1. Introduction

As you use Airdrops Transport Limited, you entrust us with your personal data. We’re committed to keeping that trust to the highest standard possible. That starts with us helping you understand our privacy policy.

This notice hereby describes the personal data we collect from you, how they are used, shared and the choices available to you regarding this data. We recommend that you read our privacy policy which highlights key points about our privacy practices.

Date Created: June 12, 2020

Effective date: July 12, 2020

2.       Overview

i.       Scope

This notice applies to users of Airdrops Transport Limited’ services anywhere in Nigeria, including users of Airdrops Transport Limited apps, websites, features or other allied services.

This notice describes how Airdrops Transport Limited and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other allied services anywhere in Nigeria, unless covered by a separate privacy notice, such as the (name of any other privacy policy). This notice specifically applies to:

Riders: individuals who request or receive transportation, including those who receive transportation requested by another individual user using Airdrops Transport Limited App.

Drivers: individuals who provide, or submit applications to Airdrops Transport Limited to provide transportation individually or through partner transportation companies on the Airdrops Transport Limited App.

Delivery recipients: individuals who request or receive food, or other products and allied services to their customers using the Airdrops Transport Limited App.

Delivery partners: individuals who provide, or submit applications to Airdrops Transport Limited to provide delivery or other allied services to their customers using the Airdrops Transport Limited App.

This notice also governs Airdrops Transport Limited’ other collections of personal data in connection with their other services. For example, Airdrops Transport Limited may collect the contact information of individuals who use accounts owned by Airdrops Transport Limited for Business customers or of owners or employees of Airdrops Transport Limited fast food/restaurant partners or Airdrops Transport Limited may collect other personal data in connection with our mapping technology and features.

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

In addition to the above, kindly take note of the following:

For users in (name the country): (Name the body responsible for treating compliant and similar issues), is responsible for receiving complaints and reports presented by any data subjects who believe their rights have been impacted by a violation of the local data protection regulation.

For (name of country) users: Information regarding Airdrops Transport Limited’ privacy polices related to the (Name of country) (Name of law guiding data regulation).

For users in (name of country): Airdrops Transport Limited’ (Name of country) Representative is (Name, address, telephone: 02-3404-0003 and email

For users in (name of country): This policy also applies to the drivers and riders.

For riders without an Airdrops Transport Limited account: The personal data of a 3rd party who take trips arranged by the owner of an Airdrops Transport Limited account, such as when a rider takes a ride arranged by the owner of an Airdrops Transport Limited Health account (such as a hospital, healthcare provider and the likes), is processed in accordance with Airdrops Transport Limited’ contract with the owner of that account, and not as otherwise described in this policy. Such processing may include sharing of rider location data with the owner of that account. In the case of the above, the 3rd party may contact the owner of such account for more information.

Airdrops Transport Limited data policies are subject to applicable laws in the places in which we operate. This means that our privacy policies described in this notice are applicable in a particular country or region only if they are permitted under the laws of those countries. Please contact us here or through our addresses below with any questions regarding our privacy policies in a particular country or region of interest.

 

3.       Data controller and transfer

(Name of the data controller) is the data controller for the personal data collected in connection with use of Airdrops Transport Limited’ services in Nigeria.

Name of the data controller (Address of Airdrops Transport Limited) is the data controller for the personal data collected in connection with use of Airdrops Transport Limited services in Nigeria and (name of other countries where Airdrops Transport Limited operates).

(Name of date controller) is the data controller for the personal data collected in connection with use of Airdrops Transport Limited’ services anywhere else. We at Airdrops Transport Limited Transport Limited process personal data inside and outside of the (name of the country). The personal data of users outside (name of country) is transferred on the basis of mechanisms approved under the various applicable laws, such as the Nigeria Data Protection Regulation 2019 and any other legislation that might come into effect subsequently.

Questions, comments and complaints about Airdrops Transport Limited’ data policy can be submitted (Provide a link that can be clinked for these questions, comments and complaints on Airdrops Transport Limited’ Privacy Policy can be submitted)

  1.  Data collections and uses

A.       The data we collect

Airdrops Transport Limited collects:

Data provided by users on Airdrops Transport Limited platform, such as during account creation.

Data created during use of our services, such as location, app usage, and device data.

