The
following document outlines the privacy policy
of JGOO and any of its subsidiaries in connection with the use of its Mobile
Applications, website, services, content, products, (“together, The
Services”). Before using any of the
JGOOs, you are required to read, understand, and agree to these terms. By
clicking “accept” you agree that you have read, understood, and accepted
the terms and the privacy policy and you hereby grant consent to JGOO to
process your data.
1.
Introduction
When you
use JGOO’s services 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.
Last
Modified: Last modified on March 16, 2024
Effective
Date: March 16, 2024
2. Data
Collections and Uses
2.1
Scope
This
policy applies to users of JGOO’s Services in
Nigeria and other jurisdictions. It describes how JGOO and
its affiliates collect and use personal information to provide its Services.
This policy applies to all users of our apps, websites, features, or other
services anywhere in Nigeria and beyond unless covered by a separate privacy
policy. This policy specifically applies to:
1.
Riders: users who request or receive
transportation and delivery services
2.
Drivers: users who provide transportation
individually or through partner transportation companies and parcel delivery
services
3.
Delivery Recipients: users who request
deliveries of food or other items Delivery
4.
Partners: users who provide delivery services
This
policy also applies to those who provide
information to JGOO in connection with an application to use our Services, or
whose information JGOO otherwise receives in connection with its Services. All
those subject to this policy is referred to as “users” for purposes of
this policy. The practices described in this policy are subject to applicable
laws in the places in which we operate. This means that we only engage in the
practices described in this policy in a particular country or region if
permitted under the laws of those places. Please contact us if you have
questions about our practices.
2.2 Data
Controller
JGOO
provides the Services to users in Nigeria and
beyond. The data controller for the information you provide or that is
collected by JGOO or its affiliates is:
JGOO
Nigeria Limited
Address:Isreal Plaza, Plot 1077, Ademola Adetokumbo Crescent, Wuse 2, Abuja, Nigeria.
3
.
Data Protection Officers
Questions,
comments and complaints about JGOO's
data practices can be submitted to JGOO's data protection officer through jgo@jefssolutioltd.com
3. The
Information We Collect
3.1 JGOO
collects.
1.
Information that you provide to it such as when
you create your user account.
2.
Information created when you use our services,
such as location, usage and device information.
3.
Delivery Recipients: users who request
deliveries of food or other items
4.
Information from other sources, such as our
partners and third parties that use the company’s APIs.
3.1.1
JGOO collects:
a. User
profile: We collect information when you
create or update your user 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, driver’s license or passport if required by law, birth date,
photo and signature. This also includes the preferences and settings that you
enable for the Company account.
b.
Background check information: We may collect
background check information if you sign up to use JGOO’s Services as a driver
or delivery partner. This may include information such as your driver history.
This information may be collected by a vendor on JGOO’s behalf.
c.
Demographic data: We may collect demographic
information about you, including through user surveys. In some countries, we
may also receive demographic information about you from third parties.
d. User
Content: We may collect information that
you submit when you contact The Company customer support, provide ratings or
compliments for other users, or otherwise contact The Company.
3.1.2
Information created when you use our services.
a.
Location Information
Depending
on the 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 or delivery partner, JGOO
collects location information when the JGOO 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, JGOO collects location information when the JGOO
app is running in the foreground. In certain regions, JGOO also collects this
information when the JGOO 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 JGOO app
without enabling the JGOO app to collect their location information. However,
this may affect the functionality available on your app. For example, if you do
not enable JGOO 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 JGOO to collect your location information.
b.
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 travelled, and payment method. Additionally, if
someone uses your promotion code, we may associate your name with that person.
c.
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.
d.
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.
e.
Communications data
We
enable users to communicate with each other and
the company through the JGOO apps, websites, and other Services. For example,
we enable drivers and riders, and delivery partners and recipients, to call or
text each other. To provide this service, JGOO receives some information
regarding the calls or texts, including the date and time of the call/text, and
the content of the communications. JGOO 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.
3.1.3
Information from other sources lik e;
(a).
User feedback, such as ratings or compliments.
(b).
Users providing your information in connection
with referral programs.
(c).
Users requesting services for or on your
behalf.
(d).
Users or others providing information in
connection with claims or disputes.
(e).
JGOO’s business partners through which you
create or access your account, such as payment providers, social media
services, on-demand music services, or apps or websites who use JGOO’s APIs or
whose API, JGOO uses.
