TRAVI MOBILE

Privacy Policy

Privacy Policy


Introduction

Travi Mobile Limited (“Travi,” “we,” or “us”) is committed to respecting your online privacy. This Online Privacy Policy (“Policy”) describes how Travi collects, uses, and shares (i.e., “processes”) the information, including Personal Information, we receive in connection with the use of our website at www.travimobile.com (the “Site”). The term “Personal Information” means any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location/destination data, online identifier, or one or more factors specific to you. Travi Mobile is the controller and is responsible for the Personal Information processed in connection with the use of the Mobile App and the Site. Please read this Policy carefully. By using or accessing the App or Site, or by providing Personal Information to us on or through the App and the Site, you acknowledge that you have read, understand, and agree to the terms and conditions of this Policy. If you do not agree, your choice is not to use the App or the Site.


How to Contact Us

We welcome your comments or questions regarding this Privacy Policy. Please email us at hello@mtravi.com or contact us at the following addresses:

Port Harcourt:

3 Agudama Street, D/Line

Port Harcourt, Rivers State

South South - Nigeria.

Uyo:

9 Inyang Street

Off Calabar – Itu Road

Itam, Uyo – Akwa Ibom State

South South - Nigeria



Information We May Collect From You

We may collect Personal Information from you in a variety of ways, including when you provide it to us voluntarily, through automated data collection technologies like cookies, or by receiving it from other sources. The following sections list the type of information we may collect under each mechanism.



Information that you provide us voluntarily

You may provide us Personal Information voluntarily when you:

• Sign Up: During the authentication process after downloading the mobile app from store, you will be required to supply us your name, phone number, and/or your email.
• Contact us: This occurs, for instance, when you correspond with us by phone, email, or otherwise; when you contact us through the Site, (e.g., by using the Site email request function); or when you provide us with feedback or report a problem with the ICT infrastructures. The information you give us may include your name, email address, phone number, physical address, or other Personal Information you provide to us in your communications with us.
• Register for or Set Up Admin Account: When you register for an account on the admin panel of the Mobile App platform, we collect Personal Information, Company Information, Bank Account, Incorporation Number and other unique email address and password, your name, and other contact information. You may also provide us with additional information when you post comments to our blogs or use other community/public features of the App (“Report Feature”).
• Request or opt in to receive materials: Some features of the Mobile App allow you to voluntarily provide us with Personal Information when you schedule a trip, apply for insurance, complete e-manifest, through the driver’s manifest form or when you “embark on a travel” to and from a given destination, product information, data sheets, and collateral marketing material (collectively, “Materials”).
• Order products: When you order product or services from us, schedule advert or campaign or request quotations from Travi Mobile through forms on the Site, we collect Personal Information that you provide, such as name, email, shipping and billing addresses, and phone number, as well as information about the product or service type, quantity, and frequency of product or service purchase.



Information we collect automatically

We and our third party service providers may use cookies and other automatic data collection technologies to collect information from you as you use the Mobile App and Site, including information about your online activities over time and across third party transport companies, websites or other online services.

We may automatically collect the following information when you access our ICT infrastructure (Mobile Apps and Site):

• Device information, including the type of device you are using; the Internet protocol (IP) address used to connect your computer to the Internet; browser type and version; browser plug-in types and versions; operating system and platform; language preferences; and/or time zone setting.

• Site usage information, including pages you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page; and/or any phone number used to call our customer service number.

• Location information, including physical addresses and other location data. See our Cookie Notice for more information about the automatic data collection technologies we use and the choices you have for opting out.



Cookies

Like most websites, mtravi.com uses “cookies” or other automated data collection technologies to automatically collect information about how Site visitors access, navigate, and use the Site. Travi Mobile Limited uses this information to better understand the use of the Site and to improve our customer experience and the usability of and content on the Site. For more information about our practices in this area, please see our Cookie Notice.



