ZIQQI PRIVACY POLICY

I. Introduction

“Ziqqi Go” and “Ziqqi Courier” are brands owned by Idukaan FZC (hereafter “Ziqqi”, “we”, or “us”), a private limited liability company established in the United Arab Emirates, having its offices at P6-186 SAIF Zone Sharjah, operating under trade license number 18233, and its subsidiaries and affiliates.

When you use Ziqqi’s apps, websites, features, or other services, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This policy describes the personal data we collect, how it’s used and shared, and your choices regarding this data.

II. Overview

This notice describes how Ziqqi and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world, unless covered by a separate privacy notice. This notice specifically applies to:

  • • Passengers: individuals who request or receive transportation, including those who receive transportation requested by another individual
  • • Drivers: individuals who provide, or submit applications to Ziqqi to provide, transportation individually or through partner transportation companies
  • • Delivery recipients: individuals who request or receive food, or other products and services
  • • Delivery partners: individuals who provide, or submit applications to Ziqqi to provide, delivery or other services

This notice also governs Ziqqi’s other collections of personal data in connection with Ziqqi’s services. For example, we may collect the contact information of owners or employees of Ziqqi Food restaurant partners. All those subject to this notice are referred to as “users” in this notice.

Please note that for passengers without a Ziqqi account, the personal data of such passengers who take trips arranged by the owners of a Ziqqi account, is processed in accordance with our contract with the owner of that account, and not as otherwise described in this notice. Such processing may include sharing of passenger location data with the owner of that account. Please contact the owner of such account for more information.

Our data practices are subject to applicable laws in the places in which we operate. Ziqqi.com Limited (Nyarugenge, Umujyi wa Kigali, RWANDA) is the data controllers for the personal data collected in connection with use of Ziqqi’s services in Rwanda. Idukaan FZC is the data controller for the personal data collected in connection with use of Ziqqi’s services anywhere else.

III. Data collections and uses

A. The data we collect

Ziqqi collects:

  • Data provided by users to Ziqqi, 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 Ziqqi partners and third parties that use Ziqqi APIs

The following data is collected by or on behalf of Ziqqi:

1. Data provided by users. This includes:

  • • User profile: We collect data when users create or update their Ziqqi accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), government identification documents, including driver’s license numbers and images, birthdate, signature, and photo. This also includes vehicle or insurance information of drivers and delivery partners, and user settings. We may use the photos submitted by drivers and/or delivery partners to verify their identities, such as through facial recognition technologies.
  • • Background check and identity verification: We collect background check and identity verification information for drivers and delivery partners. This may include information such as driver history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on Ziqqi’s behalf.
  • • Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.
  • • User content: We collect the information users submit when they contact Ziqqi customer support, provide ratings or compliments for other users or restaurant partners, or otherwise contact Ziqqi. This may include feedback, photographs or other recordings collected by users.

2. Data created during use of our services. This includes:

  • • Location data: We collect precise or approximate location data from a user’s mobile device if enabled by the user to do so. For drivers and delivery partners, Ziqqi collects this data when the Ziqqi app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device. For passengers and delivery recipients, Ziqqi collects this data when the Ziqqi app is running in the foreground. In certain regions Ziqqi may also collect this data when the Ziqqi app is running in the background of the user’s mobile device. Passengers and delivery recipients may use the Ziqqi apps without enabling Ziqqi to collect location data from their mobile devices. However, this may affect some functionality available in the Ziqqi apps. For example, a user who has not enabled location data collection will have to manually enter their address. In addition, the location data collected from a driver during a trip will be linked to the passenger’s account, even if they have not enabled location data to be collected from their device, including for purposes of receipt generation, customer support, fraud detection, insurance, and litigation.
  • • Transaction information: We collect 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 someone uses your promotion code, we may associate your name with that person.
  • • Usage data: We collect data about how 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 Cookie Notice.
  • • Usage data: We collect data about how 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 Cookie Notice.
  • • Communications data: We enable users to communicate with each other and Ziqqi through Ziqqi’s mobile apps and websites. For example, we enable drivers and passengers, and restaurants or delivery partners and delivery recipients, to call, text, or send other files to each other. To provide this service, Ziqqi receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Ziqqi may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics.

3. Data from other sources. This includes:

  • User feedback, such as ratings, feedback, or compliments.
  • 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.
  • Ziqqi 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.
  • Users or others providing information in connection with claims or disputes.
  • Ziqqi business partners through which users create or access their Ziqqi account, such as payment providers, social media services, or apps or websites that use Ziqqi’s APIs or whose APIs Ziqqi uses.
  • Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
  • Insurance, vehicle, or financial services providers for drivers and/or delivery partners.
  • Partner transportation companies (for drivers or delivery partners who use our services through an account associated with such a company).
  • Publicly available sources.
  • Marketing service providers. Ziqqi may combine the data collected from these sources with other data in its possession.