Data from other sources, such as Airdrops Transport Limited partners and 3rd parties that use Airdrops Transport Limited App and allied services

The following data is collected by or on behalf of Airdrops Transport Limited:

i.    Data as provided by users. This includes:

a.      User profile: We collect data when our users create or update their Airdrops Transport Limited accounts. These include their names, email addresses, phone numbers, login names and passwords, address, profile picture, payments or banking information (including those related to payment verification information), government identification documents when included in their Airdrops Transport Limited accounts, including driver’s license numbers and images from Airdrops Transport Limited drivers and other users of the Airdrops Transport Limited App who include such information, birth dates, signatures, and photos. These also include vehicle and insurance information of drivers and delivery partners, and user settings. The photos submitted by drivers and/or delivery partners may be used to verify their identities through facial recognition technologies or any other means. For additional information, please see the section titled “How we use personal data.”

b.      Background check and identity verification: At Airdrops Transport Limited, we collect background check and identity verification information for drivers and delivery partners to enable us serve our users better. This may include information such as driver history or criminal record or any other record (if permitted by law) and right to work. This information may be collected by an authorized vendor on our behalf. We also collect identity verification from Airdrops Transport Limited fast food/restaurant users.

c.     Demographic data: Airdrops Transport Limited collects demographic data about users, including through user surveys. In some countries, Airdrops Transport Limited may also receive demographic data about 3rd party users.

d.     User content: Airdrops Transport Limited collects the information users submit when a user contacts Airdrops Transport Limited customer support, provide ratings or compliments for other users or fast food/restaurant partners or otherwise contact Airdrops Transport Limited. This may include feedback, photographs or other recordings collected by users.

5.   Data created during use of Airdrops Transport Limited services. These include:

a.     Location data: Airdrops Transport Limited collects the precise or approximate location data from a user’s mobile device or any other device with which the user accesses Airdrops Transport Limited services. But this is only done if the user enabled his/her device to do so. For drivers and delivery partners, Airdrops Transport Limited collects this data when the Airdrops Transport Limited app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile devices. For riders, delivery recipients, and renters, Airdrops Transport Limited collects this data when the Airdrops Transport Limited app is running in the foreground. In some other regions (State the exceptions where need be), Airdrops Transport Limited may also collect this data when the Airdrops Transport Limited app is running in the background of the user’s mobile device. Riders, delivery recipients, and renters may use the Airdrops Transport Limited apps without enabling us to collect location data from their mobile devices. However, this may affect some functionality available in the Airdrops Transport Limited apps. For instance, a user who has not enabled location data collection will have to manually enter their addresses. In addition, the location data collected from a driver or rental device during a trip will be linked to the rider’s or renter’s account, even if they have not enabled location data to be collected from their devices, including for purposes of receipt generation, customer support, fraud detection, insurance, litigation etc.

b.      Transaction information: Airdrops Transport Limited collects transaction information related to the use of our services, including the type of services requested or provided, order details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if anyone uses another user’s promotion code, Airdrops Transport Limited may associate the name of the user of the promo code with the user whose promo code was used.

c.     Usage data: Airdrops Transport Limited collects data about how our users interact with our services. This includes data 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 services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our (Provide a link that can be clinked to see/read more on the cookie notice).

d.     Device data: Airdrops Transport Limited may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, mobile network data and other similar details.

e.     Communications data: Airdrops Transport Limited enables her users to communicate with each other and Airdrops Transport Limited through the use of Airdrops Transport Limited’ mobile apps and websites. For instance, Airdrops Transport Limited enables her drivers, riders and restaurants or delivery partners and delivery recipients, to call, text, or send other files to each other (without disclosing their telephone numbers to each other). To provide this service, Airdrops Transport Limited receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Airdrops Transport Limited may also use this data for customer support services (including but not limited to resolving disputes between our users), for safety and security purposes, to improve our products and services, and for analytics.

f.      Rental devices data: Airdrops Transport Limited collects data generated by her rental device when they’re in use. This includes the date and time of use, and the location, route, and distance traveled. Only to the extent permitted by law, the location data collected from the rental device during the trip will be linked to the renter’s account, even if they have not enabled Airdrops Transport Limited to collect location data from their mobile device.

g.       Data from other sources. This includes:

i.       User feedback, such as ratings, feedback, or compliments.

ii.     Users participating in our referral programs. For example, when a user refers another       person, we receive the referred person’s personal data from that user.

iii.     Airdrops Transport Limited account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes but not limited to owners of Airdrops Transport Limited for Business accounts.

iv.      Users or others providing information in connection with claims or disputes.

v.      Airdrops Transport Limited business partners through which users create or access their Airdrops Transport Limited account, such as payment providers, social media services, or apps or websites that use Airdrops Transport Limited’ APIs or whose APIs Airdrops Transport Limited uses.

vi.      Vendors who help Airdrops Transport Limited verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.

vii.       Insurance, vehicle, or financial services providers for drivers and/or delivery partners.

viii.    Partner transportation companies (for drivers or delivery partners who use our services through an account associated with such a company).

ix.        Publicly available sources.

x.         Marketing service providers.

