Important Defined Terms

In this privacy policy, unless the context otherwise requires, the following words and expressions have the following meanings:

• Personal Information or Personal Data or Data: means any information relating to an identified or identifiable natural person.
• Platform: means the [Royal Rides Online Car Hire] solution that may be accessed through our Website including its sub-domains, our mobile or web application(s), or such other electronic means and which offers a secure transaction platform that guarantees both immediate payment and confirmed delivery of goods or Services.
• Service or Services: means the provision of certain online based car hire services, data, technology and analytics services, and any other business or non-business services that may be offered by us and our affiliates (each, a “Services”) non-electronically, through our Website or its sub-domains, and/or through any part of our Platform.
• Royal Rides: means the proprietary brand name for the Platform and associated with the Services which is owned solely by Royal Rides.
• Member or Members: means any natural or legal person who accesses or otherwise uses, whether they have registered or opened an account with us, the Services. A Member includes a Car Provider (as defined below) and a Car Hirer (as defined below).
• Website: refers to Royal Rides including all its sub-domains.

Who is affected by this privacy policy?

This privacy policy applies to anyone who uses our Services and anyone who creates an account on our Platform or otherwise uses our app, websites, or other services that we offer.

The privacy policy outlines how we collect and use data and specifically applies to:

• Car Providers: These are Members who supply Vehicles to other people through our Platform.
• Car Hirers: These are Members who hire or otherwise lease Vehicles from a Car Provider through our Platform.
• Any other person who applies to become a Member on our Platform.

Membership is open to all nationalities; however, membership benefits and our liability are restricted to individuals physically present in Kenya at the time of their use of our Services.

An Overview of Our Approach Towards Privacy and Data Protection

We strive to provide you with a fulfilling online car hire experience whether, you are a car provider or a car hirer. To enable us to deliver this promise to you, we will ask you to share with us some of your personal information (also referred to as, “personal data”) for your own benefit and convenience of use of our services, and for legal reasons too.

We appreciate the importance of your own personal information and we therefore undertake and have put in place measures to protect the data which you give us, beginning right from its collection, sharing and storage. The systems and processes we have put in place ensure that the personal data we process and store about you is accurate, minimised and can only be accessed by those that need it for the right reasons.

We are legally mandated by the Kenyan Data Protection Act, No. 24 of 2019, Laws of Kenya and in some cases, by other global data protection and privacy laws, to protect personal data that we collect from data subjects (meaning, the natural person in respect of whom the personal data relates).

We know that it is important to inform you how we use your personal data, for this reason, in this privacy policy, we describe how we will process and use any personal data about you and any other natural person whose personal data we collect.

Please read this privacy policy carefully to understand how and why we use your personal data.

This privacy policy is complemented by and should be read alongside our Terms and Conditions (the “Terms”) which are published on our website and application, and any other terms that we may make available to you from time to time.

Contacting Us

You can contact us by writing to us at [email] to submit any concerns, queries, requests or complaints regarding either this privacy policy or your personal information.

You can also contact the relevant Government office which regulates and enforces the protection of personal data in Kenya, or elsewhere in the world where relevant laws might apply to your personal information.

Updates to our Privacy Policy

We will review our privacy policy and make changes to it from time to time. Whenever we do this, we will publish the updated version on our website and app.

Consent

We are required by law to obtain your consent before, during and after receiving your personal data. Therefore, by accepting and accessing our Services, you accept and signal your acceptance of this privacy policy, and you unequivocally consent to us collecting, storing, retrieving, transmitting, altering, using, disclosing or otherwise “processing” your personal data.

on our website and associated sites such as our App and social media handles, which may not necessarily form part of our Services. Such functionalities include, signing us to receive news, insights, or marketing information, among others.

Please note that you have the option not to disclose some part or all of your personal data to us. In that case, you may or may not be able to access some of the Services and Platform fully or partially. However, in that case, we cannot guarantee that you will have an optimised experience. You have the unfettered right in that case, to stop using the Services or otherwise accessing the Platform including requesting us to delete any accounts or information you may have shared with us.

What data do we collect?

We may collect and use personal data of various kinds relating to you, about you, and/or from other sources, including third parties, business partners, our affiliates, or publicly available sources. In sum, we collect the following data:

• personal identification information which can be used to identify a person for example, name, email address, telephone number; and
• non-personal identification information which cannot on its own be used to identify a person.

How do we collect your data?

