1. Introduction

ACHRAMS ("we," "our," or "us") is committed to protecting your privacy and personal data in accordance with the Nigeria Data Protection Regulation (NDPR) 2019 and other applicable data protection laws in Nigeria.

This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our airport car hire booking services.

2. Information We Collect

2.1 Personal Information You Provide

For All Users:

• Contact Information: Name, phone number, email address
• Travel Information: Flight details, pickup/drop-off locations, booking preferences
• Special Requirements: Wheelchair access needs, luggage requirements, vehicle size preferences, elderly assistance needs
• Identification: Government-issued ID (for verification purposes when required)

For Drivers:

• Professional Information: FAAN ACHRAM credentials, driver's license, vehicle registration
• Location Data: GPS coordinates for queuing, pickup and drop-off (with your consent)
• Background Check Data: Criminal record verification, NIN verification, employment history

For Passengers:

• Location Data: GPS coordinates for pickup and drop-off (with your consent)
• Trip Details: Destination, estimated and actual fares, trip duration
• Security Information: Security code confirmations, driver verification actions

2.2 Information Collected Automatically

• Location Data: Real-time GPS coordinates during trips (with your consent)
• Device Information: Device type, operating system, browser type, IP address
• Usage Data: Booking history, service preferences, app interactions, queue positions (for drivers)
• Communication Records: Customer support conversations, feedback, ratings, trip alerts

2.3 Information from Third Parties

• Payment Processors: Transaction confirmation for driver wallet funding
• FAAN: Driver verification credentials, airport access authorization, payment gateway transaction records
• Social Media: Profile information if you choose to connect your social media accounts

3. Legal Basis for Processing (NDPR Compliance)

We process your personal data based on the following lawful grounds:

• Consent: You have given explicit consent for specific processing purposes
• Contract Performance: Processing is necessary to fulfil our service agreement with you
• Legal Obligation: We must process your data to comply with Nigerian laws and FAAN regulations
• Legitimate Interest: Processing is necessary for our legitimate business operations, provided your rights are protected

4. How We Use Your Information

4.1 Service Delivery

For Passengers:

• Process and manage your car hire bookings
• Connect you with verified FAAN-approved drivers
• Provide real-time trip tracking and updates
• Send booking confirmations with driver details and security codes
• Direct you to designated FAAN pickup locations
• Process special requirement requests

For Drivers:

• Manage the driver queue system
• Assign trip requests based on availability
• Process wallet funding through FAAN Payment Gateway
• Monitor service quality and performance
• Coordinate with FAAN for credential verification

4.2 Safety and Security

• Verify driver credentials with FAAN
• Generate and manage security codes for driver-passenger verification
• Monitor trip alerts and emergency button activations
• Provide real-time location tracking during trips
• Investigate incidents or complaints
• Prevent fraud and unauthorized access
• Respond to safety concerns promptly

4.3 Communication

• Send booking notifications and updates
• Provide driver and vehicle details to passengers
• Send security codes for trip verification
• Notify drivers of trip requests
• Respond to customer support inquiries
• Provide service announcements
• Send promotional offers (with your consent)
• Communicate trip alerts to relevant authorities

4.4 Improvement and Analytics

• Analyse usage patterns to improve our services
• Monitor queue efficiency and driver availability
• Optimise route recommendations
• Enhance user experience for both passengers and drivers
• Evaluate special requirements fulfilment
• Conduct research and development

5. Data Sharing and Disclosure

We only share your personal information in the following circumstances:

5.1 Service Providers

Between Platform Users:

• To Drivers: Passenger name, phone number, pickup/drop-off locations, special requirements (necessary for service delivery)
• To Passengers: Driver name, photo, phone number, vehicle details, security code (necessary for verification and safety)

External Partners:

• Payment Processors: Driver wallet funding information for transaction processing
• Technology Partners: Excelian Technologies (platform provider and developer)
• FAAN: Driver credentials, trip data, emergency alerts, payment gateway transactions

5.2 Regulatory Authorities

• FAAN: Driver verification, airport access compliance, emergency response coordination, payment gateway oversight
• NITDA: Compliance with NDPR requirements
• Law Enforcement: When legally required or to protect rights and safety, including trip alert responses

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity (you will be notified in advance).

