Privacy Policy

1. Scope and applicable law

This Policy applies to Riders, Drivers, applicants, account holders, website visitors and people who contact support. It is designed principally for the Data Protection and Privacy Act, Chapter 97, Laws of Uganda, and the Data Protection and Privacy Regulations, 2021.

The Platform is intended to arrange services within Uganda and is not intentionally offered as a transport platform outside Uganda. If another jurisdiction’s mandatory privacy law applies to particular processing, we will honour the non-waivable requirements of that law.

2. Personal data we collect

2.1 Identity and contact data

Name, telephone number, email address, date of birth, photograph, address, account identifiers, preferred language, emergency or support contact information, and identity-verification results.

2.2 Verification and eligibility data

National Identification Number and identity-document images, driving licence information, age and eligibility information, and records used to investigate duplicate, fraudulent or unauthorised accounts. We limit access to identification documents because misuse could cause significant harm.

2.3 Driver and vehicle data

Vehicle owner or operator details, registration number, category, make, model, year, colour, capacity, photographs, insurance, inspection, permit and approval information, Driver availability and online status, and documents submitted during registration or review.

2.4 Location, route and Trip data

Pickup and destination, GPS coordinates, route points, timestamps, estimated and actual distance or duration, arrival, acceptance, start, completion and cancellation status, and safety or support events connected with a Trip.

2.5 Payment and wallet data

Wallet balances and ledger entries, fares, fees, commissions, withdrawals, refunds, payment references, transaction status, payment telephone number, payment-provider responses and reconciliation records. Payment providers may separately process mobile-money or bank credentials under their own notices. YOYO CARS does not ask you to disclose a mobile-money PIN or one-time code to its staff.

2.6 Device, technical and usage data

IP address, device and operating-system information, application version, device or notification token, session and authentication events, crash and diagnostic data, network information, security logs, feature interactions and consent or policy-acceptance records.

2.7 Communications and support data

Support requests, complaints, reviews, ratings, survey responses, notices, messages exchanged through Platform features where available, and call recordings when you are notified and recording is lawful.

2.8 Safety, fraud and compliance data

Reports, incident details, account links, risk indicators, disputed transactions, chargebacks, sanctions or legal checks where required, and records reasonably necessary to prevent, detect, investigate or respond to unlawful activity, threats or serious breaches.

3. Sources of personal data

We obtain personal data:

• directly from you during registration, booking, payment, support and account use;
• from the Rider or Driver involved in the same request or Trip;
• automatically from the app, device and server when you use the Platform;
• from payment, identity, map, messaging, cloud, analytics and security providers acting lawfully;
• from vehicle owners, businesses or representatives who register or authorise a vehicle or account; and
• from public authorities, public records or other sources where collection is lawful and relevant.

4. Why we process data and our lawful bases

4.1 Providing the requested service and performing our contract

We use account, location, Trip, vehicle, payment and communication data to register and authenticate Users; present services and fares; match requests; support acceptance and Trip progress; process and reconcile payments; maintain wallet records; provide support; and enforce the Terms of Use.

4.2 Legal obligations

We process information where necessary to comply with data-protection, tax, accounting, payment, transport, court, law-enforcement and other binding legal obligations. We verify the authority and scope of a request before disclosure where reasonably possible and lawful.

4.3 Legitimate interests

Where permitted, we process proportionate data for safety, fraud prevention, account and payment security, service reliability, dispute resolution, network protection, business continuity, audit, defence of legal claims and improvement of the Platform. We assess necessity and balance these interests against the rights and reasonable expectations of affected people.

4.4 Consent

We rely on consent where the law requires it, including for optional marketing, optional device permissions or particular processing that cannot properly rely on another basis. Consent is specific to the described purpose and may be withdrawn. Withdrawal does not invalidate processing lawfully completed before withdrawal.

4.5 Vital interests and emergencies

In a genuine emergency, we may process or disclose information reasonably necessary to protect a person’s life, health or safety, subject to applicable law.

