Privacy Policy

We take privacy seriously

eDryv respects the privacy of all our customers and is fully committed to transparency in how we collect, use, and protect our customers' data.

 

eDryv requires your data to provide services, respond to your inquiries, and fulfil our legal obligations when you use our internet-enabled platforms ("platforms", which include social media channels). You are afforded several privacy and data protection rights under the law set out in this Privacy policy, and this right can be exercised at any time.

 

The purpose of this Privacy Policy is to describe eDryv's practices concerning the personal information that is collected, used or processed in connection with the operation of our platform. It also applies to information we may collect directly from you via phone or email communications to us, our Users or Members (collectively "Communications").  

 

We may also collect information which is posted on interactive or public comment sites such as eDryv's Facebook, Instagram, TikTok, and Twitter pages.

 

This Privacy policy is designed to help you understand the information we gather about you, what we use that information for, and with whom we share that information. Kindly read this policy to better understand our processes and practices regarding your data and how it will be treated.

 

TO WHOM IT MAY CONCERN

This policy applies to all persons who use eDryv's Transport Management System (TMS) and Advertising Management System (AMS) or online platforms, access eDryv';s e-hailing products, or interact with eDryv through any means or form connection with any legal, contractual or business purpose.

 

Essentially, this policy applies to you if you access, inquire into or use our products or services; visit our premises or use our website or mobile platform; and/or we perform any other activities for/with you in connection with our corporate commercial ride-hailing business.

 

It is important that you read this Privacy Notice together with any other policy document, privacy statement or fair processing policy we may provide at different points when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements all such other notices and policies and is not intended to override them.

 

In this Privacy Notice, we may sometimes collectively refer to the handling, collecting, protecting, and storing of personal data as the "processing" of personal data.

 

CHILDREN UNDER THE AGE OF 18

The eDryv Platform is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If you are under 18, do not use the Platform, and do not provide or post any information about yourself on or through any part of the Platform, make any purchases through the Website, or use any of the interactive or public comment features of the Platform.

 

If we learn that we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us as outlined in the "How to Contact Us" section.

 

OTHER WEBSITES

Kindly note that third-party websites that may be linked to this website/mobile application are not governed by this Privacy Notice. We encourage visitors to our platforms to review the privacy notice on these other websites before sharing personal data.

 

You acknowledge that you have read and understood the contents of this Privacy Notice when you access our platforms; use our services, content, features, technologies or functions offered on our website or digital platforms; or otherwise, interact with us.

 

HOW WE COLLECT YOUR PERSONAL DATA

When the user downloads TMS and AMS and submits an application for membership concerning the e-ride hailing services or the advertising services, we collect the following information:

• Identification and contact information: name, e-mail address, telephone number, and selfie (picture you take of yourself with your mobile phone when prompted to do so during the registration process to become a member)
• Payment information: payment information of a credit or debit card, including name of the holder, card number, expiration date, CVV or similar code, and billing postal code; and
• Login information: email and password.

We also collect data in situations where users may elect to provide information to us, an instance could be, when filling in a form, survey or questionnaire on our Platform, entering a contest or promotion sponsored by us, joining a product waitlist, or reporting a problem. In such cases, we retain copies of the correspondence (including email addresses) and record the nature of the communication and actions taken, to enable us to respond adequately and follow-up as needed.  

 

When a user calls us for assistance with our services, we may record your communications with our representatives to help us assist you and for quality assurance and employee training purposes.

 

We may also collect or obtain personal data from you as we observe or infer that information about you from the way you interact with us. In order to improve your experience when you use our platforms and to ensure that our platforms function effectively and securely, we (or our service providers) also use cookies (small text files stored in a user's browser or mobile device) and web beacons (small graphic images that are placed on a website and used to monitor a user's interaction with that website) which may collect personal data.

 

Additional information on how we use cookies and other tracking technologies and how you can control these can be found in our Cookies Notice.

 

BOOKING AND SUBSCRIPTION INFORMATION

With respect to eDryv Service, when a user requests a ride, on the App, or, with respect to the e-ride hailing service, when a user enters a drop-off destination, confirms a pick-up destination, or selects "Request Ride" within the App, we collect and record the booking information generated in connection with the booking. This "Booking Information" includes the time and date when the reservation was made and the location at which the eDryv service was reserved or the Vehicle was requested, and the location of the destination drop-off. (includes phone, user, and eDryv/Vehicle locations).