Airdrops Transport Limited may combine the data collected from these sources with other data in its possession.

 

6. How we use personal data

Airdrops Transport Limited collects and uses data to enable reliable, efficient and convenient transportation, delivery, and other products and services. We also use the data we collect to do the following:

i.         To enhance the safety and security of our users and services.

ii.        For customer support and allied services.

iii.       For research and development.

iv.       To enable communications between users.

v.        To send marketing and non-marketing communications to users

vi.     In connection with legal proceedings and for compliance with relevant regulatory agencies.

Airdrops Transport Limited does not sell or share her users’ personal data with third parties for their direct marketing, except with users’ consent. Airdrops Transport Limited uses the data it collects for purpose of:

i.      Providing efficient services and developing user friendly features. At Airdrops Transport Limited, we use the data we collect to provide, personalize, maintain and improve on our products and services. This includes but not limited to using the data to:

a.      Create and update users’ accounts.

b.      Verify drivers’ and delivery partners’ identity, background history, and eligibility to work under relevant laws as applicable in various countries of operation.

c.        Enable a more efficient system for transportation, deliveries and other services.

d.       Offer, process, or facilitate payments for our services.

e.      Offer, obtain, provide, or facilitate insurance, vehicle, invoicing, or financing solutions in connection with our services.

f.       Track and share the progress of rides or deliveries.

g.      Enable features that allow users to share information with other people, such as when riders submit a compliment about a driver, when delivery recipients provide feedback for a fast food/restaurant or delivery partner, refer a friend to Airdrops Transport Limited, split fares, or share ETA and location with their contacts.

h.     Enable features to personalize users’ Airdrops Transport Limited accounts, such as creating bookmarks for favorite places and to enable quick access to previous destinations. Airdrops Transport Limited may, for example, present an Airdrops Transport Limited fast food user with personalized fast food/restaurant or food recommendations based on their prior orders. Please see the section of this notice titled “Choice and transparency” to learn how to object to this use of personal data.

i.      Enable Accessibility (Provide a link that can be clinked for this purpose) features that make it easier for users with disabilities to use our services, such as those that enable deaf or hard-of-hearing drivers to alert their riders of their disabilities, allow only text messages from riders, and enable receipt of flashing trip request notifications instead of sound notifications on their mobile device.

j.      Perform internal operations necessary to provide our a more efficient services, including to troubleshoot, software bugs and operational problems; to conduct data analysis, testing, and research and to monitor and analyze usage and activity trends.

7.       Safety and security. Airdrops Transport Limited uses personal data to help maintain the safety, security and integrity of our services and users. This includes:

i.       Screening riders, drivers, and delivery partners before enabling their use of our services and at subsequent intervals, including but not limited to reviews of background checks, where permitted by law, to help prevent use of our services by unsafe drivers and/or riders.

ii.      Using data from drivers’ or delivery partners’ devices to help identify unsafe driving  behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. We also use data from delivery partners’ devices to verify the type of vehicles they used to provide deliveries.

iii.       In certain regions, using information derived from driver’s license photos, and other photos submitted to Airdrops Transport Limited, for safety and security purposes. This includes Airdrops Transport Limited’ Real-Time ID Check feature, which prompts drivers and delivery partners to share a selfie before going online this is to ensure that the driver or delivery partner using the app matches the Airdrops Transport Limited’ account/ID we have on file. This is inclusive of comparing photographs that we have on file against photographs (i) of other users to prevent identity-borrowing, and (ii) from public databases to verify user identity.

iv.      Using device, location, profile and other data to prevent, detect and combat fraud or unsafe activities.

v.    Using user ratings and feedback to encourage compliance with our Community Guidelines (Provide a similar link that can be clinked on for the purposes of viewing Community Guidelines) and as grounds for deactivating drivers and delivery partners with low ratings or who otherwise violated such guidelines in certain countries.