B. How we use personal data

Ziqqi collects and uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use the data we collect:

  • To enhance the safety and security of our users and services
  • For customer support
  • For research and development
  • To enable communications between users
  • To send marketing and non-marketing communications to users
  • In connection with legal proceedings

Ziqqi does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

Ziqqi uses the data it collects for purposes including:

1. Providing services and features. Ziqqi uses the data we collect to provide, personalize, maintain, and improve our products and services.

This includes using the data to:

  • Create and update users’ accounts.
  • Verify drivers’ and delivery partners’ identity, background history, and eligibility to work.
  • Enable transportation, deliveries, and other services.
  • Offer, process, or facilitate payments for our services.
  • Offer, obtain, provide, or facilitate insurance, vehicle, invoicing, or financing solutions in connection with our services.
  • Track and share the progress of rides or deliveries.
  • Enable features that allow users to share information with other people, such as when passengers submit a compliment about a driver, when delivery recipients provide feedback for a restaurant or delivery partner, refer a friend to Ziqqi, or share ETA and location with their contacts.
  • Enable features to personalize users’ Ziqqi accounts, such as creating bookmarks for favorite places, and to enable quick access to previous destinations. We may, for example, present a Ziqqi Food user with personalized restaurant or food recommendations based on their prior orders.
  • Enable Accessibility 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 passengers of their disabilities, allow only text messages from passengers, and enable receipt of flashing trip request notifications instead of sound notifications on their mobile device.
  • Perform internal operations necessary to provide our 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.

2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

  • Screening passengers, drivers, and delivery partners before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe drivers and/or passengers.
  • 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.
  • In certain regions, using information derived from driver’s license photos, and other photos submitted to Ziqqi, for safety and security purposes. This includes 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.
  • Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
  • Using user ratings and feedback as grounds for deactivating drivers and delivery partners with low ratings or who otherwise violated such guidelines in certain countries.

3. Customer support. Ziqqi 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:

  • Direct questions to the appropriate customer support person
  • Investigate and address user concerns
  • Monitor and improve our customer support responses and processes

4. Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user 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.

5. Enabling communications between users. For example, a driver may message or call a passenger to confirm a pickup location, a passenger may contact a driver to retrieve a lost item, or a restaurant or delivery partner may call a delivery recipient with information about their order.

6. Marketing. Ziqqi may use the data we collect to market our services to our users. This includes sending users communications about Ziqqi services, features, promotions, studies, surveys, news, updates, and events.

We may also send communications to our users about products and services offered by Ziqqi partners. For example, if a user has placed a Ziqqi Food order, we may provide recommendations, promotions, or ads about similar food offered by other Ziqqi partners. Although we may send users communications about Ziqqi partners’ products and services, we 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.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of Ziqqi’s services, and user preferences and settings.

7. Non-marketing communications. Ziqqi 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 aren’t for the purpose of marketing the services or products of Ziqqi or its partners.

8. Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Ziqqi’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

9. Automated decision-making. We use personal data to make automated decisions relating to use of our services. This includes:

  • • Enabling dynamic pricing, in which the price of a ride, or the delivery fee for Ziqqi Food orders, is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic, and the number of passengers and drivers using Ziqqi at a given moment.
  • • Matching available drivers and delivery partners to users requesting services. Users can be matched based on availability, proximity, and other factors.
  • • Determining driver and delivery partner ratings, and deactivating drivers, passengers, and delivery partners with low ratings.
  • • Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm Ziqqi, its users, and others. In some cases, such as when a user is determined to be abusing Ziqqi’s referral program, such behavior may result in automatic deactivation.
  • • Using driver location information, and communications between passengers and drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a driver is delaying a passenger pickup in order to induce a cancellation, we will not charge the passenger a cancellation fee and will adjust the amounts paid to the driver to omit such a fee.

C. Cookies and third-party technologies

Ziqqi and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Ziqqi uses cookies and similar technologies for purposes such as:

  • • Authenticating users
  • • Remembering user preferences and settings
  • • Determining the popularity of content
  • • Delivering and measuring the effectiveness of advertising campaigns
  • • Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people 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.

D. Data sharing and disclosure

Some of Ziqqi’s 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.

Ziqqi may share the data we collect:

1. With other users

This includes sharing:

  • • Passengers’ first name, rating, and pickup and/or dropoff locations with drivers.
  • • Passengers’ first name with other passengers in a carpool trip.
  • • Delivery recipients’ first name, delivery address, and order information with their delivery partner and restaurant. We may also share ratings and feedback, or other information to the extent required by law, with the restaurant partner and delivery partner.
  • • For drivers and delivery partners, we may share data with the passenger(s), delivery recipient(s), and restaurant partner(s), including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; length of use of the Ziqqi app; contact information (depending upon applicable laws); and driver or delivery partner profile, including compliments and other feedback submitted by past users. We also provide passengers and delivery recipients with receipts containing information such as a breakdown of amounts charged, driver or delivery partner first name, photo, route map, and such other information required on invoices in the country or region where the driver or delivery partner operates.
  • • For those who participate in Ziqqi’s 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.