(f).
Insurance providers (if you are a driver or
delivery partner).
(g).
Financial services providers (if you are a
driver or delivery partner).
(h).
Partner transportation companies (if you are a
driver who uses our services through an account associated with such a company).
The owner of the company for business or the company family profile that you
use.
(i). Publicly available
sources.
(j).
Marketing service providers.
JGOO
may combine the information collected from
these sources with other information in its possession.
4.
How We Use Your Information
4.1
JGOO collects and uses the information to
enable reliable and convenient transportation, delivery and other products and
services. JGOO uses the information it collects for purposes including:
4.1.1
Providing services and features.
JGOO
uses the information we collect to provide,
personalize, maintain and improve our products and services. This includes
using the information to:
1.
Create and update your account.
2.
Verify your identity.
3.
Enable transportation, deliveries, and other
services. This includes automated processing of your information to enable
dynamic 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 the service at a
given moment.
4.
Process or facilitate payments for those
services.
5.
Offer, obtain, provide or facilitate insurance
or financing solutions in connection with our Services.
6. To
track the progress of your ride or delivery.
7.
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 JGOO, split fares, or share your ETA.
8.
Enable features to personalize your account,
such as creating bookmarks for your favourite places,
and enabling quick access to previous destinations.
9.
Perform internal operations necessary to provide
our services, including troubleshooting software bugs and operational problems,
conducting data analysis, testing, and research, and monitoring and analyze
usage and activity trends.
4.1.2
Safety and security
We use
your data to help maintain the safety,
security and integrity of our services and users. This includes, for example;
1.
Screening drivers and delivery partners prior to
enabling their use of our services and at subsequent intervals, including
thorough reviews of background checks, where permitted by law, to prevent the
use of our Services by unsafe drivers.
2.
Using information from drivers’ devices to
identify unsafe driving behaviour such as speeding or
harsh braking and acceleration, and to raise awareness among drivers regarding
such behaviours.
3.
Using the device, location, profile, usage and
other information to prevent, detect and combat fraud or unsafe activities.
4.
Using user ratings to encourage improvement by
affected users, and as grounds for deactivating users with ratings below a
certain minimum as may be required in their region. Calculation and
deactivation may be done through an automated decision-making process.
4.1.3
Customer support
JGOO
uses the information it collects (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;
1.
Direct your questions to the appropriate
customer support person.
2.
Investigate and address your concerns.
3.Monitor
and improve our customer support
responses.
4.1.4
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.
4.1.5
Communications among users
JGOO
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 delivery partner may call a delivery
recipient with information about their order.
4.1.6
Communications from us
JGOO
may use the information we collect to
communicate with you about products, services, promotions, studies, surveys,
news, updates and events. We may use the information to promote and process
contests and fulfill any related awards 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 user. We may also use the
information to inform you about elections, ballots, referenda and other policy
processes that relate to our Services.
4.1.7
Legal proceedings and requirements
We may
use the information we collect to
investigate or address claims or disputes relating to your use of our Services,
or as otherwise allowed by applicable law, or as requested by regulators,
government entities, and official inquiries.
5.
Cookies and Third-Party Technologies
JGOO
and its partners use cookies and other
identification technologies on our apps, websites, emails, and online ads for
purposes described in this policy. Cookies are small text files that are stored
on your browser or device by websites, apps, online media, and advertisements.
We use cookies and similar technologies for purposes such as:
1.
Authenticating users.
2.Remembering
user preferences and settings.
3.
Determining the popularity of content.
Delivering and measuring the effectiveness of advertising campaigns.
4.
Analyzing site traffic and trends, and generally
understanding the online behaviours and interests of
people who interact with our Services. We may also allow others to provide
audience measurement and analytics services for us, to serve advertisements on
our behalf across the Internet, and to track and report on the performance of
those advertisements. These entities may use cookies, web beacons, SDKs, and
other technologies to identify your device when you visit our site and use our
services, as well as when you visit other online sites and services.
6.
Information Sharing and Disclosure
6.1 We
may share the information we collect:
6.1.1
With other users
If you
are a driver or delivery partner, we may
share information with your rider(s) including name and photo; vehicle make,
license plate; location; average rating provided by riders; the total number of
trips; for how long you have been using the JGOO app; and contact information).
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 rider has submitted about you. The rider/delivery
recipient 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.
6.1.2
At your request
This
includes sharing your information with:
(a).
