Nayo Privacy Notice

I. Introduction

When you use Nayo you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data (“data”) we collect how it’s used and shared and your choices regarding this data. We recommend that you read this information about our privacy practices which provides summaries of the data we collect and how we use it.

A. Scope

This notice applies to users of Nayo’s apps websites and other services. This notice describes how Nayo collects and uses data. This notice applies to all Nayo users in Cameroon and specifically applies to:

Riders: those who request or receive transportation and related services via their Nayo account.
Drivers: those who provide transportation to Riders individually via their Nayo account or through partner transportation companies.

All those subject to this notice are referred to as “users” in this notice.

For users in Cameroon: Nayo processes the data of users in Cameroon on the grounds that it is necessary to fulfill the terms of our agreements with those users or based on their consent.

II. Data collections and uses

A. The data we collect

Nayo collects data :

provided by users to Nayo
created during use of our services

Please see here for a summary of the data we collect and how we use it. Nayo collects the following data from these sources:

1. Data provided by users

This includes first and last name email phone number login name and password.
For drivers this also includes vehicle or insurance information contact information and evidence of health or fitness to provide services using Nayo apps.
Identity verification documents and photos: This includes government issued identification such as driver’s license or passports (which may contain identification photos and numbers date of birth and gender) and user-submitted photos such as selfies and profile pictures.
User content: We collect data (including chat logs and call recordings) when users contact Nayo customer support provide ratings or feedback for users or otherwise contact Nayo.

2. Data created during use of our services

Location data (driver): We collect precise and approximate location data from drivers’ mobile devices when the Nayo app is running in the foreground (app open and on-screen) or background (app open but not on-screen).
Location data (riders): We collect precise and/or approximate location information from riders’ mobile devices if they enable us to do so via their device settings.
Riders may use the Nayo apps without enabling collection of location data from their mobile devices. However, this may affect certain features in the Nayo apps. For example, a rider who has not enabled precise location data will have to manually enter their pickup address.
In addition, precise location data collected from a driver’s device during a trip is linked to the rider’s account, even if the rider has not enabled precise location data to be collected from their device. This data is used for purposes such as customer support, fraud detection, insurance, litigation and receipt generation.
Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided; trip or order details (such as date and time, requested pick-up and drop off addresses, distance traveled and payment transaction information (such as rider’s name and location, amount charged, and payment method). We also associate a user’s name with that of anyone who uses their promotion code
Communications data: We collect data regarding communications between users that are enabled through Nayo’s apps.

3. Data from other sources

Users participating in our referral programs. For example when a user refers another person we receive the referred person’s data from that user.
Users or others providing information in connection with claims or disputes.
Service providers who help us verify users’ identity background information detect fraud and screen users in connection with sanctions anti-money laundering or know-your-customer requirements.
Insurance vehicle or financial services providers for drivers
Partner transportation companies (for drivers who use our services through an account associated with such a company).
Publicly available sources.
Marketing partners and service providers including banks in connection with data resellers.
Law enforcement officials public health officials and other government authorities.

B. How we use personal data

Nayo uses data to enable reliable and convenient transportation services. We also use data:

To enhance the safety and security of our users and services
For customer support
To enable communications between users
For marketing and advertising
To send non-marketing communications to users
In connection with legal proceedings

Please see here for a summary of the data we collect and how we use it. Nayo uses the data we collect:

To provide our services. Nayo uses data to provide, personalize, maintain, and improve our services

This includes using data to:

Create accounts.
Enable transportation, such as:

Using location data to navigate rider pick-ups and order drop-offs, calculate Estimated Time of Arrival, and track the progress of rides.
Enabling features that involve data sharing, such as sharing driver first name and vehicle information with riders to facilitate pick-ups, or features that enable ETA sharing
Matching available drivers to users requesting services, including based on personal data such as location and proximity to other users, and user settings / preferences (such as preferred destinations), and non-personal data such as vehicle type requested.

Enabling accessibility features.

