and Cabconect Platform, communications between drivers and passengers either in-app or by phone. To connect drivers or dispatchers to customers who need and request for transportation/ logistic services

   4. Cabconect Data Protection Officer: Cabconect has nominated your data protection officer; you can contact your data protection officer on…

      
      

2. The Categories of Data Processed by Cabconect.

   1. The categories of personal data processed by Cabconect, so that we can provide you with the best transportation and logistic services in our market place. The categories of personal data processed are herein under provided thus:

      1. Personal Contact Information: These are categories of information such as: name, phone number, email address, home address, office address depends on the services being offered and whether it’s to a natural or artificial person.

      2. Personal Profile Information: These are categories of information such as your saved address, profile picture, preferred language and means of communication and your drivers’ license details.

      3. Location of Operation: This is the category of information that has to do with the location of nearby scooters to you or a car for a ride, where you need a ride from and the progression of the journey and final destination of your trip.

      
      

      1. Personal Payment Information: This has to do with information regarding the means by which you pay and the amount charged for each ride or logistic service provided

      2. Limited identification data of the device: The limited identification data like the IP address of phone used by you, on which the Cabconect app has been installed.

      3. Data about the usage of the Transportation/Logistic services: These have to do with things like data about journey status, times and data about your conduct as assessed by drivers.

      4. Data on sensors for rental vehicles. This is the kind of data provided

         on the App which has to with data/information such as vehicle speed, engine power, driving style information (including sudden braking or skidding) and the total weight of objects and person(s) on the vehicle and changes in the weight.

      5. Additional information/Data that may be processed: In addition to above mentioned sources/data collected and processed, we may collect and receive your data from other sources, which include:

         • Drivers and third parties who provide information and content in connection to the service or in regard to possible claims and disputes; and

         • Users who participate in our referral campaigns. In that case we receive the referred person's information from that user.

      6. Take Notice that: A lack of (or inaccurate) personal data may prevent us from fulfilling our contract with you, or from doing something expected of us by the law or in accordance with our terms and conditions. It may also mean that we cannot operate your account. For instance in case of a passenger or client, we collect and process the personal data andsubmitted by you in the course of installing and using the Cabconect app; refusing to share geolocation data via the App means we cannot direct a driver to your location for pick- up, nor can we show you one of our own vehicles close to you for hire. We will also not be able to fulfill our obligations to you in other circumstances, i.e; if you refuse to undertake an identity verification check to ensure the integrity of your account, then Cabconect reserves the right to block such an account and the said account may be suspended or blocked to prevent fraud and or crime.

      
      

3. The Purpose of processing Data: Cabconect processes your personal data so we can provide you with one or more of our transportation/logistic services, the purpose of processing your Data are herein provided thus:

   • We connect you with a driver or passenger or rider as the case may

     be, help find you hire a vehicle or connect you with one who provides or needs logistic services

   • We also collect your data for security purposes and to the integrity of the market place which we provide.

   • Your data we process also help us to improve our products and services.

   • Personal data is generally processed in order to provide the services contracted through the Cabconect app with you. This means that to give you the service we promised you, and to meet our terms and conditions, we'll process your personal data to meet those obligations.

     
     

   • We collect and process personal data for the purpose of connecting passengers with drivers so you can be picked up and dropped off; or to show you where our nearest available hire vehicles are located, such as our cars. Instant messages directly in the Cabconect app is processed in order to provide service and customer support (including resolving disputes between driver and rider).

   • Your data collected and processed help us for analysis.

4. We also use your Data collected to Achieve the following:

   • We display geolocation data and the phone number of passengers to drivers when ride-hailing to enable efficient pick-up and drop-off, and make the journey and route transparent. This data is collected only when the Cabconect app is activated. The collection of geolocation data stops after closing the Cabconect app. In some countries drivers cannot see passengers' phone numbers; the driver sees an altogether different number which temporarily diverts to the passenger's phone number meaning the driver and passenger can still communicate.

   • We use geolocation data to make sure you get to your destination and resolve quality issues related to our services. We also need to know where you choose to drop off a hire vehicle so we can bill correctly, recharge batteries and maintain our fleet.

