USER’S ACKNOWLEDGEMENT OF THIS POLICY

BY USING THE SERVICES OR REGISTERING, DOWNLOADING OR ENTERING THE WEBSITES AND/OR THE APPS YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF THIS POLICY, INCLUDING THE PROCESSING (INCLUDING COLLECTING, USING, DISCLOSING, RETAINING OR DISPOSING) OF YOUR INFORMATION. THE INFORMATION SWVL HOLDS ABOUT YOU MAY BE HELD AND PROCESSED ON COMPUTER AND/OR PAPER FILES. IF YOU PROVIDE SWVL WITH ANY INFORMATION REGARDING ANOTHER PERSON, IT IS YOUR RESPONSIBILITY TO MAKE THEM AWARE OF THIS POLICY. IF YOU HAVE ANY QUESTIONS OR COMMENTS REGARDING PRIVACY ISSUES ON THE SITE AND/OR THE APP, PLEASE CONTACT SWVL BY EMAIL AT legal@swvl.com

TYPES OF INFORMATION WE COLLECT

1. SWVL collects both "Personal Information" and "Anonymous Information" about you. "Personal Information" is information that can be used to identify you, such as your full name, email address, phone number, payment method, password, mailing address, IP address, and profile picture, location, as well as information that is linked to such information. "Anonymous Information" is information that we cannot use to identify you and is not linked to information that can be used to do so. It includes passively collected information about your activities on the Websites or on the Apps, such as use and usage data, to the extent that information is not linked to your Personal Information. "Personal Data" means collectively, Personal Information and Anonymous Information.

2. While accessing certain portions of the Services, we passively collect certain information from your devices, such as your IP address, screen resolution information, geographic location, Wi-Fi information, browser information, unique device identifier ("UDID") where applicable and/or your mobile operating system, and use third party service providers to obtain detailed analytics. We also collect geolocation data from you upon you downloading and opening the Apps. Sometimes, this passively collected information will constitute Personal Information – please see Sections 2.4 and 2.5 in particular.

3. Voluntarily submitted information, We collect information that you provide to us during your use of the Services. Some examples include:

   1. Personal Information that you enter when registering for or using the Apps, including your full name, email address, phone number, payment method, billing information, profile picture and profile information. The provision of some of this information (as indicated by us) is mandatory in order to create an account and use our Services;

   2. communications with us (e.g. emails, in-app messages and photos, text messages) or with captains (e.g. written in-app instructions to captains);

   3. user preference information you provide such as marketing preferences, communication preferences (e.g. sms or in-app messages) home address, work address, and/or favourites, as well as information in surveys;

   4. information you provide to our customer support team or other SWVL staff by email, post, the Apps, sms, Facebook messenger, in-app messaging, Instagram messaging, telephone or otherwise, in which case SWVL may keep a record of that correspondence to respond to your enquiries and improve its services, and we may record your customer support calls for quality assurance purposes and for improving our services. Any photos you send us will be stored on your own device;

   5. information that you post on any forums or message boards (such as SWVL’s pages on third party social media sites, and other third party maintained and publicly accessible forums where SWVL is discussed);

   6. data you provide, including photos or comments, in connection with or participation in any promotions or competitions sponsored, promoted or offered by SWVL and/or any third-party and any data provided to SWVL by way of feedback, profile forms or issues relating to the Services;

   7. data you provide, including a copy of your identification or credit card, in connection with special instances relating to fraud or otherwise where SWVL needs to authenticate user identity and/or ownership of the payment method provided. Full credit card information is not retained by SWVL, and the copy of your credit card will be used solely for the purposes of authenticating your ownership and preventing fraud; and

   8. where you are a captain - insurance policies, fleet information, vehicle information, and licensing information. The provision of this information is mandatory in order to become a captain.

4. Information collected through use of the Services

   1. Geolocation data: If you access the Apps through a mobile device, we may access, collect, monitor and/or remotely store "geolocation data" which may include the GPS coordinates of your trip (including pickup and drop-off data and route information) or similar information regarding the location of your mobile device.

