1.1.Decentralized Mobility Limited has access to all personal data and other data provided or generated in connection with your use of the Decentralized Mobility Limited Services. Decentralized Mobility Limited shall take all reasonable steps to ensure confidentiality of such data and comply with the Nigerian Data Protection Regulation 2019 and any other applicable Privacy Policies and laws whenever such data contains personal data. Except where otherwise provided by applicable Privacy Policies and laws, Decentralized Mobility Limited maintains access to such data also after the Agreement between you and Decentralized Mobility Limited is terminated. 

1.2.You have access to personal and other data provided by you or generated in connection with your use of Decentralized Mobility Limited Services to the extent that is made available to you under your Bloxmove Driver Account through the Bloxmove App. You shall take all reasonable steps to ensure confidentiality of such data and comply with applicable Privacy Policies and laws as long and to the extent that such data contains personal data of Passengers. 

1.3.Decentralized Mobility Limited processes the following Personal data: 

1.3.1. Name, e-mail, phone number, place of residence; 

1.3.2. Geolocation of drivers and driving routes; 

1.3.3. Information about vehicles (including registration number); 

1.3.4. Driver’s engagement and interactions on the Bloxmove App and driver ratings (including Driver Score); 

1.3.5. Driver’s license, photo, profession and identity documents; 

1.3.6. Data about criminal convictions and offences; 

1.3.7. Communication and correspondence records such as when the driver engages with our inapp chat (“Send a Message” option), or speak with our customer service agents, the date and time of the communication, and its content. 

Purpose of Processing Data 

1.4. We collect and process personal data for the purpose of connecting passengers with drivers to help them move around cities more efficiently: 

1.4.1. 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 Bloxmove app or indicate in the Bloxmove app that you are offline and currently are not providing E-hailing Services; 

1.4.2. 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; 

1.4.3. the Bloxmove app displays driver’s photo, name and vehicle details for the passengers to identify driver and vehicle; 

1.4.4. you will receive summaries from the Bloxmove Driver Portal, which will include your efficiency and ratings as a driver. Summary and ratings about driver are necessary to provide a reliable service for passengers; 

1.4.5. Personal data related to instant messages directly in the Bloxmove App is processed in order to provide service and customer support (including resolving disputes between driver and rider), for security purposes as well as to improve our products and services, and for analysis; 

1.4.6. We collect and use information about a driver’s engagement and interaction on the marketplace, and their ratings (including Driver Score) to encourage user safety, ensure drivers comply with the Driver Terms, and make sure we’re providing a quality and enjoyable service to everyone. Where the Driver Score drops below a specified threshold, we may issue the driver with a notification or request to, for example, digest some further guidance. If your score continues to drop, you may be temporarily suspended from accessing the Bloxmove App. You may appeal any decision to suspend your account. For further information on how to appeal a decision to suspend your account, please see our FAQ on Driver Score here. 

Legal basis for Data Processing 

1.5.Personal data is processed for the performance of the contract concluded with the driver. The prerequisite for the use of the Decentralized Mobility Limited services is the processing of driver’s identification and geolocation data. Personal data may be processed on the ground of legitimate interest, including for the purpose of investigating and detecting fraudulent payments. Data regarding the criminal convictions and offences is processed for compliance with a legal obligation. 

Recipients

 1.6.Your name and photo is disclosed to passengers, when you have received their order. When you have accepted the passenger’s order, 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 Decentralized Mobility Limited local subsidiaries, representatives, affiliates, agents, fleet owners etc). Processing of personal data by will occur under the same conditions as established in this privacy notice. 

Security and Access 

1.7.Any personal data collected in the course of providing services is transferred to and stored in the data centre of AWS. Only authorised employees of Decentralized Mobility Limited group companies and partners have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding E-hailing). 

Correction, Retention, and Data Portability

1.8.Your personal data will be stored as long as you have an active driver’s account. If your account will be closed the personal data will be stored for additional 3 year period while data necessary for accounting purposes shall be stored for 7 years. In the event that there are suspicions of a criminal offence, fraud or false information having been provided, the data will be stored as long as necessary according to the internal, legal, and regulatory requirements. In the event of disputes, the data shall be retained until the claim is satisfied or the expiry date of such claims. 

1.9.We respond to the request for deleting and transferring personal data submitted by an e-mail within a month and specify the period of data deletion and transfer. The retention period for the data about instant messages directly in the Bloxmove app messages is 365 days, except cases where messages are related to a reported incident – in which case we will store them for max of 1 year.