5. Mandatory and optional information

Registration and core services require certain data, such as an authenticated telephone number, identity and Trip information. Driver registration also requires lawful Driver and vehicle documentation. If required data is not provided, we may be unable to create or verify the account, process payment or provide the requested service.

Optional information and permissions will be identified where reasonably practicable. Refusing optional processing will not prevent unrelated core services.

6. Location information

Location is central to pickup, matching, navigation, Trip progress, safety, support and fraud prevention. Depending on your role, device permissions and Platform state:

• a Rider’s location may be processed while selecting a pickup, requesting or taking a Trip, using a location feature, or submitting a safety or support report;
• a Driver’s location may be processed while the Driver is online, available for requests, travelling to a pickup or completing an active Trip; and
• background location may be processed during an active Trip or online-driver period where the operating system permits it and it is reasonably necessary for the stated function.

Location collection should stop or reduce when the relevant function ends, subject to short technical delays and retention of completed Trip records. Device settings may allow you to limit permission, but matching, navigation, traceability or safety features may then not work. We do not promise continuous human monitoring of location and the Platform is not an emergency service.

7. Automated systems

Automated rules and models may assist with matching, estimated routes or fares, vehicle eligibility, duplicate-account detection, fraud indicators, transaction limits, safety signals and service recommendations. Results may be affected by inaccurate inputs or third-party data.

Where an automated decision produces a significant adverse effect and applicable law requires a right of review, you may contact us for meaningful human review. We may withhold details that would enable fraud or compromise another person’s rights, but will provide the information required by law.

8. How and why we share data

We disclose only information reasonably necessary for an identified purpose:

• Trip participants: the assigned Rider and Driver receive relevant identity, vehicle, contact, pickup, destination, location and status information needed for the Trip and safety. They must not use it for unrelated purposes.
• Payment providers: transaction and account information needed to collect, reconcile, refund or withdraw funds and prevent fraud.
• Service providers: hosting, storage, maps, communications, identity verification, analytics, customer support, security and professional advisers subject to appropriate confidentiality, purpose and security obligations.
• Vehicle owners and businesses: relevant account, vehicle, Trip or payment data where the User acts with their authority or the disclosure is otherwise lawful.
• Authorities and legal recipients: information required by a valid law, court order or lawful regulatory request, or reasonably necessary to establish, exercise or defend legal claims, prevent crime or address a serious safety threat.
• Corporate transactions: limited due-diligence or transfer information in a genuine financing, reorganisation, merger or sale, subject to confidentiality and continued protection.

We do not sell personal data merely for payment. If we introduce a materially different commercial disclosure, we will provide notice and obtain consent where required.

9. Processors and confidentiality

Providers processing personal data for YOYO CARS must act on documented instructions, apply appropriate security, maintain confidentiality, help us address rights and incidents, and return or delete data as contractually and legally required. We assess providers proportionately to the sensitivity and risk of the processing.

10. International processing and transfers

Our infrastructure or providers may process or store data outside Uganda, including in the European Economic Area or another jurisdiction. Before doing so, we use a lawful transfer basis and assess whether the destination and recipient provide protection at least equivalent to Ugandan requirements, or obtain valid consent where that is the appropriate legal route.

Where EU, UK or another applicable law imposes additional transfer requirements, we will use an available lawful mechanism such as an adequacy decision, contractual safeguards or a permitted exception. Information about material transfer safeguards may be requested at privacy@yoyoservices.com, subject to confidentiality and security restrictions.

11. Retention and deletion

We keep identifiable personal data only for as long as necessary for the purpose collected, an active account or Trip, a lawful business function, a contract, a legal retention period, or the establishment, exercise or defence of a claim. Retention is determined by:

• the sensitivity, volume and risk of the information;
• the duration of the account, application, Trip or transaction;
• tax, accounting, payment, transport and regulatory recordkeeping duties;
• fraud patterns, chargeback periods, safety investigations and limitation periods;
• pending complaints, litigation, legal holds or authority requests; and
• whether aggregation or de-identification can satisfy the purpose instead.