   2. Contacts: We may access your calendar or contacts if you provide us with your permission to do so.

   3. Transaction data: We collect information created during your various interactions with any Service, including the date and time of an order, captain acceptance of the order, captain arrival, completion of the Services, as well as distance travelled, amount charged, including breakdown of base fee, tip and additional fees, as well as promotional code delivery.

5. Information collected via technology

   1. f you are using our Websites, we automatically collect information from you, including your hardware model, browser type, operating system, Internet Protocol (IP) and domain name. If you are using a mobile device, we may also receive your UDID, or another unique identifier, and mobile operating system. We may correlate this information with other Personal Information we have about you. We may also use cookies and URL information to gather information regarding the date and time you used the Services.

   2. In connection with your use of the Apps, we may receive the date and time of calls, SMS and in-app messages with SWVL and their respective content, as well as a record of the fact that you contacted a captain. For the avoidance of doubt, SWVL does not have access to the content of calls and/or SMS messages between passengers and captains, or any information whatsoever about your calls or SMS messages to any third-parties (i.e. anyone other than SWVL or a captain).

   3. We may use third-party services with your use of the Apps, such as Tableau, Mo-engage and Amplitude to track and analyse trends and patterns in relation to consumer behaviour.

   4. We may also use third-party fraud prevention services to track and analyse customer and captain usage logs, device logs, root logs, screen logs, and granted permission logs for purposes of security, fraud prevention, and money laundering prevention.

   5. f you choose to download or login to the Apps or Websites via a third-party website, your Personal Information may be provided to us by that website.

   6. Because we rely on third-party commercial software and programs to operate our servers, we may inadvertently collect Personal Information due to certain automatic functions or features contained in such software or due to certain software changes or upgrades. We will use reasonable efforts to remove any such information prior to engagement and after discovery in our system. If you know of any such unintended collections, please notify us promptly so we can take the necessary action to remove such information from our system.

6. Information provided by others

   1. We collect information that passengers provide about captains, and vice-versa, including ratings, complaints, and postings on SWVL’s forums or message boards, or those of third parties (such as news media) where SWVL is discussed.

   2. SWVL may receive information about you if you use any of the other websites or other services its affiliates provide. SWVL also works closely with third parties (including, for example, business partners, subcontractors in technical, payment, delivery and transportation services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Where third-parties collect information about you and share it with us, you should refer to their separately maintained privacy policies or notices.

7. Information about your device

   1. SWVL collects information about the device you use to access the Services, which may include personal data. This information is used to recognise your device so that it can be linked to your account. This activity is carried out for purposes of safety, security, evaluation of the performance of the Apps or the Websites, improvement and optimization of the customer experience, fraud prevention and may involve the sharing of information about your device including limited personal data, IP address, Wi-Fi and location information with a third-party service provider.

   2. SWVL collects information about installed malicious applications that are specifically used to commit fraud against SWVL ("Installed Apps"), including the Installed Apps’ name and installation date. For the avoidance of doubt, we do not collect data within the Installed Apps;

   3. the battery and network performance (i.e. battery status and charger use) of your device and the file names, types and files sizes on your device, including the amount of free and used local storage space, but not the contents of the files; and

   4. the system status, including device event information such as crashes and system activity.

COOKIES AND OTHER WEB FILES OR TAGS

1. The Websites use cookies and related technologies for a number of purposes, including site functionality, analytics, and advertising. The use of these technologies can involve the processing of personal data. For more information about how the Websites uses cookies and related technologies, and your choices regarding cookies, please refer to our Cookies Notice.

