PRIVACY POLICY

Effective Date: 1ST August, 2019

When you use Sheeft, you trust us with your information. We are committed to keeping that trust. That starts with helping you understand our privacy practices. This policy describes the information we collect, how it is used and shared, and your choices regarding this information.


Scope
This policy applies to users of Sheeft's services anywhere in the world, including users of Sheeft's apps, websites, features or other services.

This policy describes how Sheeft and its affiliates collect and use personal information to provide our services. This policy applies to all users of our apps, websites, features or other services anywhere in the world, unless covered by a separate privacy policy. This policy specifically applies to:
• Riders: users who request or receive transportation
• Drivers: users who provide transportation individually or through partner transportation companies

This policy also applies to those who provide information to Sheeft in connection with an application to use our services, or whose information Sheeft otherwise receives in connection with its services. All those subject to this policy are referred to as “users” for purposes of this policy.

The Information We Collect
Sheeft collects:
• Information that you provide to Sheeft, such as when you create your Sheeft account.
• Information created when you use our services, such as location, usage and device information.
• Information from other sources, such as Sheeft partners and third parties that use Sheeft APIs.

The following information is collected by or on behalf of Sheeft:

1. Information you provide

This may include:

• User profile:
We collect information when you create or update your Sheeft account. This may include your name, email, phone number, login name and password, address, payment or banking information (including related payment verification information), government identification numbers such as Bank Verification Number (BVN), driver’s license or passport if required by law, birth date, photo and signature. This also includes vehicle or insurance information of drivers. This also includes the preferences and settings that you enable for your Sheeft account.

• Background check information:
We may collect background check information if you sign up to use Sheeft’s services as a driver. This may include information such as your driver history or criminal record (where permitted by law). This information may be collected by a vendor on Sheeft’s behalf.

• Demographic data:
We may collect demographic information about you, including through user surveys. We may also receive demographic information about you from third parties.

• User content:
We may collect information that you submit when you contact Sheeft customer support, provide ratings or compliments for other users, or otherwise contact Sheeft.

• Contact Information:
We may collect contact information that you submit when you decide to refer a friend from your contacts on your mobile device, to gain incentives from Sheeft. This information will be used to share referral code as well as share incentives to users' contacts uploaded from user's contacts to our platform. Please note that this information will never be disclosed or shared with anyone.

2. Information created when you use our services

This may include:

• Location Information
Depending on the Sheeft services that you use, and your app settings or device permissions, we may collect your precise or approximate location information as determined through data such as GPS, IP address and WiFi.

• If you are a driver, Sheeft collects location information when the Sheeft app is running in the foreground (app open and on-screen) or background (app open but not on screen) of your device.

• If you are a rider and have provided permission for the processing of location data, Sheeft collects location information when the Sheeft app is running in the foreground. Sometimes, Sheeft also collects this information when the Sheeft app is running in the background of your device if this collection is enabled through your app settings or device permissions.

• Riders and delivery recipients may use the Sheeft app without enabling Sheeft to collect their location information. However, this may affect the functionality available on your Sheeft app. For example, if you do not enable Sheeft to collect your location information, you will have to manually enter your pickup address. In addition, location information will be collected from the driver during your trip and linked to your account, even if you have not enabled Sheeft to collect your location information.

• Transaction Information
We collect transaction details related to your use of our services, including the type of services you requested or provided, your order details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.

• Usage information
We collect information about how you interact with our services. This includes information such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or service you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Policy.

• Device Information
We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

• Communications data
We enable users to communicate with each other and Sheeft through the Sheeft apps, websites, and other services. For example, we enable drivers and riders, to call or text each other. To provide this service, Sheeft receives some information regarding the calls or texts, including the date and time of the call/text, and the content of the communications. Sheeft may also use this information for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services and for analytics.

3. Information from other sources

These may include:
• User feedback, such as as ratings or compliments.
• Users providing your information in connection with referral programs.
• Users requesting services for or on your behalf.
• Users or others providing information in connection with claims or disputes.
• Sheeft business partners through which you create or access your Sheeft account, such as payment providers, social media services, on-demand music services, or apps or websites who use Sheeft’s APIs or whose API Sheeft uses (such as when you order a ride through Google Maps).
• Insurance providers (if you are a Third Party Partner).
• Financial services providers (if you are a driver).
• Partner transportation companies (if you are a driver who uses our services through an account associated with such a company).
• Publicly available sources.
• Marketing service providers.
Sheeft may combine the information collected from these sources with other information in its possession.

