Privacy Policy

Last updated: [date this goes live]

This policy explains what personal data the Ọnà rider app and the Ọnà Pilot driver app collect, why we collect it, who we share it with, how long we keep it, and the rights you have over it. It applies to both apps and to onarides.com.

1. Who we are
2. What we collect
3. Why we use it
4. What other people see
5. Night Guard and recordings
6. Who we share it with
7. Where it is stored
8. How long we keep it
9. Deleting your account
10. Your rights
11. Security
12. Children
13. Changes to this policy
14. Contact us

1. Who we are

Ọnà is operated by [company legal name], a company registered in Nigeria (RC [number]), at [registered address]. In this policy, "Ọnà", "we" and "us" mean that company. We are the data controller for the personal data described here, under the Nigeria Data Protection Act 2023 (NDPA).

Our Data Protection Officer can be reached at [privacy email].

2. What we collect

Everyone

• Phone number. You sign in with your Nigerian mobile number and a one-time code sent by SMS. The same number can hold one rider account and one driver account.
• Trips. Pickup and drop-off addresses and coordinates, times, fare, payment method, the trip's status changes, any cancellation reason, and the trip code.
• Messages and ratings. Text messages you send through in-app chat during a trip, and the ratings and comments you give and receive.
• Safety reports. What you tell us in a report or emergency, the trip it concerns, and where you were when you raised it.
• Device details. A push notification token and whether your phone runs iOS or Android, so we can send you trip notifications. The app's version.
• Crash reports. If the app crashes, an error report with technical details such as the error, the app version and your device model and operating system. We have switched off the collection of your IP address, screenshots and anything identifying you in these reports.

Riders

• Identity details. Your full name, date of birth, gender, home address and National Identification Number (NIN). We ask for these when you sign up. Your NIN is stored encrypted.
• Location. Your location when you set a pickup point. While a driver is on the way to you, the app sends your location to us every few seconds so the driver can find you. This stops at pickup, when that location is erased.
• Saved cards. When you add a card, Paystack gives us a reference we can charge, plus the card's brand, last four digits, expiry date and issuing bank. We never receive or store your full card number or security code.

Drivers

• Identity and documents. Your name, the city you drive in, a selfie, and photos of your driver's licence, vehicle registration, insurance and (in Lagos) roadworthiness certificate and LASDRI card, with their expiry dates. These files are encrypted when stored.
• Your car. Its plate, make, model, year and colour, and a photo of it.
• Location. While you are online, your location roughly every minute, so we can offer you nearby trips. During a trip, your location every few seconds, which we keep as the trip's route.
• Payout details. Your bank and the account holder's name. We send your account number to Paystack to confirm the name and set up transfers, but we keep only its last four digits.
• Your balance. Your earnings, the commission you owe on cash trips, what you've paid, and your payouts.
• Your agreement to the Driver Terms, with its version and the time you agreed.

Permissions on your phone

The apps ask for your location (for pickups, matching and navigation), your camera and photos (for documents and your selfie), your microphone (for trip recordings; see section 5) and notifications. You can turn any of these off in your phone's settings. Some features won't work without them; for example, a driver cannot go online at night without the microphone.

3. Why we use it

We don't use your data for advertising, we don't sell it, and we don't make decisions about you based solely on automated processing that have legal or similarly significant effects. Night Guard's automatic checks only ask whether you're all right; a person decides anything that follows.

4. What other people see

• Your driver sees your pickup and drop-off, the fare, how you're paying, and your live location until they pick you up.
• Your rider sees your first name (never your surname), your approved selfie, your car's make, model, colour and plate, and your location during the trip.
• Phone numbers. While a trip is in progress, either of you can tap Call to reach the other through the phone's own dialer. This uses your real number. We record that the number was given out.
• A shared trip link shows first names, the car and plate, where the trip is going and where the car was last seen. It shows no phone numbers, surnames or fare, and stops showing the trip 30 minutes after it ends.
• Our staff can see what they need to review drivers' documents, investigate safety reports, process payouts and handle deletion requests. Access to safety recordings is logged.

5. Night Guard and recordings

Trips booked between 21:00 and 05:00 Lagos time, and trips still going at 21:00, run under Night Guard:

• The driver's phone records audio for the whole trip, and tells us whether it is recording. A rider's phone also keeps its own recording if they've allowed the microphone.
• We watch the trip's location for signs of trouble: a long stop away from the destination, the car heading away from it, location reports stopping, or the car moving before the trip has started. If we see one, the app asks both of you whether you're all right. An unanswered check, or a request for help, is flagged to our team.
• To book at night, riders confirm their identity, which means checking their NIN with an identity verification provider.
• Someone with an open safety report against them is not offered night trips until it is resolved.

How recordings work, day or night: recordings are saved on the phone that made them, and the app never plays them back. If you don't send one, the app deletes it 24 hours after the trip. We only receive a recording if you choose to attach it to a safety report, and we delete it from our servers 30 days later. Either person on a trip may be recording, and the other is not told when they start.

6. Who we share it with

We share personal data only with the service providers we need to run Ọnà, who may use it only to provide their service to us:

We also disclose data when the law requires it, such as a valid request from the police or a court, or when it's needed to protect someone from serious harm.

7. Where it is stored

Our servers, database and file storage are hosted by Railway in the European Union (Amsterdam, the Netherlands). Some of our providers, including Google, Apple, Sentry and Paystack, also process data outside Nigeria. When we transfer your data outside Nigeria we rely on the safeguards the NDPA allows, including the adequacy of the destination's data protection law and contractual protections with our providers.

8. How long we keep it

9. Deleting your account

You can delete your Ọnà or Ọnà Pilot account at any time.

In the app

1. Open the app and go to Account.
2. Tap Delete account, tell us why if you like, and confirm.

You can't do this during a trip. You'll be signed out, and if you change your mind you can sign in again and choose Keep my account before we've deleted it.

Without the app

Email [privacy email] from any address, with the phone number on the account and whether it's a rider or a driver account. We'll confirm the account is yours before we delete it.

What happens

We delete your account within 30 days of your request. We remove your name, phone number, email, identity details and NIN, photos, documents, car details, saved cards (and ask Paystack to cancel them), bank details, devices and the recordings you sent us. Records of your trips, payments and safety reports are kept, with your identifying details removed, because the law and the other people on those trips need them. Deleting one account doesn't delete the other account on the same number. Drivers: any money we owe you is settled before your account is deleted.

10. Your rights

Under the NDPA, you have the right to:

• get a copy of the personal data we hold about you;
• have it corrected if it's wrong;
• have it deleted (see section 9);
• object to, or ask us to restrict, how we use it;
• receive it in a commonly used, machine-readable format;
• withdraw your consent where we rely on it, without affecting what we did before;
• complain to the Nigeria Data Protection Commission (ndpc.gov.ng).

To use any of these rights, email [privacy email]. We'll answer within 30 days.

11. Security

All traffic between the apps and our servers is encrypted. NINs, saved-card references and uploaded documents and photos are encrypted when stored. Sign-in codes are stored only as a one-way hash and expire after 5 minutes. No system is perfectly secure; if a breach puts your rights at risk, we'll tell you and the Nigeria Data Protection Commission as the law requires.

12. Children

Ọnà is for people aged 18 and over. We don't knowingly collect data from children. If you believe a child has an account, email us and we'll delete it.

13. Changes to this policy

When we change this policy we'll update the date at the top. If a change materially affects how we use your data, we'll tell you in the app before it takes effect.

14. Contact us

[company legal name]
[registered address]
Data Protection Officer: [privacy email]