Operational account data is generally retained while the account is active. Trip, wallet and financial records are retained for the legally required accounting, tax, payment and claims periods. Precise location, security logs, support records, rejected applications and identity documents are reviewed under shorter, risk-based schedules unless connected with an active account, incident, fraud investigation, dispute or legal obligation.

When the applicable period ends, we delete, securely destroy or de-identify the record so it cannot reasonably identify the person. Deletion from encrypted backups occurs through the normal backup-overwrite cycle; restored data remains subject to the deletion instruction. We may preserve a narrowly scoped record where law requires it or where a documented legal hold applies.

12. Security

We use risk-appropriate technical and organisational safeguards designed to protect confidentiality, integrity and availability. Measures may include access controls, authentication, encryption in transit, restricted administrative privileges, logging, backups, monitoring, vulnerability management, staff confidentiality and incident procedures.

No connected system can be guaranteed absolutely secure. This statement does not remove our duty to apply reasonable safeguards. If a qualifying personal-data breach occurs, we will investigate, contain it, preserve evidence and notify the Personal Data Protection Office and affected people when and within the period required by law.

You can help by securing your device, using unique credentials, refusing requests for passwords, PINs or one-time codes, and reporting suspicious activity promptly.

13. Your rights

Subject to identity verification, the scope of applicable law and lawful exceptions, you may request:

• confirmation of whether we hold your personal data and access to it;
• information about purposes, categories and recipients;
• correction or completion of inaccurate information;
• deletion or de-identification when continued retention is not lawful or necessary;
• cessation of processing based on consent after you object or withdraw consent, unless another lawful basis applies;
• restriction, objection or review of certain processing where applicable;
• a portable copy where applicable and technically feasible; and
• review of a qualifying significant automated decision.

Send a request to privacy@yoyoservices.com. Describe the account and request without emailing passwords, PINs or unnecessary identity-document copies. We may request proportionate proof of identity and may redact another person’s information.

We will respond promptly and, for an access request under Ugandan law, ordinarily within 30 days after receiving sufficient information to verify and locate the data. We may extend, refuse or charge only where and to the extent the law permits, and will explain the lawful reason.

14. Complaints

Please contact us first so we can investigate. You also have the right to complain to Uganda’s Personal Data Protection Office or another competent authority. This Policy and our Terms of Use do not restrict a lawful complaint or judicial remedy.

15. Account closure

Closing an account stops future ordinary use but does not require immediate deletion of every record. We will retain only information supported by the criteria in section 11, including outstanding wallet or payment records, fraud-prevention evidence, legal obligations and unresolved Trips or claims. Unrelated data will be deleted or de-identified when its purpose expires.

16. Marketing and notifications

We may send essential account, security, Trip, payment and legal notices because they are necessary for the service or compliance. Promotional communications are sent only on a lawful basis. You may opt out of marketing without disabling essential service messages. Device notification preferences may be managed in the app or operating-system settings.

17. Cookies and similar technologies

Our website and apps may use essential cookies or local storage for security, sessions, preferences and core operation. Analytics or advertising technologies will be used only with an appropriate lawful basis and notice. Browser or device settings can limit these technologies, but essential functions may then fail. We will provide a consent control where applicable law requires one.

18. Children

The Platform is intended for account holders aged 18 or over. We do not knowingly permit a child to register independently as a Rider or Driver. A lawful adult may arrange transport involving a child only where the service permits it and the adult remains responsible for consent, supervision and compliance with safety rules. If we learn that a child’s personal data was collected without a lawful basis, we will restrict and delete it subject to safety, evidence and legal obligations.

19. Changes to this Policy

We may update this Policy to reflect legal, security, provider or service changes. We will publish the revised date and give reasonable additional notice of a material change. Where a new activity requires consent, posting an update alone will not replace the consent required by law.

20. Contact details