1. Who we are and what this covers
HaloRide Technologies Ltd is the data controller for personal data processed through the HaloRide apps and website. This notice applies to riders, drivers, applicants, guarantors, emergency contacts and website visitors. Contact our data protection officer at [email protected].
2. Data we collect
- Account data: name, phone number, email, photo, language and app settings.
- Identity data: selfies, liveness results, national ID and licence numbers and documents, guarantor details (drivers), and ID checks for night trips (riders).
- Location data: precise location while you use the rider app, and while drivers are online or on a trip; trip routes and timestamps.
- Trip and pricing data: pickup, destination, estimates shown, offers, counters, agreed and final fares.
- Payment data: payment method tokens and limited card details from our payment partners, wallet and earnings records, bank details for payouts.
- Safety data: SOS alerts, trip-watch alerts, reports and case records, and — where you enable it and consent — encrypted in-trip audio.
- Communications: in-app chat and masked call metadata; we do not record masked calls.
- Device and usage data: device model, operating system, app version, crash data and diagnostics.
- Data about you from others: ratings and reports from other users, KYC results from verification providers, and inspection results from partner garages.
3. How we use data and our legal bases
- To provide the Services — matching, pricing, navigation, payments and receipts (performance of a contract).
- To keep people safe — verification, trip monitoring, SOS response with our partner Sety, investigating reports (legitimate interests; vital interests in emergencies; legal obligation).
- To set fair prices — our Fair Price models use aggregated trip, traffic and demand data (legitimate interests).
- To prevent fraud and enforce our terms (legitimate interests; legal obligation).
- To communicate with you — service messages, and marketing only where you have opted in (contract; consent).
- To comply with law — tax, accounting and lawful requests from authorities (legal obligation).
Identity verification and in-trip audio recording rely on your consent where the law requires it. You can withdraw consent at any time, though some features may then be unavailable.
4. Automated decisions
We use automated systems to estimate fares, block offers below the fair floor, match identity documents to selfies, and flag trips for safety review. Decisions with a significant effect on you — such as refusing driver approval or deactivating an account — involve human review, and you can ask us to explain or reconsider them.
5. Who we share data with
- The other party to your trip: limited details such as first name, photo, rating, vehicle and plate, and live location during the trip. Phone numbers are masked.
- People you choose: contacts you share a trip with or who receive your SOS alert.
- Sety, our safety partner, to monitor trips and respond to alerts.
- Service providers: cloud hosting, maps, identity verification, payments, messaging and customer support, under contract.
- Authorities, where required by law or where necessary to protect someone’s life or safety (see our Law Enforcement Guidelines).
- In a business transfer such as a merger or acquisition, subject to this notice.
We do not sell personal data.
6. How long we keep data
- Account data: while your account is open, then up to 3 years for legal and safety purposes.
- Trip and location history: up to 7 years where required for tax and legal claims; detailed location points are minimised after 180 days.
- Identity documents: for the life of the account plus the period required by local law.
- In-trip audio: 30 days unless needed for an open safety case.
- Safety cases: up to 7 years.
7. Security
We encrypt data in transit and at rest, store identity documents and audio in restricted storage, apply role-based access with audit logs for our staff, and test our systems regularly. No system is perfectly secure; tell us at [email protected] if you suspect a problem.
8. International transfers
Our service providers may process data outside your country. Where required, we use safeguards such as standard contractual clauses and transfer impact assessments.
9. Your rights
Depending on where you live, you may have rights to access, correct, delete or port your data, to object to or restrict processing, to withdraw consent, and to complain to a regulator. You can exercise most rights in the app under Privacy, or by emailing [email protected]. We respond within the time the law requires.
10. Children
The Services are not directed to children. We do not knowingly collect data from children except where a responsible adult books a trip for them where permitted.
11. Changes
We will notify you in the app before material changes take effect.
Dispositions régionales
Nigeria (NDPA 2023)
We process personal data in accordance with the Nigeria Data Protection Act 2023 and the GAID. You may lodge a complaint with the Nigeria Data Protection Commission (NDPC).
European Economic Area and United Kingdom (GDPR)
Our legal bases are set out in section 3. You may complain to your local supervisory authority, or in the UK to the Information Commissioner’s Office. Where required, we will appoint an EU and UK representative before offering the Services in those regions.
United States (CCPA/CPRA and state laws)
California and other state residents may request to know, delete and correct personal information and to opt out of sale or sharing. We do not sell or share personal information for cross-context behavioural advertising. We will not discriminate against you for exercising your rights. Sensitive personal information (such as precise location and government ID) is used only for permitted purposes.
South Africa (POPIA)
You may complain to the Information Regulator of South Africa.
Kenya (Data Protection Act 2019)
You may complain to the Office of the Data Protection Commissioner.
Ghana (Data Protection Act 2012)
You may complain to the Data Protection Commission of Ghana.
Brazil (LGPD)
You may exercise your rights under Article 18 of the LGPD and complain to the ANPD.