TALCTECH MOVE PRIVACY POLICY (FOR DRIVERS)

1. 
   INTRODUCTION:
   
   When you use TalcTech Move, 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 (“data”) we collect, how it’s used and shared, and your choices regarding this data.
   
   

2. 
   OVERVIEW:
   
   

I). SCOPE:

This Privacy Policy applies to users of all TalcTech Move Apps and all TalcTech Apps. This Policy describes how TalcTech Industries Limited collects and uses data.

This Policy specifically applies to;

• 
  Drivers: Those who provide transportation to Riders individually via their TalcTech Move Accounts.
  
  

All those subject to this Privacy Policy are referred to as “users” in this Privacy Policy.

Our privacy practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

• 
  For users in Nigeria: TalcTech Move processes the data of users in Nigeria on the grounds that it is necessary to fulfill the terms of our agreements with those users or based on their consent.
  
  

3. 
   DATA COLLECTION AND USES:
   
   

I). THE DATA WE COLLECT:

TalcTech Move collects data; a). provided by users to TalcTech Move, b). created during use of our services, c). from other sources.

TalcTech Move collects the following data from these sources:

1. Data provided by users. This includes:

• 
  Account information: We collect data when users create or update their TalcTech Move accounts, or place orders via guest checkout features. This includes first and last name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information) and user settings (including accessibility settings).
  
  For Drivers, this also includes vehicle or insurance information and emergency contact information.
  

• Background check information (Drivers): This includes information submitted during the Driver application process, such as driver history or criminal record (where permitted by law), license status, known aliases, prior addresses, and right to work. This information may be collected by TalcTech Move service providers.
  

• Identity verification documents and photos: This includes government issued identification such as driver’s license or passports (which may contain identification photos and numbers, date of birth, and gender), and user-submitted photos such as selfies and profile pictures.
  

• Demographic data: We collect demographic data such as birth date/age, gender or occupation when necessary to enable certain features, or provide access to age-restricted products or services.
  

• User content: We collect data (including chat logs and call recordings) when users contact TalcTech Move customer support, provide ratings or feedback for users, restaurants or merchants, use features that enable users to upload content or submit recordings (including in-app audio recordings or dashboard cameras recordings), or otherwise contact TalcTech Move.
  
  

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

• 
  Location data (Driver): We collect precise and approximate location data from Drivers’ mobile devices when the TalcTech Move app is running in the foreground (app open and on-screen) or background (app open but not on-screen).
  
  
  
  
  In addition, precise location data collected from a Driver’s device during a trip is linked to the Rider’s account, even if the rider has not enabled precise location data to be collected from their device. This data is used for purposes such as customer support, fraud detection, insurance, litigation and receipt generation.
  

• Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided; trip details (such as date and time, requested pick-up and drop off addresses or distance traveled); and payment transaction information (such amount charged, and payment method). We also associate a user’s name with that of anyone who uses their promotion code.
  

• Usage data: We collect data about how users interact with our services. This includes access dates and times, app features or pages viewed, browser type, and app crashes.
  

• Device data: We collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.
  

• Communications data: We collect data regarding communications between users that are enabled through TalcTech Move's apps. This includes communication type (phone, text or in-app message), date/time, and content (including recordings of phone calls solely when users are notified of the recording in advance).
  
  

3). Data from other sources. These include:

• 
  Users or others providing information in connection with claims or disputes.
  

• TalcTech Industries Limited's business partners in connection with debit or credit cards issued by a financial institution in partnership with TalcTech Industries Limited to the extent disclosed in the terms and conditions for the card.
  

• Service providers who help us verify users’ identity, background information, and eligibility to work, detect fraud, and screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements.
  

• Insurance, vehicle, or financial services providers for Drivers.
  

• Partner transportation companies (for Drivers who use our services through an account associated with such a company).
  

• Publicly available sources.
  

• Law enforcement officials, public health officials, and other government authorities.
  