USES MADE OF THE INFORMATION

1. SWVL may use, combine, and process your Personal Data for the following purposes ("Purposes"):

   1. Providing Services and Features - your Personal Data will be used to provide, personalise, maintain, and improve our products and services. This includes using your Personal Data to:

      1. Providing Services and Features - your Personal Data will be used to provide, personalise, maintain, and improve our products and services. This includes using your Personal Data to:

      2. engage you to provide Services;

      3. create, administer, and update your account;

      4. verify your identity;

      5. validate your ride and process payments;

      6. enable dynamic pricing, in which the price of a ride 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 captains using SWVL at a given moment;

      7. offer, obtain, provide, or facilitate insurance or financing solutions;

      8. track the progress of your trip and detect abnormal trip variations;

      9. enable features that personalise your Apps, such as lists of your favourite places and previous destinations;

      10. perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;

      11. protect the security or integrity of the Services and any facilities or equipment used to make the Services available;

      12. process and manage your rewards;

      13. enable communications between our users;

      14. process, manage or verify your application of promotions, rewards, and subscriptions with SWVL; and

      15. enable our partners to manage and allocate fleet resources.

   2. Safety and Security - We use your data to ensure the safety and security of our services and all users. This includes:

      1. screening captain partners before enabling their use of our Services;

      2. identifying unsafe driving behaviour such as speeding, harsh braking and acceleration, and providing personalised feedback to our captain partners;

      3. verifying your identity when you log in to the Apps;

      4. using device, location, profile, usage, and other Personal Data to prevent, detect and combat fraud or unsafe activities;

      5. sharing captains and passengers’ location and details when the emergency button is activated;

      6. monitoring compliance with our terms and conditions, policies and Captain’s Code of Conduct; and

      7. detecting, preventing, and prosecuting crime.

   3. Customer Support - We use Personal Data to resolve customer support issues. For example, we may:

      1. investigate and address concerns;

      2. monitor and improve our customer support responses;

      3. respond to questions, comments, and feedback; and

      4. respond to questions, comments, and feedback; and

   4. Research and Development and Security - We may use the Personal Data we collect for testing, research, analysis, and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve, and enhance the safety and security of our services, develop new features, products, and services, and facilitate insurance and finance solutions.

   5. Legal Purposes - We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law. We may also use your Personal Data when we are required, advised, recommended, expected, or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental, or other authority. For example, we may use your Personal Data to:

      1. comply with court orders or other legal, governmental, or regulatory requirements;

      2. enforce our Terms of Service or other agreements; and

      3. protect our rights or property in the event of a claim or dispute.

      We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.

   6. Marketing and Promotions - We may use your Personal Data to market SWVL and SWVL’s partners’ sponsors’ and advertisers’ products, services, events, or promotions. For example, we may:

      1. send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and

      2. notify, invite, and manage your participation in our events or activities.

      We may communicate such marketing to you by post, telephone call, short message service, online messaging service, push notification by hand and by email.

      IF YOU WISH TO UNSUBSCRIBE TO THE PROCESSING OF YOUR PERSONAL DATA FOR MARKETING AND PROMOTIONS, PLEASE CLICK ON THE UNSUBSCRIBE LINK IN THE RELEVANT EMAIL OR MESSAGE. ALTERNATIVELY, YOU MAY ALSO UPDATE YOUR PREFERENCES IN OUR APPS SETTINGS.

SECURITY AND DATA RETENTION

1. SWVL has implemented administrative, physical, and electronic measures designed to protect your information from unauthorized access, modification, and unavailability. SWVL will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Data and, where we consider appropriate or where required by applicable law, notify you via email, text or conspicuous posting on the Websites in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

2. Although guaranteed security does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with this Policy and all applicable laws and regulations.

3. Where SWVL has given you (or where you have chosen) a username, login or password which enables you to access certain parts of the Websites and/or the Apps, you are responsible for keeping this information confidential. SWVL asks you not to share a username, login, or password with anyone, and not to reuse the same password across multiple websites.

4. SWVL restricts access to your Personal Data to individuals who need access to it in order to process it on SWVL’s behalf. These individuals, where employees, are bound by confidentiality agreements and SWVL will take appropriate action (which may include disciplinary proceedings) in the event SWVL finds that its employee(s) has failed to meet standards in looking after your Personal Data. SWVL cannot accept any liability for employees or agents acting outside the normal course of their employment or the terms of their agency agreement, or for captains or any third-parties with whom your Personal Information may be shared who act outside of the terms of our contracts with them.