8.      Customer support. Airdrops Transport Limited uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

i.         Direct questions to the appropriate customer support person for quick resolution of complaints or inquiries.

ii.        Investigate and address user concerns, inquiries, complaints and any issues whatsoever.

iii.        Monitor and improve our customer support responses and processes.

9.      Research and development: Airdrops Transport Limited may use the data collect for testing, research, analysis, product development and machine learning purposes with the aim to improve the users’ experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

10.      Enabling communications between users: For example, a driver may message or call a rider to confirm a pickup location, a rider may contact a driver to retrieve a lost item, or a fast food/restaurant or delivery partner may call a delivery recipient with information about their order.

11.     Marketing: Airdrops Transport Limited may use the data we collect to market our services to our users and not any other 3rd party. This includes sending users communications about Airdrops Transport Limited services, features, promotions, surveys, news, updates, events and the likes. Airdrops Transport Limited may also send communications to our users about products and services offered by Airdrops Transport Limited partners. For instance, if a user has placed an Airdrops Transport Limited Eats order, Airdrops Transport Limited may provide recommendations, promotions or ads about similar food offered by other Airdrops Transport Limited partners. Although Airdrops Transport Limited may send users communications about Airdrops Transport Limited partners’ products and services. Airdrops Transport Limited do not sell users’ personal data to or share it with such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.

Airdrops Transport Limited may use the data we collect to personalize the marketing communications (including advertisements) that we send to our users, including user location, past use of Airdrops Transport Limited’ services and user preferences and settings.

Airdrops Transport Limited may also send users communications regarding elections, ballots, referenda, and other political processes that relate to our services and which may affect the availability of our services in these users’ areas.

12.    Non-marketing communications: Airdrops Transport Limited may use the data we collect to generate and provide users with receipts, inform them of changes to our terms, services, or policies; or send other communications that are not for the purposes of marketing the services or products of Airdrops Transport Limited or its partners.

13.     Legal proceedings and requirements. Airdrops Transport Limited may use the personal data we collect to investigate or address claims or disputes relating to use of our services or as otherwise allowed by applicable law or laws in the various areas where our services are available or as requested by regulatory/security agencies/organization, government entities and any other official inquiries.

14.    Automated decision-making: Airdrops Transport Limited uses personal data to make automated decisions relating to use of our services which include the following:

i.     Enabling dynamic pricing (Provide a link that can be clinked on to view the dynamic pricing) in which the price of a ride or the delivery fee for Airdrops Transport Limited fast food/restaurant orders. It is determined based on constantly varying factors such as the estimated time, distance, the predicted route, estimated traffic and the number of riders and drivers using Airdrops Transport Limited at that given moment.

ii.     Matching available drivers and delivery partners to users requesting our services per time. Users can be matched based on availability, proximity and any other factors. Please see here (Provide a link that can be clinked on for information on how the matching process is done) for further information about our matching process.

iii.      Determining driver and delivery partner ratings and deactivating drivers, riders and delivery partners with low ratings. For more information about how ratings are determined and used, please see here  (Provide a link that can be clinked on for information on how the matching process is done) for riders ratings, here  (Provide a link that can be clinked on for information on how the rating process is done) for drivers ratings see here (Provide a link that can be clinked on for information on how the rating process is done) for delivery partner ratings. Kindly check the process of our drivers’ ratings as stated above for more information.

iv.       Deactivating users who are identified as having engaged in fraud or any other   activities that may otherwise considered harm to Airdrops Transport Limited, its users, partners and others. In some cases, such as when a user is willfully determined to be abusing Airdrops Transport Limited’ referral program despite several warnings, such behavior may result in automatic deactivation.

v.         Using driver location information and communications between riders and drivers, to identify cancellation fees earned or induced through fraud and any other similar means. For example, if we determine by using such information that a driver is delaying a rider’s pickup in order to induce a cancellation, Airdrop will not charge the rider a cancellation fee and will adjust the amounts paid to the driver to omit such an induced fee. To object to such adjustment, please contact Airdrops Transport Limited customer support services for resolution of the issue.

Click the links in this section for more information about these processes. To object to a deactivation resulting from these processes, please contact Airdrops Transport Limited customer support services.