  

II). HOW WE USE DATA:

TalcTech Move uses data to enable reliable and convenient transportation, and other products and services. We also use data; a). to enhance the safety and security of our users and services, b). for customer support, c). for research and development, d). to enable communications between users,

e). to send non-marketing communications to users, f). in connection with legal proceedings.

TalcTech Move uses the data we collect:

1. To provide our services. TalcTech Move uses data to provide, personalize, maintain, and improve our services.

This includes using data to:

• 
  create/update accounts.
  

• enable transportation and other services/features, such as:
  

  • 
    using location data to navigate rider pick-ups and order drop-offs, calculate ETAs, and track the progress of rides.
    

  • enabling features that involve data sharing, such as sharing Driver's first name and vehicle information with riders to facilitate pick-ups, or features that enable ETA sharing and fare splitting.
    

  • matching available Drivers to users requesting services, including based on personal data such as location and proximity to other users, and user settings / preferences (such as preferred destinations), and non-personal data such as vehicle type requested.
    

  • enabling accessibility features.
    

• calculating prices and fares, including using location data and trip or order details (such as requested pick-up and drop off addresses). We may also consider non-personal data or factors, including date and time, estimated distance and time, minimum base fares, tolls, taxes and fees, and surge pricing.
  

• process payments, and enable payment and e-money products.
  

• personalize users’ accounts.
  
  

• 
  facilitate insurance, vehicle, invoicing, or financing solutions.
  

• provide users with trip updates, generate receipts, and inform them of changes to our terms, services, or policies.
  

• perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems.
  
  

TalcTech performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, are compatible with such uses, or are necessary for purposes of TalcTech Move’s and its users’ legitimate interests.

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

• 
  verifying users' accounts, identity or compliance with safety requirements.
  
  For example, we review Driver background checks (including criminal history where required or permitted by law) to verify their identities and eligibility to provide transportation services and ride with TalcTech Move.
  

• using customer service information (including reports of safety incidents), device data (e.g., to detect speeding or harsh braking / acceleration), transaction, and usage data to identify potentially unsafe Drivers and driving. This can lead to drivers receiving messages encouraging safer driving, and/or account suspension/deactivation following human review by our staff.
  
  

• 
  using account, device, location, usage, transaction, wireless carrier, and other data, including communications between users and metadata, to prevent, detect, and combat fraud, including by guest users.
  

• using reported incidents, user ratings and other feedback to encourage safe use of TalcTech Move’s platform and compliance with our terms and as grounds for suspending or deactivating users with low ratings.
  

• using Driver's data (such as past trip information and reported incident rates) and rider data (such as account information, cancellation and reported incident rates, current pick-up and drop-off location, past trip information, and ratings information) to predict and help avoid pairings of users that may result in increased risk of conflict. We also avoid pairings where one user has previously given the other a low (e.g., 1 star) rating.
  
  

• 
  using Driver's data to help law enforcement, in the event that a crime was carried out during one of our trips by either a Driver.
  
  

3. Customer support. We use the information we collect (which may include call recordings, chat logs, in-app audio recordings and video call footage) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.

TalcTech Move performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users or for purposes of TalcTech Move’s legitimate interests in monitoring and improving its customer support services.

4. Research and development. We use data for analysis, machine learning, product development, research, and testing. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our services, and develop new services and features. TalcTech Move performs the above activities on the grounds that they are necessary for purposes of TalcTech Move’s legitimate interests in improving and developing new services and features.

5. Enabling communications between users. For example, a Driver may message or call a Rider to confirm a pick-up location, or a Rider may call a Driver to retrieve a lost item. TalcTech Move performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with our users.

7. Non-marketing communications. TalcTech Move may use data to send surveys and other communications that are not for the purpose of marketing the services or products of TalcTech Move or its partners. TalcTech Move performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, or for purposes of TalcTech Move’s and its users’ legitimate interests in informing users about events that may have an impact on their use of TalcTech Move’s services.