Calculating prices and fares, including using location data and trip details (such as requested pick-up and drop off addresses). We may also consider non- personal data or factors, including date and time, estimated distance and time, minimum base fares, tolls, taxes and fees, and surge pricing
Process payments, and enable payment.
Provide users with trip updates, generate receipts, and inform them of changes to our terms, services, or policies
Perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems
Nayo performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, are compatible with such uses, or are necessary for purposes of Nayo’s and its users’ legitimate interests.
2. Safety, fraud protection and security. We use data to help maintain the safety, security, and integrity of our services and users. This includes.
Verifying users' accounts, identity or compliance with safety requirements.
Using customer service information (including reports of safety incidents), transaction, and usage data to identify potentially unsafe drivers and driving. This can lead to drivers receiving messages encouraging safer driving, and/or account deactivation following human review.
using account, location, usage, transaction, and other data, including communications between users and metadata, to prevent, detect, and combat fraud, including by guest users
using reported incidents, user ratings*, and other feedback to encourage safe use of Nayo’s platform and compliance with our terms and as grounds for deactivating users with low ratings.
using driver data (such as past trip information and reported incident rates) and rider data (such as account information, cancellation and reported incident rates, current pick-up and drop-off location, past trip information, and ratings information) to predict and help avoid pairings of users that may result in increased risk of conflict.* We also avoid pairings where one user has previously given the other a low (e.g., 1 star) rating.
Using location, phone number, user name, vehicle details and other relevant information to provide live support from safety experts during trips. Nayo performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, and/or for purposes of the legitimate safety and security interests of Nayo, our users and members of the general public.
Customer support. We use the information we collect (which may include call recordings, chat logs, in-app text messages to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.
Nayo performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users or for purposes of Nayo’s legitimate interests in monitoring and improving its customer support services.
5. Enabling communications between users. For example, a driver may message or call a rider to confirm a pick-up location, a rider may call a driver to retrieve a lost item.
Nayo performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users.
6. Marketing and Advertising. Nayo uses data to market its services, and those of Nayo partners.
We specifically use account, approximate location, usage data, and trip history to provide ads and marketing communications that are personalized based on users’ observed or inferred location, interests and characteristics

This includes using this data to:

• Display Nayo advertising on third party apps or websites. We also provide ads that are personalized based on data about users’ current trip request, including time of request and services requested. For example, if a user requests a trip to a supermarket, we may display in-app ads for third party products that may be available at that supermarket.
• send emails, text messages, push notifications, and in-app messages or other communications marketing or advertising Nayo products, services, features, offers, promotions, news and events. For example, we may send push notifications suggesting a user’s favorite destinations, or in-app messages offering discounts.
We also measure the effectiveness of Nayo’s ads, and of third party ads displayed in Nayo’s apps or in connection with our services.
Nayo performs the above activities on the grounds that they are necessary for purposes of Nayo’s legitimate interests in informing users about Nayo services and features or those offered by Nayo partners.
7. Non-marketing communications. Nayo may use data to send surveys and other communications that are not for the purpose of marketing the services or products of Nayo or its partners. We may also send users communications regarding elections, ballots, referenda, and other political processes that relate to our services. For example, Nayo has notified users of ballot measures or pending law relating to Nayo’s services in those users’ areas.
8. Legal proceedings and requirements. We use data to investigate or address claims or disputes relating to use of Nayo’s services, to satisfy requirements under applicable laws, regulations, operating licenses or agreements, insurance policies, or pursuant to legal process or governmental request, including from law enforcement.
Nayo performs the above activities on the grounds that they are necessary for purposes of Nayo’s legitimate interests in investigating and responding to claims and disputes relating to use of Nayo’s services and features, and/or necessary for compliance with applicable legal requirements

C. Cookies and third-party technologies

Nayo and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice, and Nayo’s Cookie Notice. Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and ads. Nayo uses cookies and similar technologies for purposes such as:
• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
Analyzing site traffic and trends, and generally understanding the online behaviors 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 ads on our behalf across the internet or for other companies’ products and services on our apps, and to track and report on the performance of those ads.

D. Data sharing and disclosure

Some of Nayo’s services and features require that we share data with other users, or at users’ request or with their consent. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

Nayo may share data:

1. With other users
This includes sharing:

• Riders’ first name, rating, and pickup and/or dropoff locations with drivers.
• riders’ first name with other riders in a carpool trip. Riders in carpool trips may also see the other riders’ dropoff location.
• for drivers, we may share data with the rider(s), including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; period of time since they signed up to be a driver; contact information; and driver profile, including compliments and other feedback submitted by past users.
We also provide riders with receipts containing information such as a breakdown of amounts charged, driver first name, photo, and route map. We also include other information on those receipts if required by law.
• for those who participate in Nayo’s referral program, we share certain data of referred users, such as trip count, with the user who referred them as necessary to determine the referral bonus.