Sheeft collects and uses information to enable reliable and convenient transportation, delivery and other products and services. We also use the information we collect:
• To enhance the safety and security of our users and services
• For customer support
• For research and development
• To enable communications to or between users
• To provide promotions or contests
• In connection with legal proceedings
Sheeft does not sell or share your personal information to third parties for third party direct marketing purposes. Sheeft uses the information it collects for purposes including:

1. Providing services and features

Sheeft uses the information we collect to provide, personalize, maintain and improve our products and services. This includes using the information to:
• Create and update your account.
• Verify your identity.
• Enable transportation, deliveries, and other services. This includes automated processing of your information to enable efficient pricing, in which the price of a ride is determined based on constantly varying factors such as the estimated time and distance of the predicted route, estimated traffic, and the number of riders and drivers using Sheeft at a given moment.
• Process or facilitate payments for those services.
• Offer, obtain, provide or facilitate insurance or financing solutions in connection with our services.
• To track the progress of your ride or delivery.
• Enable features that allow you to share information with other people, such as when you submit a compliment about a driver, refer a friend to Sheeft, split fares, or share your ETA.
• Enable features to personalize your Sheeft account, such as creating bookmarks for your favorite places, and to enable quick access to previous destinations.
• Enable Accessibility features that make it easier for users with disabilities to use our services, such as those which enable deaf or hard-of-hearing drivers to alert their riders of their disabilities, allow only text messages from riders, and to receive flashing trip request notifications instead of sound notifications.
• Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.

2. Safety and security

We use your data to help maintain the safety, security and integrity of our services and users. This includes, for example:

• Screening drivers prior to enabling their use of our services and at subsequent intervals, including through reviews of background checks where permitted by law, to prevent use of our services by unsafe drivers.

• Using information from drivers’ devices to identify unsafe driving behavior such as speeding or harsh braking and acceleration, and to raise awareness among drivers regarding such behaviors.

• Using device, location, profile, usage and other information to prevent, detect, and combat fraud or unsafe activities. This includes processing of such information, in certain countries, to identify practices or patterns that indicate fraud or risk of safety incidents. This may also include information from third parties. In certain cases such incidents may lead to deactivation by means of an automated decision making process.

• Using user ratings to encourage improvement by affected users, and as grounds for deactivating users with ratings below a certain minimum. Calculation and deactivation may be done through an automated decision making process.

3. Customer support

Sheeft uses the information we collect (including recordings of customer support calls after notice to you and with your consent) to assist you when you contact our customer support services, including to:

• Direct your questions to the appropriate customer support person
• Investigate and address your concerns
• Monitor and improve our customer support responses

4. Research and development

We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

5. Communications among users

Sheeft uses the information we collect to enable communications between our users. For example, a driver may text or call a rider to confirm a pickup location, or a restaurant or delivery partner may call a delivery recipient with information about their order.

6. Communications from Sheeft

Sheeft may use the information we collect to communicate with you about products, services, promotions, studies, surveys, news, updates and events. Sheeft may also use the information to promote and serve you relevant ads and content about our services and those of our business partners. You may receive some of these communications based on your profile as a Sheeft user.

Sheeft may also use the information to inform you about elections, ballots, referenda and other political and policy processes that relate to our services.

7. Legal proceedings and requirements

We may use the information we collect to investigate or address claims or disputes relating to your use of Sheeft's services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

Some of Sheeft's products, services and features require that we share information with other users or at your request. We may also share your information with our affiliates, subsidiaries and business partners, for legal reasons or in connection with claims or disputes.

Sheeft may share the information we collect:

1. With other users

• For example, if you are a rider, we may share your first name, average rider rating given by drivers, and pickup and/or drop-off locations with drivers.

• If you are a driver, we may share information with your rider(s) including name and photo; vehicle make, model, color, license plate, and vehicle photo; location; average rating provided by riders; total number of trips; for how long you have been using the Sheeft app; and contact information (depending upon applicable laws). If you choose to complete a driver profile, we may also share any information associated with that profile, including information that you submit and compliments that past riders have submitted about you. The rider will also receive a receipt containing information such as a breakdown of amounts charged, your first name, photo, and a map of the route you took.

2. At your request

This includes sharing your information with:

• Other people at your request. For example, we may share your ETA and location with a friend at your request, or your trip information when you split a fare with a friend.

• Sheeft business partners. For example, if you requested a service through a partnership or promotional offering made by a third party, Sheeft may share your information with those third parties. This may include, for example, other apps or websites that integrate with our APIs, vehicle suppliers, or services, or those with an API or service with which we integrate, or business partners with whom Sheeft may partner with to deliver a promotion, a contest or a specialized service.