   • We use contact details to notify passengers and riders of updates to

     the Cabconect app so you can keep using our services. We also gather limited

   • We also use your data from the device that you use to connect you with our internet, mobile and telephone services, and to help keep your account safe through authentication and verification checks.

   • We collect data on the routes taken by our passengers and riders to analyze geographic coverage. This lets us do things like improve recommendations to the drivers about the most efficient routes, and helps us make sure that our hire-vehicles and drivers are in the most convenient locations for customers or passengers.

   • We obtain payment details to process passenger payment on behalf of drivers for ride-hailing. And we process payments for our own hire- vehicles with the use of your data.

   • We collect data about journey statuses, time and passenger ratings from driver feedback to encourage user safety, promote compliance with our terms and conditions, and make sure we're providing a quality and enjoyable service to everyone. Customer support data and correspondence is collected for the purposes of feedback, and resolving disputes and service quality issues.

   • Your name, phone number and email address will be used to communicate with you for things like letting you know that your journey has been completed, sending you trip confirmation slips and receipts, and letting you know about important service updates such as when bad weather suspends the hiring of ours scooters.

   • When using Cabconect rental vehicles, we process the data collected through the sensors of the rental vehicles for security purposes, to identify potentially dangerous driving to previous one. The corresponding notification has no serious consequences for the data subject - the goal is to ensure a safe driving style.

   • We may process all personal data about you for the establishment, exercise or defense of legal claims in case we need to defend against or give proof of claims for damages, or other claims submitted to us for investigation.

5. The legal basis on which we use your Personal Data/Information

   We are allowed to use personal information in the ways described above if we have a proper reason to do so. We always make sure we have a good reason for doing anything with your data.

6. Legitimate interest Ground: As a market place provider, we generally in other circumstances process your personal data relying on legitimate interest grounds, if we have concluded a legitimate interest assessment. Legitimate interests include our commercial interests in providing an innovative, personalized, safe and profitable service to our passengers and partners, unless those interests are overridden by other interests. We may process your personal data (excluding special categories of personal data) based on legitimate interest grounds for the following purposes:

   • We process your data on legitimate ground for the purpose of investigating and detecting fraudulent payments, malicious activities or unlawful activities, and/or safety or security incidents (depending on the nature of the investigation, all data categories are subject to be processed);

   • Maintaining the safety and security of our network and systems, and responding to suspected or actual criminal acts;

   • Making and reviewing recordings and logs: we may record messages and orders given both in our premises and using means of communication (email, phone calls, the Cabconect app, etc.) as well as information and other activities we have performed. We may also review audio recordings submitted to us using our safety toolkit trip audio recording feature (where such feature is available). If necessary, we use these recordings for investigations, proof and protection against claims and/or for quality assurance;

   • and implementing and maintaining features to ensure the security of our services; and

   • establishing, exercising or defending legal claims, including: (i) supporting our own internal investigations; (ii) the assignment of claims and the use of debt collecting agencies; and (iii) the use of legal advisors (depending on on the claim all data may be

   processed).

7. Resort to Alternative Legal Basis: Depending on the particular circumstances, we may, in the course of delivery of our services rely on alternative legal basis when it is more appropriate to do so, these includes:

   • In a situation where it is necessary to comply with a legal obligation such as for processing data when the law requires it, for instance if there is a valid legal request to disclose personal information to a third party such as a Court or regulatory authority;

   • Where it becomes compulsory in order to protect your vital interests, or those of others, for example in the event of an emergency or an imminent threat to life; another’s reputation or to protect the integrity of our company.

   • Where you have given us clear consent to do so for another specific purpose for which you have been fully informed. In countries where legitimate interest is not an available activities, Bolt instead relies on an alternative valid legal basis available as set out above.

8. Where Data collected can be processed for a New Purpose other than the Initial: In an instance where your personal data is processed for a new purpose other than that for which the personal data are originally collected and the processing is not based on the data subject's consent, we carefully assess the permissibility of such new processing. We will, in order to ascertain whether processing for a new purpose is compatible with the purpose for which the personal data are initially collected, take into account, inter alia:

   If there is any link between the purposes for which the personal data are collected and the purposes of the intended further processing;

   If the context in which the personal data are collected, in particular regarding the relationship between you and us;

   If the nature of the personal data, in particular whether special categories of personal data are processed or whether personal data related to criminal convictions and offences are processed;

   If the possible consequences of the intended further processing for you; and

   If there is existence of appropriate safeguards

9. Recipients of Data of Users of Our APP.

   We only work with trusted partners and authorities. And it is only those trusted partners and authorities that we share when there is a proper reason to do so. We limit sharing to only that which is required. We do not sell your personal information.