 

15.       Cookies and third-party technologies: Airdrops Transport Limited 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 browsers or devices by websites, apps, online media and advertisements. Airdrops Transport Limited uses cookies and similar technologies for purposes such as:

i.        Authenticating users.

ii.       Remembering user’s preferences and settings.

iii.      Determining the popularity and acceptability of our content and services.

iv.      Delivering and measuring the effectiveness of advertising campaigns

v.    Analyzing site traffic, trends and generally understanding the online behaviors and interests of our users 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 the devices used by visitors to our websites, as well as when they visit other online sites and services.

Please see our Cookie Notice (Provide a link that can be clinked on for information on Airdrops Transport Limited’ cookie) for more information regarding the use of cookies and other technologies described in this section.

 

16.   Data sharing and disclosure: Some of our products, services and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries and partners for legal reasons or in connection with claims or disputes.

Airdrops Transport Limited may share the data collected with other users which includes sharing:

i.        Riders’ first name, rating, pickup and/or drop off locations with drivers.

ii.      Riders’ first name with other riders in a carpool trip. Riders in carpool trips may also see the drop off location of the other riders.

iii.    Delivery recipients’ first name, delivery addresses and order information with their delivery partner and fast food/restaurant. We may also share ratings and feedback or other information to the extent required by law with the fast food/restaurant partner and also delivery partner.

iv.    For drivers and delivery partners, we may share data with the rider(s), delivery recipient(s) and fast food/restaurant partner(s), including name, photo, vehicle make, model, color, license plate, vehicle photo, location (before and during trip) and average rating provided by users, total number of trips, length of use of the Airdrops Transport Limited app, contact information (depending upon applicable laws of various areas where we operate) and driver or delivery partner profile, including compliments and other feedback submitted by past users. We also provide riders and delivery recipients with receipts containing information such as a breakdown of amounts charged, driver or delivery partner’s first name, photo, route map and such other information required on invoices in the country or region where the driver or delivery partner operates.

v.       For those who participate in Airdrops Transport Limited’ referral program, we share certain personal data of referred users, such as trip count with the user who referred them to the extent relevant to determining the referral bonus.

vi.        At the user’s request inclusive of sharing data with:

a.     Other people at the user’s request. For example, Airdrops Transport Limited will share a user’s ETA and location with a friend when requested by that user or a user’s trip information when they split a fare with a friend.

b.     Airdrops Transport Limited business partners. For instance, if a user requests a service through a partnership or promotional offering made by a third party, Airdrops Transport Limited may share some of the data with the 3rd party. This may include for example, other services, platforms, apps or websites that are integrate with our APIs; vehicle suppliers or services; those with an API or service with which we are integrated or fast food/restaurant partners or other Airdrops Transport Limited’ business partners and their users in connection with promotions, contests, or specialized services.

vii.      With the general public. Questions or comments from users submitted through public forums such as Airdrops Transport Limited blogs and Airdrops Transport Limited social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user on this public forum.

viii.      With the Airdrops Transport Limited account owner. If a user requests transportation or places an order using an account owned by another user, we may share such order or trip information, including real-time location data with the owner of that account.

ix.    With Airdrops Transport Limited subsidiaries and affiliates. We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Airdrops Transport Limited processes and stores data in the (Location where data collected are stored) on behalf of its international subsidiaries and affiliates.

x.     With Airdrops Transport Limited service providers and business partners. Airdrops Transport Limited provides data to vendors, consultants, marketing partners, research firms and other service providers or business partners. These include:

a.        Payment processors and facilitators

b.     Background check and identity verification providers (drivers and delivery partners only)

c.       Cloud storage providers

d.     Marketing partners and marketing platform providers, including social media advertising services.

e.      Data analytics providers.

f.    Research partners, inclusive of those performing surveys or research projects in partnership with Airdrops Transport Limited or on Airdrops Transport Limited’ behalf.

g.      Vendors that assist Airdrops Transport Limited to enhance the safety and security of its apps and services generally.

h.         Consultants, lawyers, accountants, and other professional service providers.

i.          Fleet partners

j.         Insurance and financing partners

k.        Airports

l.        Fast food/restaurant partners and/or their point of sale providers and any other service providers.

m.       Vehicle solution vendors or third-party vehicle suppliers and/or repairers.

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

Airdrops Transport Limited may share users’ personal data if we believe it is required by applicable law, regulation, operating license or agreement, legal process or governmental and/or security request, or where the disclosure is otherwise appropriate due to safety or similar concerns. These include sharing personal data with law enforcement officials, public health officials, other 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 Airdrops Transport Limited’ 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. If a user uses another person’s credit card, Airdrops Transport Limited may be required by law to share the personal data of such a user, including trip or order information with the owner of that credit card.