3. With the general public when you submit content to a public forum

We love hearing from our users -- including through public forums such as Sheeft blogs, social media, and certain features on our network. When you communicate with us through those channels, your communications may be viewable by the public.

4. With Sheeft subsidiaries and affiliates

We share information with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf..

5. With Sheeft service providers and business partners

Sheeft may provide information to its vendors, consultants, marketing partners, research firms, and other service providers or business partners. This may include, for example:

• Payment processors and facilitators.
• Background check providers (drivers only).
• Cloud storage providers.
• Marketing partners and marketing platform providers.
• Data analytics providers.
• Research partners, including those performing surveys or research projects in partnership with Sheeft or on Sheeft’s behalf.
• Vendors that assist Sheeft to enhance the safety and security of its apps.
• Consultants, lawyers, accountants and other professional service providers.
• Fleet partners.
• Insurance and financing partners.
• Airports.
• Restaurant partners.
• Vehicle solution vendors or third party vehicle suppliers.

7. For legal reasons or in the event of a dispute

Sheeft may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing your information with law enforcement officials, government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies, to protect Sheeft’s rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to your use of our services. If you use another person’s credit card, we may be required by law to share information with that credit card holder, including trip information.

This also includes sharing your information with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8. With your consent

Sheeft may share your information other than as described in this policy if we notify you and you consent to the sharing.

Sheeft retains user profile and other information for as long as you maintain your Sheeft account.

Sheeft retains transaction, location, usage and other information for 7 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. Sheeft thereafter deletes or anonymizes such information in accordance with applicable laws.

Users may request deletion of their accounts at any time. Following such request, Sheeft deletes the information that it is not required to retain, and restricts access to or use of any information it is required to retain.

Sheeft requires user profile information in order to provide its services, and retains such information for as long you maintain your Sheeft account.

Sheeft retains certain information, including transaction, location, device and usage information, for a minimum of 7 years in connection with regulatory, tax, insurance and other requirements in the places in which it operates. Once such information is no longer necessary to provide Sheeft's services, enable customer support, enhance the user experience or other operational purposes, Sheeft takes steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.

You may request deletion of your account at any time through the Privacy Settings in the Sheeft app, or via Sheeft's website (riders and delivery recipients here; drivers and delivery partners here).

Following such request, Sheeft deletes the information that it is not required to retain. In certain circumstances, Sheeft may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Sheeft will delete your account as described above.

Sheeft may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, if Sheeft shuts down a user's account because of unsafe behavior or security incidents, Sheeft may retain certain information about that account to prevent that user from opening a new Sheeft account in the future.

Sheeft provides means for you to see and control the information that Sheeft collects, including through: • in-app privacy settings
• device permissions
• in-app ratings pages
• marketing opt-outs
You may also request that Sheeft provide you with explanation, copies or correction of your data.

a. Privacy settings

The Privacy Settings menu in the Sheeft rider app gives users the ability to set or update their location and contacts sharing preferences, and their preferences for receiving mobile notifications from Sheeft. Information on these settings, how to set or change these settings, and the effect of turning off these settings are described below.

b. Device permissions

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Sheeft app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Sheeft app seeks before you first use the app, and your use of the app constitutes your consent.

c. Ratings Look-Up

After every trip, drivers and riders are able to rate each other, as well as give feedback on how the trip went. This two-way system holds everyone accountable for their behaviour. Accountability helps create a respectful, safe environment for both drivers and riders. Your rider rating is available in the main menu of the Sheeft rider app. Your driver rating is available in the Ratings tab of the Sheeft Partner app.

d. Explanations, Copies and Correction

You may request that Sheeft: • Provide a detailed explanation regarding the information Sheeft has collected about you and how it uses that information.
• Receive a copy of the information Sheeft has collected about you.
• Request correction of any inaccurate information that Sheeft has about you.
You can also edit the name, phone number and email address associated with your account through the Settings menu in Sheeft's apps. You can also look up your trips, orders and deliveries history in the Sheeft apps.

e. Marketing opt-outs

You may opt out of receiving promotional emails from Sheeft. You may also opt out of receiving emails and other messages from Sheeft by following the instructions in those messages. Please note that if you opt out, we may still send you non-promotional messages, such as receipts for your rides or information about your account.

Disputes relating to the processing of personal data and/or relating to Sheeft’s Privacy policy must first be submitted to Sheeft customer support by email - info@sheeft.com.ng or by contacting Sheeft’s Data Protection Officer by email - admin@sheeft.com.ng. If not resolved by any of these means, then shall be resolved according to the Dispute Resolution Clause of Sheeft’s Terms and Conditions of Use.