5. We will retain your Personal Information only for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws.

6. In general, this means that we store your data throughout the existence of your account with us or for as long as is otherwise required to deliver our Services, except where we have a lawful basis for saving it for an extended period of time (for instance, after fully executing a contract, we may still have a legitimate interest in using your contact details for marketing purposes). We also retain the data we need for the execution of pending tasks and the data we need to investigate and realize your complaints or queries, or our legal rights and our claims, as well as certain data that we must store for a legally mandatory period of time. When certain data is only saved due to a legally mandatory preservation term, the processing of it by us is limited, even where you do not specifically request this.

DISCLOSURE AND SHARING OF YOUR INFORMATION

1. We know how important it is to keep your information confidential. We will not rent, sell or share your Personal Information with third-parties except as specifically approved by you at the time of disclosure or under the circumstances described in this Policy.

2. If you do not want us to use or disclose certain Personal Information collected about you in the ways identified in this Policy, you may choose not to (i) provide your Personal Information at any time (unless it is mandatory for the Services); (ii) download the Apps; (iii) consent to the placement of non-essential cookies (see the Cookies Notice).

3. In addition to using the information collected by us for the purposes described in section 4 above, we may also share your information as described below. Please review our sharing policy closely, especially with respect to your Personal Information.

4. Passengers and Captains

   1. We share certain information about passengers (including but not limited to name, pickup and drop-off locations, route information, profile picture) with captains to enable the scheduling and provision of the Services.

   2. We share certain information about captains (including but not limited to name, rating, location, profile picture, license plate number, fleet information, birthday week) with passengers to enable the scheduling, provision, and receipt of the Services.

   3. We share certain information about captains (including but not limited to name, rating, location, profile picture, license plate number, fleet information, birthday week) with passengers to enable the scheduling, provision, and receipt of the Services.

5. Service Providers

   We also share Personal Information with vendors, payment providers, transportation providers, promotion companies, sponsorship companies, software providers, consultants, market researchers and other third parties who perform services using the Websites or Apps or on behalf of SWVL. As an example, we share Personal Data with companies that provide sms and in-app service notifications, email services, and hosting services. We also share Personal Information with third-parties that provide analysis, monitoring, and reports to assist us in preventing and detecting fraudulent transactions and other activity. SWVL has selected companies who maintain high standards with respect to privacy and agree to use the Personal Information only to perform specific services on behalf of SWVL.

6. Compliance with Laws, Law Enforcement and Safety

   We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend SWVL’s, or a third-party’s, rights or property. We may also reserve the right to disclose information we’ve collected about you for purposes of protecting the health and safety of the passengers and captains, such as in the case of risk of harm or violence against any person. Finally, we may also disclose information in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of SWVL, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

7. Anonymous Information

   Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other users ("Aggregated Anonymous Information"). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third-parties to further the purposes described herein, or for other commercial purposes, in our sole discretion.

8. Within SWVL

   We may share all or some of your Personal Information with any of our parents, subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honour this Policy.

9. Business Transactions

   Additionally, in the event we undergo a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, including in the unlikely event of bankruptcy, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy, and that any entity that acquires us, is merged with us or that acquires our assets may continue to process your Personal Information as set forth in this Policy.

LOCATION OF YOUR INFORMATION

1. Your Personal Information may be disclosed to other SWVL entities and third-parties (including service providers) in jurisdictions including, but not limited to: British Virgin Islands, Egypt, Kenya, Pakistan and United Arab Emirates.

2. Consequently, the data that SWVL collects from you may be transferred to, and stored in, a country that is not considered to offer an adequate level of protection under your local laws. It may also be processed by staff operating outside of your country of residence who work for SWVL or for one of its suppliers, service providers or partner entities. By submitting your Personal Information, you acknowledge, and, where necessary under local laws, agree to, this transfer, storing or processing.

3. SWVL may also make disclosures of your Personal Information to government entities, courts, or regulators in other countries, where these are disclosures anticipated by section 6. In this context, we may rely on the fact that a disclosure to a court or administrative authority is based on an international agreement, which provides a legal basis for the transfer.