Please see (Provide a link that can be clinked on for information on Airdrops Transport Limited Guidelines for Law Enforcement Authorities) for more information. This also includes sharing personal 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.

xi. With consent. Airdrops Transport Limited may share a user’s personal data other than as described in this policy if we notify the user and they consent to the sharing.

 

17.     Data retention and deletion: Airdrops Transport Limited retains user profile, transaction and other personal data for as long as a user maintains their Airdrops Transport Limited account. Airdrops Transport Limited may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal or any other regulatory requirements.

Airdrops Transport Limited retains user profile, transaction and other information for as long as a user maintains their Airdrops Transport Limited account. For drivers and delivery partners, Airdrops Transport Limited also retains vehicle and background check information (only to the extent permitted under the relevant laws applicable in our areas of operation) for as long as they maintain their Airdrops Transport Limited account.

Riders and delivery recipients may request deletion of their account at any time through the Settings > Privacy menu in the Airdrops Transport Limited app or through Airdrop (Provide a link that can be clinked on for Airdrops Transport Limited Help Desk/Center) Following such requests, Airdrops Transport Limited deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation or other legal requirements. For example, Airdrops Transport Limited retains location, device and usage data for these purposes for a minimum of 7 years, while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, research and development. In certain circumstances, Airdrops Transport Limited may be unable to delete a user’s account if there is an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Airdrops Transport Limited will delete the account as described above.

Airdrops Transport Limited may also retain certain information if necessary for purposes of safety, security and fraud prevention. For Instance, if Airdrops Transport Limited deactivates a user’s account because of unsafe behavior, fraud or security incidents, Airdrops Transport Limited may retain certain information about that account to prevent that user from opening a new Airdrops Transport Limited account in the future.

 

18.    Grounds for processing: Airdrops Transport Limited only collects and uses personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of Airdrops Transport Limited’ legitimate interests or those of other parties, to fulfill our legal obligations or based on consent.

We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located but generally include processing personal data:

To provide requested services and features

In order to provide our services, we must collect and use certain personal data. This personal data includes:

i.      User profile data, which we use to establish and maintain user accounts, verify user identity, communicate with users about their trips, orders, accounts and enable users to make payments or receive earnings (bonus earnings from referrals and others)

ii.     Background trip information, which is used to verify an applicant’s eligibility to be a driver or delivery partner.

iii.     Driver and delivery partner location data, which we use to track trips and assist with navigation

iv.    Usage data, which is necessary to maintain, optimize and enhance our services, including to determine incentives, connect riders and drivers and calculate costs of trips and driver earnings.

v.        Transaction information

vi.       Information relating to customer support

vii.    For purposes of the legitimate interests of Airdrops Transport Limited or other parties inclusive of government, regulator and security agencies.

This includes using personal data to maintain and enhance our users’ safety and security. We use personal data to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of our apps. We also use personal data to prevent matching of riders and drivers for whom there is higher risk of conflict because such a rider and driver have been the subject of prior complaints from other users inclusive of drivers too.

This also includes purposes such as combating fraud; improving our services, direct marketing, research and development and enforcing Airdrops Transport Limited’ Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims and to protect the rights and safety of the general public.

viii.    To fulfill Airdrops Transport Limited’ legal obligations. Airdrops Transport Limited is subject to laws and regulations in many cities and countries that require it to collect and retain data about our users’ trips and to provide copies of such data to the government or other relevant authorities. We collect and use personal data to comply with such laws where applicable.

Airdrops Transport Limited may also share data with law enforcement regarding criminal acts or threats to public safety or requests by third parties pursuant to legal processes. For more information about such sharing, please see Airdrops Transport Limited.

ix.     With consent: Airdrops Transport Limited may collect and use personal data based on the user’s consent. Airdrops Transport Limited may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

A user who has provided consent to a collection or use of his/her personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

19.      Choice and transparency: Airdrops Transport Limited enables users to access and control the data that Airdrops Transport Limited collects, including through:

i.          In-app settings

ii.         Device permissions

iii.        In-app ratings pages

iv.        Marketing opt-outs

Airdrops Transport Limited also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts or that Airdrops Transport Limited restrict its processing of user personal data.

a.      Privacy settings: The settings menu in the Airdrops Transport Limited app for riders gives them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from us. Information about these settings, how to set or change these settings and the effect of turning off these settings is described below.