How We Use Your Information

We may process Personal Information for the purposes set out in this Policy only where we have a valid legal ground for doing so under applicable data protection law. The legal ground will depend on the purpose for which we process your Personal Information. We will process your Personal Information for the following purposes as is necessary for the performance of our obligations under our customer terms, or to answer questions or take steps at your request prior to entering those terms:

• To fulfill your requests for product and service or connectivity ;

• To respond to your inquiries or other communications; and

• To carry out our obligations arising from your account with us, or any other contract entered into between you and us, and to otherwise provide you with the information, products, and services that you request from us. We use your Personal Information for the following purposes as is necessary for certain legitimate interests, or where you have given your consent to such processing to the extent required by applicable law (such consent can be withdrawn at any time):

• To provide you with information about other events, products, or services we offer that might be of interest to you, provided you have not opted-out of receiving that information;

• To provide you, or permit selected third parties to provide you, with information about events, products, or services we feel may interest you, provided you have given your consent where required by law;

• To notify you about changes to your account, new version of app, upgrades, the Site’s new pages, or our services;

• To ensure that content from the Site is presented most effectively for you and your computer;

• As required by law or based on our good faith belief that it is necessary to conform or comply with the law or to protect the users of our Mobile App, Admin Panel, Site, products and services or the general public; and

• To otherwise fulfill the purposes for which you have provided your Personal Information or for any other reason with your express consent. We may also combine information we receive from third parties with information you give to us and information we collect about you. We may use this information and any combined Personal Information for the purposes set out above, depending on the types of information we receive.


We may also share with our Processors (as defined under the GDPR) and advertisers, business partners, and other third parties anonymous data in aggregated form about App Usser and Site visitors. For example, we might share that the App users are “x” percent, Site users “y” percent. We have the right to use Anonymous Information for any purpose and in any manner. “Anonymous Information” means information that is not associated with or linked to your Personal Information; Anonymous Information does not, by itself, permit the identification of individual persons. Anonymous Information includes non-personally identifiable data we create from Personal Information by excluding information that makes such data personally identifiable.


If you are based in the European Economic Area (“EEA”) and we collect your Personal Information on our own behalf, we will only process your Personal Information, including sharing it with third parties, for a purpose described above if: (i) you have provided your consent, which can be withdrawn at any time; (ii) the processing is necessary for the performance of a contract to which you are a party; (iii) we are required by law; (iv) it is required to protect your vital interests or those of other persons; or (iv) the processing is necessary for the purposes of our legitimate commercial interests, except where such interests are overridden by your rights and interests.



How We Share Your Information

We may share information that is not your Personal Information without restriction, including aggregate information about App Users or visitors to the Site and information that does not identify any individual.

We may share your Personal Information for the purposes described in this Policy:

• With our affiliates;

• With our service providers who assist us with the customization or upgrade of Mobile App and the Site or otherwise perform support services for us;

• With our Chief Operating Officers, Stakeholders in the transport sector (Nigerian Government and Unions) , sales representatives, dealers, value added resellers, and other third-parties in Travi Mobile distribution channels for their purposes of protecting, marketing and supporting our products;

• To another business entity in the event of a merger, restructuring, acquisition, any other sale or transfer of our assets or liabilities, or any change in ownership control;

• To anyone with your consent; and

• If we have a good faith belief that disclosure is necessary, to: (1) comply with the law or with legal process served on us; (2) protect and defend the rights or property of us, our users or others; (3) act in an emergency to protect someone’s safety; or (4) investigate any violation or potential violation of the law, this Policy, or any other agreement between you and Travi Mobile Limited.



Public Areas

We may display your username and email address (collectively, your “Public Profile”) when you post comments to our App, blogs or use other community features on Public Areas of the App and the Site. Your Public Profile may be available on the Mobile App or Site to other visitors. If you post content to or use Public Areas or send reports, email or other messages to other users of the App and Site, you should be aware that any Personal Information you provide in that regard can be read, collected, or used by other users of the App and Site and could be used to send you unsolicited messages. We are not responsible for the Personal Information you choose to submit in the Public Areas or send to other users.



International Transfers

Travi Mobile is headquartered in the Nigeria. The information you provide to us or that we obtain as a result of your use of Mobile App or Site is collected in Nigeria and subsequently transferred to the any part of the State in the Country where you travel to or to another country in which we have facilities or our affiliates operate or in which we engage service providers or other third parties.



We will not transfer Personal Information relating to individuals within the African continent, to third parties located outside of the African continent without ensuring adequate protection under Nigerian law. Where a third party is located in a country not recognized by the AU as ensuring an adequate level of protection, we will take appropriate steps, such as implementing standard contractual clauses recognized by the AU, to safeguard your Personal Information. By using our Mobile App, visiting the Site or providing Personal Information about yourself, you consent to such transfer and processing of your Personal Information.



