Privacy Policy

WAKAJUGBE PRIVACY POLICY

Introduction

Wakajugbe Financial, Inc. (together with its subsidiaries and affiliates, “Wakajugbe,” “we,” “our,” and “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, disclose, and protect Personal Information you provide when you use:

  • Our website at wakajugbe.com, including any other web pages or materials that link to this Privacy Policy,
  • Our mobile application(s), and
  • Other services that reference or link to this Privacy Policy (collectively, the “Wakajugbe Services”).

It also explains how you can exercise your privacy rights under relevant data protection laws in your jurisdiction.

Capitalized terms not defined in this Privacy Policy have the meaning set forth in the Wakajugbe End User Terms of Use.

Note: This Privacy Policy applies only to Personal Information that Wakajugbe processes in its capacity as a “business” or similar term under applicable data protection laws. It does not cover uses of Personal Information by a third-party merchant or when Wakajugbe processes Personal Information on behalf of a merchant under a separate customer agreement.

If you follow links to external websites, please note that those sites have their own privacy practices and that we do not accept any responsibility or liability for their policies. We encourage you to review their respective privacy notices before providing any Personal Information.

1. Information We Collect

“Personal Information” means any information relating to an identified or identifiable individual. “Process” or “Processing” means any operation performed on Personal Information.

1.1. Information You Provide Directly

We collect Personal Information you provide directly to us, including (but not limited to):

  • Account information: Your name, phone number, email address, password/passcode, and payment method details (e.g., credit card or other payment instrument) when you create a Wakajugbe account or a Wakajugbe Merchant account.
  • Communication information: Any content of emails, phone calls (including call time/duration), or in-app chat/messages with our customer service or support teams.
  • Promotional, survey, or contest submissions: Information you choose to give us when participating in surveys, contests, sweepstakes, or promotions.

1.2. Information from Other Sources

  • Merchant purchase data: When you make a purchase from a Wakajugbe Merchant using your Wakajugbe account, we receive information about your transaction (order details, shipping updates, purchase frequency, applicable rewards/discounts, etc.).
  • Identity verification: With your permission, our third-party service providers may collect and verify identity information (e.g., driver’s license information, facial or biometric verification) to help prevent fraud. We only receive the verification status (pass/fail) and do not receive or store your biometric data.
  • Passkey or device-based verification: If you enable device-specific verification such as Face ID, we receive only the verification result (pass/fail), not the underlying biometric data.

1.3. Automatic Data Collection

We automatically collect certain information when you interact with the Wakajugbe Services, such as:

  • Technical identifiers: IP address, cookie identifiers, mobile advertising IDs, device information (e.g., IMEI, MAC address), browser type, operating system, mobile carrier, and language settings.
  • Usage details: Pages visited, date/time of visit, time spent on each page, links clicked, features used, and transaction activity.
  • Geolocation: Depending on your device settings, we may collect precise or approximate location information to enable location-based features (e.g., ride pickups, e-vehicle location for rentals).
  1. How We Use Your Information

Wakajugbe processes Personal Information for a variety of business purposes, which may include:

  1. Providing the Wakajugbe Services
  • Facilitate ride requests, match you with drivers, locate available vehicles, and process payments on behalf of Wakajugbe Merchants.
  • Verify identity and ensure secure transactions; detect and mitigate fraud or illegal activity.
  • Communicate essential transaction updates, such as order confirmations, shipping details, or ride statuses.
  • Customize your ride experience (e.g., recommended routes, personalized offers).
  1. Administrative Purposes
  • Respond to customer questions and requests for technical support.
  • Send important account-related notifications (e.g., account verification, policy updates, system maintenance).
  • Maintain internal quality control, auditing, and compliance processes.
  1. Marketing the Wakajugbe Services
  • Send promotional communications and tailor advertising or offers.
  • Conduct market research and develop new products/features.
  • Measure interest in our services and enhance user engagement.
  1. De-identified and Aggregated Data
  • Use aggregated or anonymized data (which cannot identify you) for analytics, research, or other lawful purposes.
  1. Cookies and Similar Technologies
  • We and our partners use cookies, pixel tags, and other tracking technologies (“Technologies”) to collect information automatically for analytics, marketing, and personalization.
  • You can configure your browser or device settings to block, delete, or disable these Technologies.
  1. Disclosing Your Information

We may disclose Personal Information to:

  1. Wakajugbe Merchants
  • To facilitate and support your transactions. Your information is also governed by the merchant’s own privacy policy.
  1. Service Providers
  • To third parties that help us operate and provide the Wakajugbe Services (e.g., payment processors, hosting providers, call centers, fraud prevention partners).
  1. Affiliates
  • To our subsidiaries, affiliates, or entities under common control for internal business purposes.
  1. Business Partners
  • With your consent or where we believe products or services may interest you.
  1. Advertising Partners
  • For interest-based or personalized advertising (e.g., targeted ads based on your activities).
  1. Legal/Regulatory or Security Reasons
  • Where required by law, court order, or to protect our rights, enforce contracts, protect users, or address illegal activities.
  1. Merger or Acquisition
  • If we undergo a merger, reorganization, sale of assets, or financing transaction, your Personal Information may be transferred as part of that deal.
  1. International Data Transfers
  • We may transfer and store your Personal Information in countries outside your own (including Nigeria, the United States, or other regions where we operate). In doing so, we take steps to ensure an adequate level of data protection in line with applicable laws.

4. How to Exercise Your Rights

Depending on your jurisdiction, you may have legal rights regarding your Personal Information, including:

  • Access: Request confirmation of whether we process your Personal Information and obtain a copy.
  • Rectification: Request correction of inaccurate or incomplete Personal Information.
  • Erasure: Request deletion of Personal Information, subject to certain legal exceptions.
  • Restrict/ Object: Ask us to limit our processing or object to certain processing activities, including automated decision-making.
  • Portability: Receive a copy of your Personal Information in a portable format or request that it be transferred to another service provider.
  • Withdraw Consent: Where consent is the basis of processing, you may withdraw at any time.
  • Unwanted Email: You can unsubscribe if unwanted email is received by using the unsubscribe link at the bottom of the email to opt out.

How to Submit a Request:

  • Contact us at info@wakajugbe.com or through the “Contact Us” section in the Wakajugbe app or website.
  • We will verify your identity before fulfilling the request to protect your privacy.

5. Data Retention

We retain Personal Information for as long as needed to:

  • Provide the Wakajugbe Services,
  • Fulfill the purposes for which it was collected,
  • Resolve disputes,
  • Conduct audits,
  • Pursue legitimate business interests, and
  • Comply with legal obligations.

Retention periods vary based on the nature of the information and legal or operational requirements. We regularly review and safely dispose of data no longer needed for these purposes.

6. Security of Your Information

We implement appropriate technical and organizational measures to protect the security of your Personal Information. However, no data transmission or storage system can be guaranteed to be 100% secure. We encourage you to take precautions when sharing information online. To the fullest extent permitted by applicable law, Wakajugbe disclaims liability for unauthorized disclosure.

  1. Children’s Privacy

Wakajugbe Services are not directed to children under 18, and we do not knowingly collect or solicit Personal Information from children under 16. If you become aware that a child has provided us with Personal Information without parental consent, contact us at info@wakajugbe.com. We will take steps to delete such information and (if applicable) terminate the child’s account.

8. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you as required by law (e.g., via email, app notification, or prominent notice on our site). Your continued use of the Wakajugbe Services after these changes become effective constitutes acceptance of the revised policy.

GLOBAL PRIVACY NOTICE FOR PASSENGERS AND RIDERS

This section specifically addresses privacy practices for passengers and riders who use Wakajugbe’s transportation marketplace services (“E-hailing Services”).

Controller and Contact

  • Data Controller: Wakajugbe Operations (a private limited company incorporated under the laws of the Federal Republic of Nigeria with registration number RC 7060334).
  • Registered Address: 3 Sir Emmanuel Jack Close, Off Tombia Extension, New G.R.A. Port Harcourt. Rivers State. Nigeria
  • Data Protection Officer (DPO): info@wakajugbe.com, or write to the DPO at the relevant city office address listed on our website (please mark the envelope “Data Protection Officer”).

1. Personal Data We Process

In order to provide our E-hailing Services, we process the following categories of personal data:

  • Contact Details: Name, phone number, email address, and potentially home address for certain features.
  • Profile Information: Profile picture, saved addresses (favorites), language preferences, driver’s license details (where relevant).
  • Geolocation: Location data for ride pickup, vehicle tracking, drop-off, and route optimization.
  • Payment Information: Payment card details, amounts charged, and transaction data.
  • Communications: In-app chat history, correspondence with customer service, phone call logs, feedback, and reviews.
  • Device/Technical Data: Limited device-identifying information (IP address, OS version), usage logs, and sensor data from vehicles (e.g., speed, acceleration, weight load for scooters/cars).

We may also receive information from third parties (e.g., drivers, affiliates) concerning billing or dispute resolution.