When you register on the Platform, when you access the Platform for example through our Website, when you create and update your Member profile, and when you carry out a transaction on the Platform, we and third parties working with us may collect the following information:

• name, email address, age, citizenship, home address, date of birth, telephone number(s), country of nationality, photographs of individuals, Vehicles and associated items, GPS data if a tracker is installed in your vehicle and we have access to the data emanating therefrom, details of your Vehicle if you are a Car Provider, details of any products or Services you provide, other personal data if you choose to register or access the Platform through third party sites such as Google, and have provided your personal information on those third party sites, credit/debit card information, information and documentation you provide to you when you communicate with us and use our Services, data about the devices used to access our Services, communication data such as sms and recordings of conversations, and information provided from third party sources that we partner with.

When you access our Website, we may use cookies to track, collect and aggregate information about your use of the Website. To understand more how we use our cookies, please refer to our cookies policy below.

As mentioned above, we may also receive your data indirectly from the following sources:

• on Websites and connected devices and third-party Websites, mobile and web applications and other online features and Services that share your data;
• our partners who may include, e-commerce trading platforms, and payment processors who may collect personal identification information and non-personal identification information from you; and

Please note that third parties who provide us with your information are governed by their own privacy policies and related data handling terms and strategies. Please check these before providing your information to them.

Why and how will we use your data?

We collect your data so that we can:

• provide you with access to our Platform;
• enhance the safety and security of our Members and our Services;
• deliver any ordered Services or otherwise process or implement your transactions;
• provide technical support to you and manage your account with us;
• to facilitate processing of payments;
• verify the information Members provide us with;
• to send you email, notifications and updates about our Services;
• carry our research and improve our Services;
• subject to your consent to receive marketing communication, for marketing purposes to offer promotional material from us and third party offers to Members;
• to monitor and analyse activities by Members on our Platform including, identifying trends on our Website and trends in our Members database. If we use this information, it will be in an aggregated and anonymous format. We may also share this information with third parties; and
• comply with our legal and regulatory and applicable legal obligations.

Whom do we share your data with?

With your consent, signified by you accepting this privacy policy, we may share your data with our partners or affiliated entities including our Services providers so that they can offer Services on our behalf, offer you their products and Services, and/or carry out any part of the Services delegated to them. If you are asked to submit personal data on any third-party websites, the collection of that data will not be covered by this privacy policy. Any third parties’ use of your personal data will be governed by their own privacy policies and may involve separate obligations under the applicable laws. We highly recommend you review these third parties’ privacy policies if they apply to you.

Third parties that may receive your information from us include:

• with other users in order to facilitate car hire bookings and execution of car hire transactions on our Platform;
• our payment services providers such as Safaricom’s M-Pesa and airtel money;
• any party that provides Services on our Platform;
• our identity verification partners, when we deem it necessary to verify your identity by asking for your personal information;
• our data storage and management Services providers;
• our customer relationship management Services providers which we may use to send personalised email communications amongst other uses;
• if we adopt a rating programme that involves collecting and moderating any reviews and ratings, our third-party review and ratings partner;
• any third party that may invite you to access our Platform and/or register as a Member;
• any of our group entity, for analytical use only and in a pseudonymised format;
• if all, or substantially all of our assets, are acquired by a third party subject to the acquirer continuing to use your data in accordance with the terms of this privacy policy, in which case the data we hold may be part of the transferred assets; and
• if we sell or acquire any business or assets, in which case we may disclose your information to the prospective seller or acquirer, provided that they continue to use your data in accordance with the terms of this privacy policy.

We may also disclose your information, with or without your consent, to any entity in respect of which we have a duty to disclose or share your information so as to comply with any legal obligation or in order to enforce or apply our Terms of Use and any other legal requirements; or to protect our rights, safety, property, our Members or others.

We use cookies to collect information relating to your use of our Website so that we can maintain and improve its functioning, and the quality of our Platform and our Services.

How do we store and secure your data?

Information you provide us with is stored in secure servers maintained by us and/or provided by our cloud storage services provider(s). In addition, this information may be stored or processed in countries outside Kenya, which may have different standards of data protection than in Kenya. Whereas we have taken extreme precaution in selecting these services provider(s), we cannot guarantee that they will always have secure storage capabilities. Further, it is your sole responsibility to make an informed decision to access or use our Services. We will, however, always be vigilant to ensure that any weakness identified in the storage of your information is quickly addressed to prevent any misuse of your information.

Please note that the transmission of information through the internet is not completely secure. Therefore, although we will take all reasonable measures to ensure the information you provide us with is secure and there is no unauthorised access, we cannot guarantee the security of your data. As such, any transmission you make will be at your own risk.

When you register as a Member, you will be asked to choose a password which you will use to access Member-related services. You are responsible for keeping this password confidential. Do not share this password with anyone.