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.
(b).
Our business partners. For example, if you
requested a service through a partnership or promotional offering made by a
third party, we 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 we may partner with to deliver a
promotion, a contest or a specialized service.
(c).
With the public when you submit content to a
public forum. We love hearing from our users, including through public forums
such as our 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.
(d).
With the owner of the accounts that you may
use. If you use a profile associated with another party, we may share your trip
information with the owner of that profile. This occurs, for example, if you are
(a) a rider using your employer’s account for a business profile, or taking
trips arranged through the company’s central account; or (b) a rider who takes
a trip arranged by a friend or under a Family Profile.
6.1.3
With our affiliates
We
share information with our subsidiaries and
affiliates to help us provide our services or conduct data processing on our
behalf.
6.1.4
With our service providers and business
partners
We may
provide information to its vendors,
consultants, marketing partners, research firms, and other service providers or
business partners. This may include, for example:
1.
Payment processors and facilitators.
2.
Background check providers (drivers and delivery
partners only).
3.Cloud
storage providers.
4.
Marketing partners and marketing platform
providers.
5. Data
analytics providers.
6.
Research partners, including those performing
surveys or research projects in partnership with us or on our behalf.
7.
Vendors that assist us to enhance the safety and
security of our Services.
8.
Consultants, lawyers, accountants and other
professional service providers, Fleet partners.
9.
Insurance and financing partners.
10.
Vehicle solution vendors or third-party vehicle
suppliers.
6.1.5
For legal reasons or in the event of a dispute
We 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 our 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.
6.1.6
With your consent
We may
share your information other than as
described in this policy if we notify you and you consent to the sharing.
7.
Information Sharing and Disclosure
7.1
JGOO requires user profile information to
provide its services and retains such information for as long you maintain your
Company account.
7.2 We
retain 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 our Services, enable customer support, enhance the user experience or
other operational purposes, we will take steps to prevent access to or use of
such information for any purpose other than compliance with these requirements
or purposes of safety, security and fraud prevention and detection.
7.3 We
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 we shut down a user's
account because of unsafe behaviour or security
incidents, we may retain certain information about that account to prevent that
user from opening a new one in the future.
7.4 You
may request deletion of your account at any
time through the Privacy Settings in the JGOO app. Following such request, we
shall delete the information that it is not required to retain. In certain
circumstances, we 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, we will delete your account as described
above.
8.
Explanation and Copies of your Data
8.1
Explanation
You
have the right to request an explanation of the
information that JGOO has about you and how we use that information. You also
have the right to receive a copy of the information that we collect about you
is collected based on consent or because we require the information to provide
the services that you request.
8.2
Correction
If we
have information about you that you believe
is inaccurate, you have the right to request correction of your information.
8.3
Deletion
Users
may request deletion of their accounts at any
time. Users may request deletion through the Privacy Settings menu in the JGOO
app, or via our website. We may retain certain information about you as
required by law and for legitimate business purposes permitted by law.
Please
see the 'Information Retention &
Deletion' section above for more information regarding The Company's retention
and deletion practices.
8.4
Objections and complaints
Users
in Nigeria have the right to object to our
processing of personal data, including for marketing purposes based on
profiling and/or automated decision making, subject to our right to retain or
use the information as permitted by the law.
Users
in Nigeria also have the right to file a
complaint relating to our handling of their personal information with the
National Information Technology Development Agency (NITDA) Head Office at No
28, Port Harcourt Crescent, Off Gimbiya Street Phone:
+234 92 920 263 Mobile: +2348168401851, +2347052420189, web: nitda.gov.ng.
Users may also submit questions, comments, or complaints to the Company’s Data
Processing Officers.
9.
Grounds for Processing
(a).
The processing is necessary to provide the
services and features your request.
(b).
The processing is necessary to protect the
vital interests of our users or others.
(c).
The processing is necessary for our legitimate
interests.
(d).
The processing is necessary for the legitimate
interests of other persons or parties.
(e).
JGOO collects and uses personal information to
the extent necessary for the interests of other persons or the public. This
includes sharing information in connection with legal or insurance claims, to
protect the rights and safety of others.
10.
Consent
We
collect and use your information based on your
consent. You may revoke your consent at any time. If you revoke your consent,
you will not be able to use any service or feature that requires the collection
or use of the information we collected or used based on consent. JGOO relies on
consent in connection with data collections or uses that are necessary to
enhance the user experience, to enable optional services or features, or to
communicate with you. If you are a Nigerian user, the following types of data
collections or uses are done based on your consent.