2. Purpose of the Processing

We use personal data to:

  1. Connect Passengers and Drivers
  • Match ride requests with available drivers, show nearby vehicles, facilitate route navigation and pickup/drop-off.
  1. Route Optimization and Trip Management
  • Track geolocation data for navigation, quality assurance, and fleet management.
  1. Transaction Fulfillment
  • Process payments for rides, update you about trip status, and issue receipts.
  1. Customer Support and Safety
  • Investigate concerns or disputes, resolve service quality issues, and maintain the safety and security of the platform (fraud detection, suspicious activity).
  1. Service Improvement
  • Analyze usage patterns, optimize driver deployment, enhance features, and recommend more efficient routes.
  1. Marketing and Communications
  • Send service updates, promotions, and news based on your preferences (where legally permissible).
  1. Legal Compliance and Claims
  • Investigate or defend against claims, satisfy lawful requests by public authorities, and enforce our agreements.
  1. Legal Basis

Depending on your jurisdiction, we rely on:

  • Performance of Contract: Processing is necessary to fulfill our contractual obligations to you (e.g., providing an e-hailing service).
  • Legitimate Interests: E.g., fraud detection, ensuring network security, preventing misuse, and pursuing commercial or research interests without overriding your fundamental rights and freedoms.
  • Legal Obligations: Compliance with laws, such as responding to valid legal requests or regulatory investigations.
  • Vital Interests: In emergencies or threats to life.
  • Consent: Where required (e.g., certain types of marketing).

4. Recipients

  • Drivers: For ride-hailing trips, drivers see your name, phone number (sometimes masked), and geolocation.
  • Group Companies & Partners: Local subsidiaries, affiliates, or agents may process personal data to help provide or support the services in your area.
  • Authorities: Where required by law or for safety/investigative reasons.
  • Dispute Resolution: Data may be shared with legal advisors, debt collectors, or other involved parties if a dispute arises.

5. Security and Access

  • Personal data is stored in secure data centers within territories recognized for adequate data protection, including member states of the African Union.
  • Access is restricted to authorized personnel strictly for legitimate purposes (e.g., customer support, dispute resolution).
  • For research purposes, aggregated or anonymized data is used so that individuals cannot be identified.

6. Your Rights and Controls

You can manage much of your data directly in the Wakajugbe app (e.g., editing your profile, reviewing trip history, adjusting notification preferences). Depending on your jurisdiction, you may also have:

  • Right to Access and Rectify
  • Right to Erasure
  • Right to Restrict or Object to processing
  • Right to Data Portability
  • Right to Withdraw Consent (for processing based on consent)

Contact us at info@wakajugbe.com or within the app to exercise these rights. We may verify your identity before actioning requests.

  1. Retention

We keep personal data only as long as necessary for:

  • Fulfilling the service and/or legal requirements,
  • Accounting, fraud prevention, or dispute resolution,
  • Where applicable law mandates a specific retention duration (e.g., financial or tax regulations).

Examples:

  • Ride Data & Financial Records: Typically stored for three years.
  • Accounting Data: Stored for up to seven years.
  • E-Vehicle Sensor Data: Stored for six months unless required for dispute resolution or legal claims.

8. Direct Marketing

With your permission or where allowed by law, we may send you direct marketing by email, SMS, or in-app messages. However, if you do not subscribe to it, you may unsubscribe by using the link in the footer of one of our emails, or opt-out using the Wakajugbe app.

9. Automated Decision-Making

We may use automated systems to:

  • Issue warnings or temporarily suspend service for policy violations, fraud detection, or suspicious activity.
  • Match you with drivers or vehicles based on availability, proximity, and demand.
  • Analyze complaints or rating data to improve service quality.

Where these automated decisions significantly affect you, you may request human intervention or challenge the decision by contacting customer support.

  1. Dispute Resolution
  • Initial Resolution: Please contact info@wakajugbe.com for all service-related issues.
  • Escalation: You may contact our Officer at info@wakajugbe.com if you have unresolved privacy concerns.
  • Regulatory Authorities: You have the right to lodge a complaint with the Nigerian Data Protection Authority or other competent data protection regulators if you believe we have infringed upon your rights.

11. Changes to This Notice

We will keep this privacy notice up to date as regulations evolve and our services expand. We encourage you to review this page periodically for the latest information on our privacy practices as part of Wakajugbe’s commitment to protecting your privacy and affording a transparent, safe and secure transport system.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise any rights:

  • Email: info@wakajugbe.com
  • Address: 3 Sir Emmanuel Jack Close, Off Tombia Extension, New G.R.A. Port Harcourt
  • In-App Support: Access “Help” or “Support” in your Wakajugbe app

We appreciate your trust in Wakajugbe, and we are committed to protecting your personal data in line with best industry practices and applicable data protection regulations.

Last Updated: January 2025

By using the Wakajugbe Services, you acknowledge that you have read and understood this Privacy Policy.