This privacy policy applies to you, the User of this Website, and SIMA express courier and logistics services (RC 1554528) , the owner and provider of the “NACOS” Website and App. The term “us” or “we” refers to NACOS a registered business founded in Nigeria. NACOS takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully.

1. Information we may collect from you
We may collect and process the following data about you:

• Name, e-mail, phone number, place of residence.
• Geolocation of drivers and driving routes.
• Information about vehicles (including registration number).
• Driver’s efficiency and ratings.
• Driver’s license, photo, profession and identity documents.
• Data about criminal convictions and offences. The financial data of providing transportation services is not considered as personal data, because drivers provide services in the course of economic and professional activities.

a. Information that you provide to us, including:
i. Information provided to us on the telephone or via employee application form or for our customers on our website including when you open an account with us, place orders, request rides or log on as an account holder. This will include your company or trading name (if any), your name or a contact name, address, telephone numbers, fax numbers, email address, bank details including account and BVN number. These are all details which we would require in order to invoice you for work carried out. If you use our online booking service we would store usernames and password(s) which you have set up in order that if required we could alter/delete users as per your instructions. Please do not divulge user logins and passwords to other users as they will be able to use the online booking on your account and then “Happiness may not be delivered”.
ii. We would also collect data from you should you need to make a complaint or report a problem with our website or operational/accounts queries.
iii. If you contact us we may keep a record of that correspondence and if that contact is via telephone your call may be recorded. The reasons for keeping these records are in order to deal with queries and for subsequent historical requests relating to the original requests.
iv. Personal details you choose to give when corresponding with us by phone or email.
v. Details of the transactions we carry out for you either via our website include details of proof of delivery.
(Please let us know if any of this information changes so we can keep our records up to date.)
b. Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.

2. Uses made of the information
We use information held about you in the following ways:

• We collect and process personal data for the purpose of connecting passengers with drivers to help them move around cities more efficiently.
• Geolocation and driving routes are processed to analyse the geographical area and give suggestions to the drivers. If you do not want to disclose your geolocation for passengers, you must close the Bolt app or indicate in the Bolt app that you are offline and currently are not providing transportation services.
• Driver’s license, profession, identity documents and criminal convictions and offences are processed to determine the compliance with the legal requirements and the suitability of pursuing a profession as a driver.
• Bolt app displays driver’s photo, name and vehicle details for the passengers to identify driver and vehicle.
• You will receive summaries from the Bolt Driver Portal, which will include your efficiency and ratings as a driver. Summary and ratings about driver are necessary to provide a reliable services for passengers.

a. To carry out our obligations arising from any contracts entered into between you and us.
b. To connect our clients to drivers to enable them locate and move around cities more efficiently.
c. Location data and phone number may be displayed to drivers for ease of communication. Location data is used only when NACOS is running.
d. To allow you to login or control the interactive features of our online services, when you choose to do so.
e. Where it is necessary for our legitimate interests, i.e. to operate our company and provide (including improving and personalizing) the products and services we offer.
f. To notify you about changes to our service or service effecting incidents.
g. Where we need to comply with a legal or regulatory obligation.

3. Disclosure of your information
We disclose personal data to third parties involved in the provision of the service such as hosting companies, tracking and positioner providers, logistics providers and IT providers.
Additionally, we will disclose your personal information to the relevant third party:
a. in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
b. if we are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; and
c. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our customers, our regulator, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and prevention of money laundering and credit risk reduction.

4. How secure is your data with us and where do we store your personal data.
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

5. Payment information
Customer credit/debit card payments and other payments you make either on website or via our offices will be processed via our third party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers. Please note that “NACOS” do not ourselves directly process or store the debit/credit Card data that you submit.

6. How long do we keep your data?
We will not keep your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 6 years. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

7. Access to your personal information
Under GDPR, you are entitled to request, view, amend, or delete the personal information that we hold. Email your requests to [email].

8. Your rights in respect of your personal data
Where processing of your personal data is based on consent, you can withdraw that consent at any time.
You have the following rights. You can exercise these rights at any time by contacting us at [email].
You have the right:
a. to ask us not to process your personal data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes;
b. to ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
c. to ask us not to process your personal data for scientific or historical research purposes, where relevant, unless the processing is necessary in the public interest;
d. to request from us access to personal information held about you. To submit your subject access request, you can contact us at [email];
e. to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
f. to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation or the data is children’s data and was collected in relation to an offer of information society services;
g. to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing); and
h. to ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract.
To exercise any of these rights or should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us at [email]

9. Changes to this Privacy Notice
We may change this policy from time to time and without notice, so for customers please make sure you check back frequently to see any updates or changes to our privacy policy. If we change our Policy we will publish those changes on this page. For our employees any change in the policy will be communicated via notices sent from the payroll department.

10. Contacts
If you have any questions about our collection, use or disclosure of your personal information or comments and requests please drop us an email at [email].
• You may not process the personal data of passengers without the permission of us. You may not contact any passenger or collect, record, store, grant access, use or cross-use the personal data provided by the passenger or accessible to you via the Bolt app for any reason other than for the purposes of fulfilling the transportation services.
• Your personal data is only disclosed to passengers, whose order has been accepted by you. Passengers will see driver’s name, vehicle, phone number, photo and geolocation data. Passengers also see driver’s personal data in the receipt.
• Depending on the location of the driver, the personal data may be disclosed to the Taxify OÜ local subsidiaries, representatives, affiliates, agents etc). Processing of personal data by will occur under the same conditions as established in this privacy policy.

Updated on 3rd April, 2019.

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