2. At the user’s request

This includes sharing data with:

  • • Other people at the user’s request. For example, we share a user’s ETA and location with a friend when requested by that user.
  • • Ziqqi business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Ziqqi may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurant partners or other Ziqqi business partners and their users in connection with promotions, contests, or specialized services.

3. With the general public

Questions or comments from users submitted through public forums such as Ziqqi blogs and Ziqqi social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

4. With the Ziqqi account owner

If a user requests transportation or places an order using an account owned by another party, we may share their order or trip information, including real-time location data, with the owner of that account. This occurs, for example, when:

  • • A driver or delivery partner uses an account owned by or associated with a Ziqqi partner transportation company or restaurant
  • • A passenger takes a trip arranged by a friend

5. With Ziqqi subsidiaries and affiliates

We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

6. With Ziqqi service providers and business partners

Ziqqi provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

  • • Payment processors and facilitators
  • • Background check and identity verification providers (drivers and delivery partners only)
  • • Cloud storage providers
  • • Marketing partners and marketing platform providers, including social media advertising services
  • • Data analytics providers
  • • Research partners, including those performing surveys or research projects in partnership with Ziqqi or on Ziqqi’s behalf
  • • Vendors that assist Ziqqi to enhance the safety and security of its apps
  • • Consultants, lawyers, accountants, and other professional service providers
  • • Fleet partners
  • • Insurance and financing partners
  • • Airports
  • • Restaurant partners and/or their point of sale providers
  • • Vehicle solution vendors or third-party vehicle suppliers

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

Ziqqi may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes 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 Ziqqi’s 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 you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.

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.

8. With consent

Ziqqi may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

E. Data retention and deletion

Ziqqi retains user profile, transaction, and other personal data for as long as a user maintains their Ziqqi account. Ziqqi may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements. Ziqqi retains user profile, transaction, and other information for as long as a user maintains their Ziqqi account. For drivers and delivery partners, Ziqqi also retains vehicle and background check information (to the extent permitted by law) for as long as they maintain their Ziqqi account.

Passengers and delivery recipients may request deletion of their account at any time by contacting customer support. Following such requests, Ziqqi deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, Ziqqi 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, and research and development. In certain circumstances, Ziqqi may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Ziqqi will delete the account as described above.

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

F. Grounds for processing

We only collect and use 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 Ziqqi’s 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:

a. To provide requested services and features

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

  • • User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their trips, orders, and accounts; and enable users to make payments or receive earnings
  • • Background trip information, which is used to verify an applicant’s eligibility to be a driver or delivery partner
  • • Driver and delivery partner location data, which we use to track trips and assist with navigation
  • • Usage data, which is necessary to maintain, optimize, and enhance Ziqqi’s services, including to determine incentives, connect passengers and drivers, and calculate costs of trips and driver earnings
  • • Transaction information
  • • Information relating to customer support

b. For purposes of the legitimate interests of Ziqqi or other parties

This includes using personal data to maintain and enhance our users’ safety and security. For example, 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 Ziqqi’s apps. We also use usage data to prevent matching of passengers and drivers for whom there is higher risk of conflict (for instance, because they have been the subject of prior complaints from other users).

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing Ziqqi’s 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 others.

c. To fulfill Ziqqi’s legal obligations

Ziqqi 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 authorities. We collect and use personal data to comply with such laws.

Ziqqi may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes.

d. With consent

Ziqqi may collect and use personal data based on the user’s consent. For example, we 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 their 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.

IV. Choice and transparency

Ziqqi enables users to access and control the data that Ziqqi collects, including through:

  • • In-app settings
  • • Device permissions
  • • In-app ratings pages
  • • Marketing opt-outs

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

A. 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 Ziqqi 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 Ziqqi app seeks before their first use of the app, and use of the app constitutes a grant of such permission.

B. Ratings look-up

After every trip, drivers and passengers 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, passenger ratings are available to drivers from whom they request transportation, and driver ratings are available to their passengers.

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

Delivery partners are also rated by delivery recipients and restaurant partners.

C. Marketing opt-outs

Users may opt out of receiving promotional emails and other messages from Ziqqi 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.

D. User data requests

Ziqqi users can learn about, control, and submit questions and comments about Ziqqi’s handling of their data by sending an email to legal@ziqqi.com.

  • • Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.
  • • Receiving data: Users can ask for a copy of data that Ziqqi collects from them with their consent or as necessary to provide our services.
  • • 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 Ziqqi’s apps or driver portal. They may also ask that Ziqqi change or update their data, including if they believe such data is inaccurate or incomplete.
  • • Deleting data: Users may request deletion of their account at any time through the Settings > Privacy menus in the Ziqqi app, or through Ziqqi’s website (passengers and delivery recipients here; drivers and delivery partners here).
  • • 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. Ziqqi may continue to process data after such objection or request to the extent required or permitted by law.

In addition, depending on their location, users may have the right to file a complaint relating to Ziqqi’s handling of their personal data with the data protection authority in their country

V. Updates to this notice

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Ziqqi apps or through other means, such as email. We encourage users to periodically review this notice 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 law.

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