Location
Information (Riders)
Share
Live Location (Riders)
Notifications:
Account and Trip Updates
Notifications:
Discounts and News
Accessibility
features
Please
see the Choice & Transparency section
below for further information about these data collections and uses, how to
opt-in or out of them, and the effect of opting out of these on your use of the
JGOO apps.
We may
also collect personal information about you
through voluntary surveys. Your responses to such surveys are collected based
on consent and will be deleted once no longer necessary for the purposes
collected.
11.
Choice and Transparency
11.1 We
provide means for you to see and control
the information that we collect including through:
11.1.1
Privacy Settings
The
Privacy Settings menu in the JGOO rider app
gives users the ability to set or update their location and contacts sharing
preferences, and their preferences for receiving mobile notifications from JGOO.
Information on these settings, how to set or change these settings, and the
effect of turning off these settings are described below.
(a).
Location Information
We use
rider's device location services to make it
easier to get a safe, reliable ride whenever you need one. Location data helps
improve our services, including pickups, navigation, and customer support. You
may enable/disable, or adjust, our collection of rider location information at
any time through the Privacy Settings menu in the JGOO app, or via the settings
on your mobile device. If you disable the device location services on your
device, your use of the JGOO app will be affected. For example, you will need
to manually enter your pick-up or drop-off locations. In addition, location
information will be collected from the driver during your trip and linked to
your account, even if you have not enabled The Company to collect your location
information.
(b).
Share Live Location (Riders)
We use
the rider's device location services to make
it easier to get a safe, reliable ride whenever you need one. Location data
helps improve our services, including pickups, navigation, and customer
support. You may enable/disable, or adjust, our collection of rider location
information at any time through the Privacy Settings menu in the Company app,
or via the settings on your mobile device. If you disable the device location
services on your device, your use of the JGOO app will be affected. For
example, you will need to manually enter your pick-up or drop-off locations. In
addition, location information will be collected from the driver during your
trip and linked to your account, even if you have not enabled The Company to
collect your location information.
(c).
Share Live Location (Riders)
If you
have enabled the device location services on
your mobile device, you may also enable us to share your location with your
driver from the time you request a ride to the start of your trip. This makes
it easier for your driver to pick you up. You may enable/disable location
sharing with your driver at any time through the Privacy Settings menu in the
Company app. You may use the Company app if you have not enabled location
sharing, but it may be more difficult for your driver to locate you.’
(d).
Notifications: Account and Trip Updates
We
provide users with trip status notifications and
updates related to their accounts. These notifications are a necessary part of
using the JGOO app and cannot be disabled. However, you may choose the method
by which you receive these notifications through the Privacy Settings menu in
the JGOO app.
(e).
Notifications: Discounts and News
You may
enable JGOO to send you to push
notifications about discounts and news us. You may enable/disable these
notifications at any time through the Privacy Settings menu in the JGOO app.
11.1.2
DEVICE PERMISSIONS
Most
mobile platforms (iOS,
Android, etc.) have defined certain types of device data that apps cannot
access without your consent and these platforms have different permission
systems for obtaining your consent. The iOS platform
will alert you the first time the JGOO 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 JGOO app seeks
before you first use the app, and your use of the app constitutes your consent.
12.
Updates to this Policy
We may
occasionally update this policy. If we make
significant changes, we will notify you of the changes through the JGOO apps or
by posting updates on our website, or through others means, such as email. To
the extent permitted under applicable law, by using our services after such
notice, you consent to our updates to this policy. We encourage you to
periodically review this policy for the latest information on our privacy
practices. We may also make prior versions of our privacy policies available
for review.
13.
Remedies and Limitation
Subject
to the provisions of the Nigeria Data
Protection Regulation, neither JGOO nor its affiliates, partners, suppliers, or
licensors be liable for any indirect, incidental, consequential, special or
exemplary damages arising out of or in connection with damages arising from the
breach of your privacy. Without limiting the generality of the foregoing, the
company's aggregate liability to you (whether under contract, tort, statute, or
otherwise) shall not exceed the amount of fifty dollars ($50.00). the foregoing
limitations will apply even if the above-stated remedy fails of its essential
purpose provided always that the complaint is brought within one month of the
occurrence of the said breach.