2. At users’ request or with users’ consentce

This includes sharing data with:

• Other people at a user’s request. For example, we share a user’s ETA and location with a friend when requested by that user.
• Emergency services. We may share users’ data with police, fire, and ambulance services in the event of an emergency or after certain incidents.
• Insurance companies. If a user has reported or submits a claim to an insurance company relating to Nayo’s services, Nayo will share certain data with that insurance company for the purpose of adjusting or handling the user’s insurance claim.
• General public. Questions or comments from users submitted through public forums such as Nayo blogs and Nayo social media pages may be viewable by the public, including any data included in the questions or comments submitted by a user.

3. With Nayo subsidiaries and affiliates

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

4. With Nayo service providers and business partners

These include the third parties, or categories of third parties, listed below. Where a third party is identified, please see their privacy notices for information regarding their collection and use of personal data.

• payment processors and facilitators, including MTN Momo
• customer support platform and service providers.
• Google, in connection with the use of Google Maps in Nayo’s apps.
• social media companies, including Facebook, Instagram and TikTok, in connection with Nayo’s use of their tools in Nayo’s apps and websites.
• marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness.
• research partners, including those performing surveys or research projects in partnership with Nayo or on Nayo’s behalf.
• service providers that assist Nayo to enhance the safety and security of Nayo apps and services.
• accountants, consultants, lawyers, and other professional service providers.
• insurance and financing partners.
• insurance companies, in connection with insurance claims made or reported by a user relating to Nayo’s services, and for the purpose of adjusting or handling the insurance claim.
• third-party vehicle suppliers, including fleet and rental partners.

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

Nayo may share users’ data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, insurance policy, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing data with law enforcement officials, public health officials, other government authorities, insurance companies, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Nayo’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to use of another person’s payment details, we may be required by law to share a user’s data, including trip or order information, with the owner of that payment account.

This also includes sharing data 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. With consent

Nayo may share a user’s data other than as described in this notice if we notify the user and they consent to the sharing.

E. Data retention and deletion

Nayo retains user data for as long as necessary for the purposes described above. Users may request account deletion through the Nayo customer service.

Nayo retains user data for as long as necessary for the purposes described above, which varies depending on data type, the category of user to whom the data relates, the purposes for which we collected the data, and whether the data must be retained after an account deletion request for the purposes described below.

For example, we retain data:

• for the life of users’ accounts if such data is necessary to provide our services. E.g., account data.
• for 5 years if necessary to comply with tax requirements. E.g., drivers’ trip location information.
• for defined periods as necessary for purposes of safety or fraud prevention. E.g., we retain incomplete driver applications for 1 year, and rejected driver applications for 5 years.
Users may request deletion of their account by contacting Nayo services via E-mail.

Following an account deletion request, we delete the user’s account and data, except as necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account (such as an outstanding credit or an unresolved claim or dispute). For drivers and delivery persons, this generally means that we retain certain of their data for as long as necessary for actual or potential tax, litigation, or insurance claims. For riders, we generally delete data within 90 days of an account deletion request, except where retention is necessary for the above reasons.

• Notifications: discounts and news

Users may enable Nayo to send push notifications about discounts and news from Nayo. Users may control whether they receive push notifications via Nayo’s settings
2. Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Users should check the available settings on their devices, or check with their provider.
3. In-app ratings pages

After every trip, drivers and riders are able to rate each other on a scale from 1 to 5 Stars. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, rider ratings are available to drivers from whom they request transportation, and driver ratings are available to their riders.

Riders can see their average rating in the main menu of the Nayo app.

Drivers can see their average rating after tapping ‘Ratings’ in the Nayo Driver app.

In addition, depending on their location, Users may have the right to file a complaint relating to Nayo’s handling of their data with the data protection authority in Cameroon

A. Data controllers and Data Protection

Nayo Technologies LLC. is controller of the data processed in connection with use of Nayo’s services, except where it is joint controller with other Nayo affiliates.

Nayo operates, and processes user data. We comply with applicable legal frameworks relating to the transfer of data.

Nayo is committed to protecting our users’ personal data regardless of where they are located or where, or by who, their personal data is processed. This includes implementing measures to protect users’ data, including:

• securing user data when in transit, including through encryption, and at rest.
• mandating company-wide training regarding privacy and data security.
• implementing internal policies and procedures to limit access to, and use of, users’ data.
• limiting government and law enforcement access to user data, except where required by law, there are imminent threats to safety, or users’ have consented to the access.

We may occasionally update this notice.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Nayo apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.

Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.