 

After a user submits an in-app registration, and, if applicable, the selfie of the passenger, we collect information about the use of eDryv, for a variety of reasons, including the security of the rider(s), security of the eDryv vehicle, information required by our insurance, fleet management, planning for support, and for monitoring the need for a battery charging and swap.

 

We may also share this information in a de-identified format to comply with applicable laws.  This information is collected both from the eDryv service itself and the rider's mobile phone. This "Ride Information" includes:

• Route used and geolocation, provided by a GPS or similar technology installed on the eDryv app;
• Trip information and driving data (e.g., ride distance, ride duration, ride speed, CCTV monitoring data, battery usage, etc.);
• Battery consumption;
• Traffic or parking tickets, photos, and similar reports of moving violations;
• Sensor data which includes the information received from the AI monitoring system
• Location and success of attempts to Start Ride, Cancel Ride and End Ride.

 

When a user schedules a ride we collect information about the user's reservation, ride, and the Vehicle in which the user travels for a variety of reasons, including the security of the user and other passengers, protection of the driver and vehicle, Pick-up location, drop-off location, any changes made by the user to pick-up or drop-off locations, route used and geolocation of the vehicle in which the user is riding, trip information and driving data for the vehicle in which the user is riding (e.g., ride duration, speed, battery consumption, etc.); and, interior and exterior dashcam video footage.

 

When a user uses the app, we may also collect geolocation of the mobile device, information about the functionality of the App that the User uses, the device unique ID (UID) or a sequence of characters that are unique to the User's device, and information regarding App opens.

 

OTHER FORMS OF DATA WE COLLECT

When a user provides contributions to be published or displayed ("posted") on public areas of our platform or our social media pages. Your Contributions are posted and transmitted to others at your own risk. Although you may be able to set certain privacy settings for such information, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other Users of the Platform with whom you may choose to share your Contributions. Therefore, we cannot and do not guarantee that your Contributions will not be viewed by unauthorized persons.

 

INFORMATION COLLECTED THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

As a user navigates through and interacts with our platform, we may use automatic data collection technologies to collect certain information about the User's computer, tablet, mobile device, browsing actions, and patterns, which may include information about the user's computer and internet connection, including IP address, device type, device identification number, operating system, browser type (such as Firefox, Safari, Internet Explorer), internet service provider (ISP), and carrier.

 

Where a user accesses our website, we can collect data from the referring site or exit pages, and broaden geographic location (country, city); and also access the details of the user's visits to our Platform, including traffic data, pages accessed, links clicked, and the time and date of this access.

 

We may use these technologies to collect information about a user's online activities over time and across third-party websites or other online services (behavioural tracking). The information we collect automatically may be connected to an identified person (i.e., a user) or an identifier (e.g., a cookie, or phone identifier).

 

We shall also collect usage data such as details of how you use any product or service provided by eDryv, details of how you like to use our website or the interactive products, tools, other technology or services we provide to, websites that you visited before and after visiting our website, details of how you like to interact with us, and similar information.

 

OTHER FORMS OF DATA COLLECTION

We may collect marketing and communications data such as users' preferences in receiving marketing data from us, our third parties and your communication preferences.

 

The types of personal data and "sensitive" or "special categories" of personal data that we collect will vary depending on the nature of the products and services that we provide to you and how you use our platforms. In some cases, the "sensitive" or "special categories" of personal data that we collect may include information collected as part of Know-Your-Customer (KYC) and Anti-Money Laundering (AML) checks that we must conduct before accepting you as a customer on our AMS platforms.

 

In some rare circumstances, we will also gather other "special categories" of personal data about you because you volunteer that data to us (for example, it appears in a copy of your resume/CV that you upload on our website) or for our legitimate interest (through CCTV for ensuring security in our vehicles or on our premises). In some other circumstances, the personal data we collect from you is needed to meet our legal or regulatory obligations or to provide you with the products or services requested by you.

 

HOW WE USE INFORMATION ABOUT USERS

We will use your personal data to provide you with products or services. As part of this, we may use your data in the course of correspondence relating to those products or services. Such correspondence may be with you, our customers, our service providers or public or judicial authorities with the necessary authorization. In many cases, we also use your personal data to conduct due diligence checks in advance of providing products or services to you and to process an application from you or a prospective client to receive products or services from us.

 

We use information that we collect about users or that we receive from Users or third parties:

• To present our Platform to each user;
• To provide each user with information, services or products that the user requested from us;
• To carry out our obligations and enforce our rights arising from any contracts entered between us and a user;
• To allow users to participate in interactive features on our platform;
• To contact a User about our goods and services that may be of interest to the User, unless the User has opted out of receiving such communications;
• For any other purpose with the User's prior consent; and
• In the aggregate we create statistics about the use of our Platform.