Legal basis for processing your data

We have several legal justifications for collecting and using the personal data described in this privacy policy. The justifications are:

• where it is necessary to use your personal data under any contract with you;
• where you explicitly consent to the collection, storage, and use of your information for a particular purpose, including where you consent to receiving marketing and promotional communications relating to our Services or third parties’;
• where use of your personal data is necessary for us to pursue a legitimate interest or a legitimate interest of a third party, provided these interests subordinate to your own interests, legal rights or freedoms. Examples of such legitimate interests include:
  
  • to carry out day to day business, including the operation of our fully functioning Platform;
  • to ensure delivery of high level of customer Services through open and effective communication channels;
  • to build relationships with other third parties and Services providers;
  • to track and ensure fulfilment of contractual obligations;
  • to carry our market research and business development;
  • to invest, test and launch new products and Services that might be of benefit to our customers or prospective customers;
  • to consider your application, if you apply for a job-related role with us; and
  • in some case, we may have a legal obligation to collect and/or otherwise process personal data from you.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise the information or, if this is not possible for example in cases where your information has been stored in backup archives, then we will securely store your information and separate it from any further processing until we are in a position to delete it.

Marketing communications

We would like to send you information about its products and Services that we think you might like, as well as those of our partner companies.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop us from contacting you for marketing purposes or giving your data to our other members.

If you no longer wish to be contacted for marketing purposes, please write to us at the contacts provided in this Privacy Policy.

What are your data protection rights?

We would like to make sure you are fully aware of all your data protection rights. Under the Kenyan Data Protection Act, 2019 which came into force on 25th November 2019, every Member is entitled to the following:

• the right to be informed - you have the right to be informed of the use to which your personal information is to be put;
• the right to access - you have the right to request us or any other person or entity engaged by us to Process your personal information, to provide you with copies of your personal information. We may charge you a small fee for this Services;
• the right to correction - you have the right to request us to correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete. You can edit your personal details, including changing your preferences as to the material you wish to receive from us or our partners, through your profile page whenever you wish;
• the right to erasure - you have the right to request that we erase your personal data, under certain conditions such as where the information is false or misleading; and
• the right to object to processing - you have the right to object to our processing of your personal information, under certain conditions. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Children

We take serious precautions to protect the privacy of children as this is our legal obligation. We do not knowingly collect or maintain personal information from persons under 18 years of age, and no part of the Platform is directed to persons under 18 years of age. If you are under 18 years of age, then please do not use or access the Website at any time or in any manner. We will take appropriate steps to delete any personal information of persons less than 18 years of age.

Precise geolocation (Location Access) data

If you give us your consent, we can collect your precise geolocation (latitude and longitude) from your device. The collection of your geolocation occur when you are using our app when you aren’t using our app we will not be able to collect your location data. If you decline permission for us to collect your precise geolocation, we will not collect it, and our services that rely on precise geolocation may not be available to you. your precise geolocation (latitude and longitude) we collect we do not store it anywhere, we only use it to enable you know your location and calculate the distance between you and where the car is for your easy access and ocating the car.

Camera Permission access

Camera access is required for this Royal Rides app to unleash its full potential by allowing users to capture and upload their profile image for the purpose of verifying if they are the real people doing registration on the platform. This data is not shared with any other part whatsoever.

How we use cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our Website or Platform, we may collect information from you automatically through cookies or similar technology. We may also use cookies from third party websites, usually for our marketing and promotional efforts.

We use cookies in a range of ways to improve your experience on our Platform, including:

• to operate critical components of our Websites;
• to enhance your experience when you access or use our Websites and/or Services; and
• to understand how you use our Websites.

You can set your browser or otherwise opt not to accept cookies. However, in some instances, some of our Platform’s features may not function as a result or some functionalities may no longer be available to you.

Third Parties’ Privacy Policies

Again, our Platform may contain links to other online sites. Our privacy policy applies only to our Platform, so if you click on a link to another online site, you should read their privacy policy and terms of use.

Changes to our privacy policy

We keep this privacy policy under regular review and places any updates its Website. Please check back regularly to review any changes made since your last visit.

Governing law

This privacy policy shall be governed by and construed in accordance with the laws of the Republic of Kenya.

Resolution of disputes

Any dispute arising out of or in connection with this privacy policy that is not resolved by way of consultations between us and you concerning the interpretation, implementation, or alleged breach of this privacy policy, through negotiations within twenty-one (21) calendar days of the dispute or concern being brought to the attention of the other party, either party may refer the dispute to a court of competent jurisdiction in Kenya. The Parties agree that any court proceedings shall be conducted in English and that Kenyan courts shall have exclusive jurisdiction over any disputes arising under or in connection with this privacy policy.

How to contact us

If you have any questions about this privacy policy, the information we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us using the details set out below:

• Call us at: ,.
• Or write to us at: / / P.O. Box