Your Information Choices


Communication opt-outs

If you receive materials or other communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us using the information in the Contact Us section in the App or Site.


Should you opt-out of receiving future mailings, we may share your email address or phone number with our Processors to ensure that you no longer receive further communications from the Processors. Despite your indicated email preferences, we may send you notices of updates to our Privacy Policy or other terms for the Mobile App and the Site.



Cookie opt-outs

Please see our Cookie Notice for information about cookie opt-outs.


Do Not Track disclosure

The Site does not respond to “do not track” signals at this time. For a description of “Do Not Track” information for browsers and mobile devices, and information about opt out programs that third party advertising companies participate in, please visit https://travimobile.com/.


Notice to Stakeholders


Your Stakeholders privacy rights (“Non-Disclosure Right”)

For Transport Companies only. We may share your Company Information with others for their travel decision and scheduling, unless you tell us not to. Under Non-disclosure Agreement,” all travelers are permitted to opt-out of such sharing. Please contact us using the information the Contact us section of the App and the Site to opt-out of the sharing of your Company Information with third parties for relevant purposes. We will not share your information after we have received and processed your request. For Transport Unions only. We may share the Personal Information of your officer(s), office addresses, contact information; for quick recovery of loss items and other important enquiries by our App users and Site visitors. We will not share your information after we have received and processed your request.


For Advertisers Only. We may share your location, company information and brand constitution to our App users and Site visitors. We will not share your information after we have received and processed your request of opt-out.


Flagged User Privacy Notice


For Flagged User only. Travi Mobile Limited reserves and have the right to:

• Disclose of your Personal Information that is incorrect or that is submitted erroneously, either with false pretence to commit crime or with intent to cause harm to other travelers on our platform. Within the categories of Personal Information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information. In this regard, you cannot:

• Request and receive a copy of the Personal Information we have collected about you during the prior period of supplying such information.

• Request and receive disclosure of our information sharing practices during the prior period, including a list of the categories of Personal Information given with the category of third party recipients and a list of the categories of Personal Information that we disclosed for a business purpose.

• Request that we not expose your Personal Information to a third party particularly security agents or government agencies and

• Request that we delete (and direct our service providers to delete) your Personal Information subject to certain exceptions.


Retaining Information collected and sources


Travi Mobile Limited can retain, store and process:

• Identifiers such as contact information (your name, address, phone number, email or postal address), Unique Personal Identifiers (such as online identifiers like user account names), an encrypted version of your password, communications. We may collect additional information from suppliers, vendors, or employees including business contact information, phone number, email and postal addresses and titles.

• Sensitive information such as financial and payment information like your credit or debit card information, or Flutter Wave account email address.

• Commercial information such as your transaction histories, insurance coverage, billing and shipping information, and product preferences.

• Electronic network activity information such as the internet protocol (IP) address collected from your computers and mobile devices, and information about what you do online, including your interactions with our other App users and Site and advertisements, through the use of cookies and similar technologies, system logs, and analytics monitoring.

• Inferences we make about you or your interests based on analysis of other information we have collected.

• Geolocation information.

• Audio or video information such as call center recordings or monitoring records from our customer support centers and security video recordings at our facilities.

• Employment, education and professional related information, protected classification information, biometrics (collected from current and prospective employees, contractors, service providers, vendors and suppliers).

• Employment, education and professional related information, protected classification information, biometrics (collected from current and prospective employees, contractors, service providers, vendors and suppliers).


Business purposes for collecting Personal Information

Travi Mobile collects Personal Information in order to operate and grow our business, improve our App and Site, and to offer our or third-party products or services that we think you may find of interest. More specifically, we collect Personal Information for the following business purposes:

• Provide the services and information you have requested from us and notices relating thereto including providing customer and technical support for our services and collecting fees or other amounts owed in connection with the services.

• Verify that you qualify as a registered user, travelers, insured, operator, driver and/or enrollee of a certain package.

• Provide information to you about our products or services and third-party products and services that we think may be of interest to you.

• Provide you with marketing communications and information.

• Analyze, improve, and customize our services including measuring the effectiveness of advertising and internal research on users’ interests and behaviors to better serve our users.