 

We generally use your personal data collected via our platforms to manage and improve our products and services (including by drawing up statistics on the usage of our platforms) to tailor the content of our platforms to provide you with a more personalised experience and draw your attention to information about products and services that may be of interest to you; to manage and respond to any request that you make through our platforms; to help us learn more about you and the products and services that you receive from eDryv and other products and services that you might be interested in receiving, and to correspond with you in relation to services you use or information you provide via our platforms. This correspondence is usually with you, our service providers, or public or judicial authorities with the necessary authorization.

 

THE LEGAL GROUNDS WE RELY ON FOR PROCESSING PERSONAL DATA

We will only use your personal data as allowed by the National Data Protection Act 2023, and other relevant regulatory authorities and documented by our data protection team.

 

We shall only use your personal data in any of the following circumstances:

• Where you consent to our use of your personal data when appropriate;
• Where it has become necessary to fulfil contractual obligations that we owe towards you or to take pre-contractual steps at your request;
• Where we need to comply with a legal obligation or requirement;
• Where it is necessary to achieve our legitimate business objectives;

 

To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so either because

• You have given us your explicit consent to process that information;
• The processing is necessary to enter into a binding contract with you or the performance of our obligations under applicable laws;
• The processing is necessary for reasons of substantial public interest based on applicable law (for example where we are required by law or regulatory requirements to process that information in order to ensure we meet our KYC and AML obligations); or
• The processing is necessary for the establishment, exercise or defence of legal claims;
• The processing is necessary for archiving, historical, statistical, or scientific research purposes.

 

Kindly note that where we use consent as the legal basis to process your personal data, you can withdraw your consent at any time by clicking the necessary link provided on our platforms, or by sending an email dataprotection@eDryv.com. , or by unsubscribing to our services.

 

TO WHOM WE DISCLOSE INFORMATION

It may be necessary for us to share your personal data with third parties. These third parties may include people or entities affiliated with our company, or external third parties such as our service providers, and business partners.

 

We may disclose information that we collect or receive from or about Users:

 

• To contractors, service providers, and other third parties we use to support our business and operation, such as to verify driver's license information, communicate with users, help enhance the security of our online services, distribute products purchased on our website, to process information for safety, business analytics, customer service, marketing, distribution of surveys, and fraud prevention and to process information for credit and debit card transactions;
• To social media providers when you access certain social media features through our Platform, we will share information with the social media provider (such as Facebook); that information will be governed by the social media provider's privacy policy;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, or as part of bankruptcy, or similar proceeding, in which such information is among the assets transferred;
• To third parties to market their products or services to you if you have not disabled the use of cookies by these parties through your browser. Data obtained through the short code program, as described in the SMS Terms, will not be shared with any third parties for their marketing reasons/purposes.  
• To comply with any court order, law, or legal process, including responding to any government, law enforcement or regulatory request;
• To enforce or apply our Legal Terms;
• To any competent law enforcement body, regulatory or government agency, court or other third party where we believe disclosure is necessary or appropriate as a matter of law or regulation, to exercise, establish or protect the rights, property, or safety of Company, its customers, or others; and
• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected activities; this includes exchanging information with other companies and organizations or with law enforcement for the purposes of fraud protection and credit risk reduction.

 

We require all third parties to respect the privacy ensure the security of your personal data, and treat it in accordance with the law. We do not allow our third-party service providers to use your data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.

 

TRANSFERRING USERS' DATA INTERNATIONALLY

We do not need to transfer users' data out of Nigeria. However, if a situation arises that needs the transfer of user's data outside Nigeria, we shall ensure that we are fully compliant with the General Data Protection Regulation, and in compliance with the transfer of user data as set out in the Nigeria Data Protection Regulation Framework 2020 or such other applicable regulations set out by relevant regulatory authorities.

 

We shall ensure that a similar degree of protection is afforded for it in the country to which it is transferred by using appropriate transfer mechanisms and ensuring that appropriate safeguards are in place. 

 

DATA INFORMATION RETENTION

We shall retain a user's information on eDryv's systems for as long as is necessary to fulfil the purpose for which it was collected or to comply with any legal, regulatory, tax, accounting, reporting requirements or internal policy requirements. We keep contact, payment and rider record information concerning a user as long as the user maintains an account with eDryv. We shall dispose of your data once you have closed your account with eDryv and it is considered that we no longer require your personal data in connection with the purpose for which it was collected and if disposing of such personal data would not expose us to any actions, sanctions or claims. 