i.         Location data: Airdrops Transport Limited uses riders’ device location services to make it easier for riders to get rides whenever they need one. Location data helps improve our services, including pickups, navigation and customer support services. Riders may enable or disallow Airdrops Transport Limited to collect location data from their mobile devices through the Settings > Privacy menu in the Airdrops Transport Limited app. Riders and delivery recipients can enable or disallow such collections through the settings on their mobile device.

ii.         Share Live Location (riders): Riders who have enabled Airdrops Transport Limited to collect location data from their mobile device may also enable us to share their location with their driver from the time the ride is requested to the start of the trip. This can help improve pickups for both drivers and riders, particularly in crowded areas. Riders may enable or disable this feature through the Settings > Privacy menu in the Airdrops Transport Limited app.

iii.         Emergency Data Sharing (riders): Riders who have enabled Airdrops Transport Limited to collect location data from their mobile device may also enable the Emergency Data Sharing feature that shares data with emergency police, fire and ambulance services. Such data includes approximate location at the time the emergency call was placed, the car’s make, model, color and license plate information, the rider’s name and phone number, pickup and drop off locations; and the driver’s name. Riders may enable or disable this feature through the Settings > Privacy menus or the Safety Center in the Airdrops Transport Limited app.

iv.        Notifications: account and trip updates:

Airdrops Transport Limited provides users with trip status notifications and updates related to activity on their account. These notifications are a necessary part of using the Airdrops Transport Limited app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Settings > Privacy menu in the Airdrops Transport Limited app.

v.     Notifications: discounts and news: Users may enable Airdrops Transport Limited to send push notifications about discounts and news from Airdrops Transport Limited. Push notifications may be enabled or disabled through the Settings > Privacy menu in the Airdrops Transport Limited app.

vi.       Communications from fast food/restaurant partners: Delivery recipients who have opted in to communications from fast food/restaurant partners may stop sharing their data with each fast food/restaurant partner in their Airdrops Transport Limited account settings.

vii. 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. iOS devices notify users the first time the Airdrops Transport Limited app requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices notify users of the permissions that the Airdrops Transport Limited app seeks before their first use of the app, and use of the app constitutes a grant of such permission.

viii.. Ratings look-up: After every trip, drivers and riders are able to rate each other on a scale from 1 to 5. 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.

This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for drivers and riders. Riders can see their average rating in the main menu of the Airdrops Transport Limited app. Drivers can see their average rating after tapping their profile photo in the Airdrops Transport Limited Driver app.

Delivery partners are also rated by delivery recipients and restaurant partners. Click here (Provide a link that can be clinked for these questions, comments and complaints can be submitted) for more information.

ix.         Marketing opt-outs

Users may opt out of receiving promotional emails from Airdrops Transport Limited here. (Provide a link that can be clinked for these questions, comments and complaints can be submitted) Users may also opt out of receiving emails and other messages from Airdrops Transport Limited by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for rides or information about their account.

x. User data requests. Airdrops Transport Limited provides users with a variety of ways to learn about, control, and submit questions and comments about handling of their data. To make a request, please go here. (Provide a link that can be clinked for the underlined services)

a.        Accessing data: Users can always ask for an explanation of the data we collect from them and how we use such data.

b.       Receiving data: Users can ask for a copy of data that Airdrops Transport Limited collects from them with their consent or as necessary to provide our services.

c.      Changing or updating data: Users can edit the name, phone number, email address, payment method and photo associated with their account through the Settings menu in the Airdrops Transport Limited’ apps or driver portal. They may also ask that Airdrop change or update their data, including if they believe such data is inaccurate or incomplete.

d.      Deleting data: Users may request deletion of their account at any time through the Settings > Privacy menus in the Airdrops Transport Limited app or through our website.

Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data or that we limit our use of their data. Airdrops Transport Limited may continue to process data after such objection or request to the extent required or permitted by the applicable law.

In addition, depending on their location, users may have the right to file a complaint relating to Airdrops Transport Limited handling of their personal data with the data protection authority in their country.

  1.       Updates to this notice

We may occasionally update this policy. Use of our services after an update constitutes consent to the updated notice to the extent permitted by the applicable laws.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Airdrops Transport Limited apps or through other means such as email. We encourage users to periodically review this policy for the latest information on our privacy practices. After such notice, use of our services by users will be understood as consent to the updates to the extent permitted by the applicable laws.