8. Legal proceedings and requirements. We use data to investigate or address claims or disputes relating to use of TalcTech Move’s services, to satisfy requirements under applicable laws, regulations, operating licenses or agreements, insurance policies, or pursuant to legal process or governmental request, including from law enforcement. TalcTech Move performs the above activities on the grounds that they are necessary for purposes of TalcTech Move’s legitimate interests in investigating and responding to claims and disputes relating to use of TalcTech Move’s services and features, and/or necessary for compliance with applicable legal requirements.

III). COOKIES AND THIRD-PARTY TECHNOLOGIES.

TalcTech Move and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this Privacy Policy.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements, TalcTech Move 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 ads on our behalf across the internet or for other companies’ products and services on our apps, and to track and report on the performance of those ads. 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.

IV). DATA SHARING AND DISCLOSURE.

Some of TalcTech Move’s services and features require that we share data with other users, or at users’ request or with their consent. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

TalcTech Move may share data:

1. With other users

This includes sharing:

• 
  for Drivers, we may share data with the Riders, 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; period of time since they signed up to be a Driver; contact information; and Driver profile, including compliments and other feedback submitted by past users. For Drivers who self-identify as deaf or hard of hearing via our in-app accessibility settings, we will share that information with the Riders. We also provide Riders with receipts containing information such as a breakdown of amounts charged, Driver first name, photo, and route map. We also include other information on those receipts if required by law.
  
  

3. With TalcTech Industries Ltd's Subsidiaries, Brands and Affiliates.

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

4. With TalcTech Move service providers and business partners.

These include the third parties, or categories of third parties, listed below. Where a third party is identified, please see their linked privacy notices for information regarding their collection and use of personal data.

• 
  payment processors and facilitators, including Flutterwave and Paystack.
  

• background check, identity verification and risk solutions providers.
  

• cloud storage providers.
  

• customer support platform and service providers.
  

• Google, in connection with the use of Google Maps in TalcTech Move’s apps.
  

• social media companies, including
  

• marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness.
  

• research partners, including those performing surveys or research projects in partnership with TalcTech Move or on TalcTech Move's behalf.
  

• service providers that assist TalcTech Move to enhance the safety and security of TalcTech Move apps and services.
  

• service providers that provide us with artificial intelligence and machine learning tools and services.
  

• accountants, consultants, lawyers, and other professional service providers.
  

• insurance and financing partners.
  

• insurance companies, in connection with insurance claims made or reported by a user relating to TalcTech Move’s services, and for the purpose of adjusting or handling the insurance claim.
  

• airports.
  

• third-party vehicle suppliers, including fleet and rental partners.
  
  
  
  
  
  
  

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

TalcTech Move may share users’ data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, insurance policy, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing 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), insurance companies, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect TalcTech Industries Limited’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. In the event of a dispute relating to use of another person’s credit card, we may be required by law to share a user’s data, including trip or order information, with the owner of that credit card.

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

V). DATA RETENTION AND DELETION.

TalcTech Move retains user data for as long as necessary for the purposes described above. Users may request account deletion through the TalcTech Move apps.

TalcTech Move retains user data for as long as necessary for the purposes described above, which varies depending on data type, the category of user to whom the data relates, the purposes for which we collected the data, and whether the data must be retained after an account deletion request for the purposes described below.

For example, we retain data:

• 
  for the life of users’ accounts if such data is necessary to provide our services. E.g., account data.
  

• for defined periods as necessary for purposes of safety or fraud prevention. E.g., we retain incomplete Driver applications for 1 year, and rejected Driver applications for 5 years.
  
  

Users may request deletion of their account through the Privacy menus in the TalcTech Move app. Following an account deletion request, we delete the user’s account and data, except as necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account (such as an outstanding credit or an unresolved claim or dispute). For Drivers, this generally means that we retain certain of their data for as long as necessary for actual or potential tax, litigation, or insurance claims.

4). UPDATES TO THIS PRIVACY POLICY.

We may occasionally update this Privacy Policy. If we make significant changes, we will notify users in advance of the changes through the TalcTech Move apps or through other means, such as texts or emails. We encourage users to periodically review this Privacy Policy for the latest information on our privacy practices.

Use of our services after an update constitutes CONSENT to the updated Privacy Policy to the extent permitted by law.