 

We shall also dispose and retain the data collected in line with the compliance and rules set out in the National Data Protection Act 2023.

 

CHANGE OF PURPOSE OF USERS DATA

We shall only use your personal data for the purposes for which we collect it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

 

If for any reason we need to use your personal data for a purpose which an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so, and where such purpose can only be conducted based on your consent, we shall appropriately allow you to give or refuse your consent.

 

DATA SECURITY AND PROTECTION

We have implemented measures to secure personal information in our custody from accidental loss and unauthorized access, use, alteration, and disclosure.

 

Our payment transaction will be processed through the Interswitch payment gateway and will comply with the Interswitch privacy policy.

 

The user is also expected to adhere to proper safety and security measures for its information. Where you have chosen a password for access to our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in interactive or public comment areas of the Platform. The information you share in public areas may be viewed by any User of the Platform.

 

The transmission of information via the Internet is not completely secure. We shall implore our best methods to protect personal information. However, we cannot guarantee the security of personal information transmitted to our platform. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the platform.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

IT to mention some security measures put in place to protect the data

 

STORAGE OF YOUR DATA

All personal data you provide to us may be stored on our secure cloud-based data storage as well as on our premises, offsite-based locations and network-accessible storage which include external drives only for authorized users.

 

We will take all steps that are reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

 

YOUR RIGHTS AND HOW TO CONTACT US

As a user, you have the right to express your right on how we use your data under the National Data Protection Act 2023.

 

In particular, you have a right to object to the processing of your data for reasons such as sending you marketing communication; requesting a copy of personal data we hold about you; asking that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete; ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; and to withdraw consent to our processing of your personal data (to the extent such processing is based on consent).

 

To exercise any of your rights, or if you have any other questions about our use of your personal data, please e-mail dataprotection@folti.io. or write to EDryv Data Protection Officer at 11 Eletu Ogabi Street, Off Adeola Odeku Street, Victoria Island.

 

 

BREACH AND VIOLATION OF USERS DATA

In the event of a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your personal data, we shall within 48 (forty-eight) hours of knowing about such breach report the details of the breach to the appropriate government agency.

 

Where we ascertain that such breach is detrimental to your rights and freedoms in relation to your personal data, we shall within 5 (five) days of knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.

 

COOKIES NOTICE

We use cookies on our website to improve the user experience and secure our platforms. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.

 

If you do not wish to receive cookies, you only can reject non-essential cookies on your devices, or you can set your web browser to disable non-essential cookies following the simple procedures embedded in the browser. If you decide to disable cookies, you may find that certain aspects of our website do not work as expected.

 

Third parties may use technologies similar to those described above to collect information about Users' use of our Platform. The information they collect may be associated with other information, including information about Users' activities over time and across different websites and other online services. Third parties may use this information to provide each User with interest-based advertising.

 

We do not control these third parties' tracking technologies or how they may be used.  If you have any questions about an advertisement or other targeted content, you should contact the provider responsible directly.

 

THIRD-PARTY LINKS

Our Site and Services may contain links or embedded content (e.g., videos, images, articles, etc.) which may link to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

 

CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may be updated from time to time for any reason we deem appropriate, and in compliance with the relevant regulations. You should be notified of such updates. This Privacy Policy was last updated in xxxxx 2024.

 

HOW TO DELETE YOUR eDryv ACCOUNT

If you wish to delete your eDryv account and associated data, follow these steps in the eDryv app:

 

• Open the eDryv app on your device.
• Tap the Profile tab at the bottom right of the screen.
• Scroll down and select Delete Account at the bottom of the list.
• Follow the on-screen instructions to confirm your request.

 

What Happens When You Delete Your Account?

 

• Your profile, personal data, and trip history will be permanently deleted from our system and records.
• Where a rider has pending Green Coin balance, it will be forfeited.
• However, certain transaction records may be retained for legal or security purposes as required by law.

 

HOW TO CONTACT US

All feedback, comments, questions, complaints, requests, and other communications about this Privacy Policy and our privacy practices, should be directed as follows:

 

Mailing Address: EDryv Mobility Solutions, 11 Eletu Ogabi, Off Adeola Odeku Crescent, Victoria Island, Lagos State.

Attention: Legal & Compliance

Email Address: support@folti.io.

Phone: xxxxxxx