• Administer the Mobile App, Site, Dashboards, Admin platform and services and for internal operations, including troubleshooting, data analysis, testing, research, security, statistical and survey purposes.

• Respond to your inquiries about trip booking and scheduling, travel tips, e-manifest generation and submission, and evaluate user requests on the applications.

• For legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud.

• Internal and external audit requirements, information-security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your state of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions or other agreements; and (d) to protect our rights, privacy, safety, or property, or those of other persons.


Information shared for a business purpose

During the period of our deployment of this services and product to the market, we may disclose the following categories of Personal Information to the following types of third parties for a business purpose.

• Our affiliated companies: We may share your information such as identifiers, commercial information, location, and inferences within our company and our affiliated companies for the purposes of decision making, reporting, management, analysis, administering programs, promoting service offerings and other business purposes.

• Service providers: We may have shared your information such as identifiers, commercial information, location, electronic network activity, and financial information with our service providers who provide us support services such as hosting our App and Site, processing payments, legal and accounting professional services, postal delivery and electronic mail, mobile messages, product delivery, conducting analysis to improve our Mobile App and Site, fulfilling requests you make, managing payments and answering your questions. Service providers only use the information they receive from us for the purposes we hired them for; we don’t allow them to retain, use or otherwise handle the data for their own purposes.

• Service providers: We may have shared your information such as identifiers, commercial information, location, electronic network activity, and financial information with our service providers who provide us support services such as hosting our App and Site, processing payments, legal and accounting professional services, postal delivery and electronic mail, mobile messages, product delivery, conducting analysis to improve our Mobile App and Site, fulfilling requests you make, managing payments and answering your questions. Service providers only use the information they receive from us for the purposes we hired them for; we don’t allow them to retain, use or otherwise handle the data for their own purposes.

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• With Third Parties, including governmental authorities and law enforcement, for legal or compliance purposes: We may share any or all categories of your information where we believe the disclosure is required by law or otherwise necessary to comply with the law, regulatory requirements, requests from public authorities, or to enforce our agreements or policies or protect or defend the rights and property of our customers, the company, our partners or the public (including for fraud or crime prevention purposes).


Selling Personal Information

We do not sell your information for monetary consideration but we may transfer your information to a third party that provides us with services such as helping us with advertising, data analysis and security, which may fall under the definition of “other valuable consideration” which may be considered a ‘sale’. During the period of deployment and operation, we may disclose Identifiers and Electronic Network Activity with third parties such as advertising and analytics providers for a business purpose which falls within the definition of a ‘sale’.


Additional Information


Data retention

We will store your Personal Information, in a form which permits us to identify you, for no longer than is necessary for the purpose for which the Personal Information is processed. We may retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. Consistent with these requirements, we will try to delete your Personal Information quickly upon request.


Data storage and security

We store all your Personal Information on our secure servers. We have commercially reasonable security measures in place to help protect against loss, misuse, and alteration of your Personal Information in our possession. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the App or Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of information transmitted to the App or Site; any transmission is at your own risk. Travi Mobile will contractually require each Processor or other third-party with whom it shares Personal Information to use reasonable measures to protect that Personal Information. However, we cannot monitor these Processors and other third parties to ensure that they comply.


Links to third party infrastructures

We may create links to third party websites, including in the form of widgets (e.g., social share buttons) that enable users to easily share information on another platform, such as a social media platform. The third parties that own these widgets may have access to information about your activities on our App or browsing on the Site where these widgets are placed. We do not evaluate and are not responsible for the privacy practices or content of third-party websites, including the websites of our affiliates, stakeholders, transport companies, relevant agencies that are associated with our operations. We encourage you to review the privacy policies of each link to ensure that you are comfortable with their privacy practices.


Privacy of children

The App or Site is not intended for children under 13 years of age and we do not knowingly collect Personal Information from children under 13. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact the General Manager, Travi Mobile Limited or Data Privacy Officer using the contact information above on our Mobile App or Site.


Changes to This Privacy Policy

We may make changes to this Policy from time to time. Should we make a material change to our information collection and processing practices, we will let you know by updating this Policy and revising the “Last Updated” date. The Privacy Policy in effect at the time we use your Personal Information governs how we may use your information. Your continued use of our App or Site following the posting of any changes to this Policy indicates your acceptance of the new terms.