   • The personal data of the passenger is only disclosed to the ride- hailing drivers when they engage with a ride on in the Bolt app; in such a case, the driver will see the name, phone number (in some countries the number is masked), rating and geolocation data of the passenger.

   • After providing the transportation service, the name and the telephone number (in some countries the number is masked) of the ride-hailing passenger will remain visible to the driver for 48 hours. This is necessary for drivers to resolve any issues with the passenger like getting something special left in a driver car back to a passenger.

   • Feedback given by passengers regarding the quality of the ride - hailing service is anonymous. Your rating is private between you and Cabconect.

   • Depending on the location of the passenger, the personal data may be disclosed to the Cabconect group companies and partners (local subsidiaries, representatives, affiliates, agents etc). And such personal data processed by Cabconect group of companies and partners will occur under the same strict conditions as established in this privacy policy. You can read more on your country page.

   • In some circumstances we are legally obliged to share information with external recipients. For example, under a Court Order or where we cooperate with a data protection supervisory authority in handling complaints or investigations. We can also respond to requests, such as those from law enforcement agencies, when acting in good faith we belief that the response is required by law in that jurisdiction or furthers a public interest task, affects users in that jurisdiction, and is consistent with internationally recognized standards. In any scenario, we'll always satisfy ourselves that we have a lawful basis for sharing

   such Data.

10. Security and Access to Users’ Data

    • Any personal data collected in the course of providing our services is transferred to and stored in the data centers of Zone Media Ltd. and/or Amazon Web Services, Inc., which are located in the territories of Member States of the European Union. Only authorized employees of Cabconect group of companies and partners have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding transportation/logistic services).

    • Cabconect group companies and partners can access personal data to the extent necessary to provide customer support in the respective country.

    • For our research and scientific purposes, all data, like bulk geolocation data, is anonymized so you can never be identified from it.

11. The rights and control of our Users over Personal Data

    1. Because we want you to stay in control of your personal data, Cabconect provides you with controls through the app where you can view your personal information including your profile data and trip history. We also offer in-app settings like marketing options, and transparent cookie consent controls on our website.

    2. We allow you access your personal data via the Cabconect app. You have the right to ask us for copies of your personal information. There are some exemptions, such as when we have to balance the rights of others, which means you may not always receive all the information we process. Your right to rectification.

    3. We also allow you to access and update your personal data via the Cabconect app. You have the right to ask us to rectify information you think is otherwise inaccurate. You also have the right to ask us to complete information you think is incomplete

    4. Our application allows you the right to ask us to erase your personal information in certain circumstances.

    5. Our app gives you the right to ask us to restrict the processing of your information in certain circumstances. This means that your data can only be used for certain things, such as legal claims or to exercise legal rights.

    6. You have the rights and you object to processing of your personal data if we are processing your information on the basis of legitimate interests. You may object at any time to the processing of your personal data which involves automated processing or profiling which has a significant effect on your rights and to require human intervention. You also have the right to ask for an explanation regarding the logic behind an automated decision made by Cabconect.

    7. You have the right to ask that we transfer the information you gave us from one organization to another, or give it to you, in certain circumstances. This only applies to information you have given us.

    8. The retention period for the data about instant messages directly in the Cabconect app messages is 60 days, except cases where messages are related to a reported incidences, in which case we will store them for (5) five months.

       
       

12. Retention of Users’ Data

    1. Cabconect retains users’ data for only as long as may be necessary for the purposes described above pursuant to our general terms and conditions which you have subscribed to. This means that we retain different categories of data for different periods of time depending on the type of data, the transportation/logistic service irelates to, and the purposes for which we collected the data.

    2. We store your personal data as long as you have an active passenger’s/driver’s account. If your account is closed, personal data will be deleted (as specified in our data retention schedule and rules), unless such data is still required to meet any legal obligation, or for accounting, dispute resolution or fraud prevention purposes.