4. SWVL will take appropriate steps to ensure that your Personal Information is treated securely and in accordance with applicable Privacy Laws and this Policy. This may include putting in place data transfer agreements or ensuring that SWVL or third parties comply with contractual obligations or other data transfer mechanisms or schemes. If you are located in the EU, you have a right to request to obtain further information about the data transfer mechanisms used to transfer your Personal Information to third countries.

YOUR RIGHTS

1. Subject to applicable law, you may have some or all of the following rights in respect of your Personal Information:

   1. Access to own Personal Information: You may also have the right to obtain a copy of the Personal Information held about you, and to be informed of certain details, such as (a) the source of your Personal Information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your Personal Information may be transferred.

   2. Accuracy and right of rectification: SWVL seeks to ensure that your Personal Information is accurate, complete and kept up-to-date to the extent reasonably necessary for the purposes described herein. You also have the ability to update the information we hold about you through your SWVL account. If the Personal Information is incorrect, incomplete, or not processed in compliance with applicable law or this Policy, you may have the right to have your Personal Information rectified or deleted in accordance with applicable law.

   3. Right to object: In certain circumstances (e.g., where your Personal Information is processed on the basis of SWVL’s legitimate interests), you may have the right to object to the processing of your Personal Information on the basis of compelling grounds related to your particular situation and in accordance with applicable law.

   4. Right to prevent direct marketing: You may have the right to request that SWVL does not process your personal data for marketing purposes. In such a case, you can control your initial marketing preferences by ticking the relevant box situated within the Apps settings or an ‘unsubscribe’ link within a marketing email. Thereafter, you can follow the opt-out links or unsubscribe directions in emails or SMS messages.

   Right to withdraw consent: If the processing of your Personal Information is based on your consent, you may have the right to withdraw your consent to such processing at any time. It is worth noting that the withdrawal of consent has no impact on earlier processing on such basis and does not prevent SWVL from invoking another legal basis for the processing of the relevant Personal Information.

   5. Right to lodge a complaint: You may have the right to lodge a complaint before the relevant data protection authority or supervisory authority.

2. To exercise these rights, where applicable, please contact SWVL legal@swvl.com or use the appropriate functionality in the Apps.

3. We may ask you for additional information to confirm your identity and for security purposes before complying with your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

4. Some rights may be subject to exemptions created by applicable law or may only be exercisable in certain circumstances. We will communicate openly with you to help you to understand whether, and to what extent, a right is exercisable. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

THIRD PARTY WEBSITES

From time to time SWVL may post links to third-party websites on the Websites and/or the Apps. These links are provided as a courtesy to SWVL’s users and visitors and are not administered or verified in any way by SWVL. Such links are accessed by you at your own risk and SWVL makes no representations or warranties about the content of such websites including any cookies used by the website operator. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that SWVL does not accept any responsibility or liability for these policies. As a result, SWVL strongly recommends that you read the privacy policies of any third-party websites before you provide any personal data to them.

CHILDREN

Neither the Websites nor the Apps are directed or targeted to children under the age of 18, and SWVL does not knowingly collect personally identifiable information from children under the age of 18. SWVL requires users under 18 years of age to obtain the consent of a parent or guardian, to view the Websites or use the Apps or the Services. If SWVL learns that a child under 18 years of age has provided personally identifiable information to the Websites or the Apps, it will use reasonable efforts to remove such information from its files. No part of our Service is directed towards children under the age of 18 and we do not want Personal Information from children under the age of 18. If you believe that a child under 18 years of age has given us Personal Information, please contact SWVL legal@swvl.com .

CHANGES TO SWVL’S PRIVACY POLICY

SWVL may change this Policy from time to time. Any changes SWVL may make to this Policy in the future will be posted on this page and, where SWVL deems appropriate, notified to you (usually within the Apps or by email). You are therefore invited to check it each time you send SWVL Personal Information. The date of the most recent revisions will appear on this page.

CONTACT

Questions, comments, and requests regarding this Policy are welcomed and should be addressed legal@swvl.com.