    3. All financial data regarding transportation/logistic services provided to passengers or drivers will be stored for two years after the last journey. Data required for other accounting purposes will be stored

       for Eight years after the last journey.

    4. Wherein there is a formal investigation of a criminal offence, fraud or false information having been provided, your data will be stored as long as necessary according to the internal, legal, and regulatory requirements.

    5. In an event that there is payment disputes, data will be retained until the claim is satisfied or as provided in the general terms and conditions, the expiry date of such claims whichever comes first.

    6. Your data generated from your Journey history and the data about usage of transportation/logistic services will be stored for two years, after which the data will be removed or subjected to anonymization.

    7. Data on sensors for rental vehicles is stored for 6 months only.

    8. Note that uninstalling Cabconect app in your device does not automatically delete personal data stored with us. It only when cabconect app has not been used for two years that we will reach out to you to confirm whether you wish to keep your account active for future use or otherwise, however in an event we do not get a reply within a reasonable time then, such an account will be closed and personal data will be deleted unless such data is required for any purpose aforementioned in this privacy Policy.

    9. The period to retain data generated from audio recording through our Audio Trip Recording Feature is:

       • It shall be 48 hours, while stored locally on the device of the person who generates the recording. The recordings are automatically deleted after 48 hours if a report to Cabconect's customer support team is not created and the recording is not explicitly shared with Cabconect's customer support team as part of the report.

       • Recordings shared and investigated by Cabconect will be automatically deleted after 7 days unless the retention period is manually extended for investigation/legal reasons.

13. Direct Advertisement/marketing of our Services

    • We may with the use of your Data provided do what we call direct marketing of our services or advertisement by sending direct marketing

      messages to your e-mail address and/or phone number when you have given us permission to do so, or under a soft opt-in basis. We may personalize direct marketing messages using information on how you use Cabconect’s services, such as how frequently you use the Cabconect app, and your transportation/logistic preferences.

    • If you no longer appreciate our direct marketing strategy or no longer wish to receive direct marketing messages, you can please opt- out by clicking the "Unsubscribe" link in the footer of one of our emails, or in the profile section of the Cabconect app.

    
    

14. Automated decision making

    Cabconect employs the use of automated decision making in case of issuing warnings and implementing ride hailing service suspension. Using automated decision making is less error-prone, more efficient and safer than using our employees. Data about your usage of the transportation/losgistic services (data about journey status incl. cancellations and no shows and data about your conduct as assessed by drivers) is considered when assessing the need for a warning or suspension. You can read more about the use of automated decision- making here. Ride hailing suspension will stay in force for 2 months, after which access to ride hailing service will be restored.

    
    

    Also to ensure effective delivery of our services to users of our App, we may use automated decision making in order to undertake fraud checks which are necessary for us to ensure the safety of our platform and the enforcement of our terms and conditions.

    We may also use automated decision making for complaint resolution purposes. We may use the complaints information you provide to our customer support team via our chat function. The information relating to your complaints may be used to generate an automated response which will then be evaluated by a human agent to make the final decision.

    
    

    In cases where we use automated processing or profiling that has a significant effect on your rights, you may have the right for human intervention and the right on grounds relating to your particular situation to

    object to the processing of personal data concerning you based on automated decisions/profiling as set out in section "Your rights and controls", and to express your point of view and contest the outcome of the decision by contacting our customer support in our app. You may also be entitled to an explanation regarding the logic of making an automated decision.

    
    

    Please note that certain exceptions and limitations may apply to your right to object to automated decision-making, as permitted by applicable laws and regulations. We will provide you with clear information regarding the implications of exercising your rights and the processes involved in objecting to automated decision-making.

    
    

15. Dispute resolution

    • Disputes relating to the processing of personal data are resolved through customer support in the first instance. You have the right to contact Cabconect Data Protection Officer as stated herein above via…

    • You have the right to lodge a complaint to the supervisory authority if you believe that we have processed your personal data unlawfully or have not complied with our legal obligations.

16. Finally

We hope you have found this privacy notice easy to understand.

Data protection laws are important. They strengthen rules and enhance your information rights. Many of these rules may appear complicated, but most are grounded in common sense. We take our responsibilities with your data seriously. Cabconect will continue to make changes to this privacy notice as part of our commitment to protecting your privacy and affording you even more transparency and effective service delivery.