5.4 With Your Consent

We may share your information for other purposes with your explicit consent.

6. Data Security

We implement industry-standard security measures to protect your personal information:

• Encryption: Data transmitted using SSL/TLS encryption
• Access Controls: Limited access to authorised personnel only
• Secure Storage: Data stored on secure servers with regular backups
• Security Codes: Unique verification codes generated for each trip
• Real-time Monitoring: Trip tracking and alert systems for immediate response
• Regular Audits: Periodic security assessments and vulnerability testing conducted by Excelian Technologies
• Staff Training: All employees trained on data protection best practices

Despite our efforts, no system is 100% secure. We encourage you to use strong passwords, verify driver identity using security codes, and protect your account credentials.

7. Data Retention

We retain your personal information only as long as necessary for the purposes outlined in this policy or as required by law:

• Active Account Data: Retained while your account is active
• Booking Records: Retained for 1 year for legal and accounting purposes
• Payment Information (Driver Wallets): Retained per financial regulations (minimum 1 year)
• Communication Records: Retained for 1 year for quality assurance
• Trip Alerts and Safety Records: Retained for 1 year for safety and legal purposes
• Security Codes: Deleted immediately after trip completion
• Marketing Consent: Until you withdraw consent or after 1 year of inactivity

After the retention period, we will securely delete or anonymise your data.

8. Your Rights Under NDPR

As a data subject in Nigeria, you have the following rights:

• 8.1 Right to Access

  Request a copy of the personal data we hold about you.

• 8.2 Right to Rectification

  Request correction of inaccurate or incomplete personal data.

• 8.3 Right to Erasure (Right to be Forgotten)

  Request deletion of your personal data (subject to legal retention requirements).

• 8.4 Right to Restrict Processing

  Request limitation on how we process your data.

• 8.5 Right to Data Portability

  Receive your data in a structured, commonly used format.

• 8.6 Right to Object

  Object to processing based on legitimate interests or for direct marketing.

• 8.7 Right to Withdraw Consent

  Withdraw consent at any time (does not affect prior processing).

• 8.8 Right to Lodge a Complaint

  File a complaint with NITDA if you believe your rights have been violated.

To exercise your rights, contact us at: info@exceliangroup.com.ng

9. International Data Transfers

Your data is primarily stored and processed within Nigeria. If we transfer data outside Nigeria, we ensure:

• Adequate data protection safeguards are in place
• The receiving country has adequate data protection laws
• You are informed and provide consent where required

10. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected data from a minor, please contact us immediately.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Remember your preferences and login status
• Analyse website traffic and app usage
• Improve user experience
• Provide personalized content
• Track real-time trip locations (with consent)

You can manage cookie preferences through your browser settings. Note that disabling cookies may affect functionality, including trip tracking features.

12. Marketing Communications

With your consent, we may send promotional offers and updates via:

• Email
• SMS
• Push notifications (mobile app)
• In-app messages

You can opt out at any time by:

• Clicking "unsubscribe" in emails
• Replying "STOP" to SMS messages
• Adjusting notification settings in the app
• Contacting info@exceliangroup.com.ng

13. Third-Party Links

Our platform may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. Please review their privacy policies separately.

14. Data Breach Notification

In the event of a data breach affecting your personal information, we will:

• Notify NITDA within 72 hours (as required by NDPR)
• Inform affected users without undue delay
• Provide information about the breach and remedial actions
• Take immediate steps to mitigate harm
• Coordinate with FAAN for any airport-related security concerns

15. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in:

• Our practices
• Legal requirements
• Service offerings

We will notify you of material changes by:

• Email notification
• Prominent notice on our website/app
• In-app notification

Continued use of our services after changes constitutes acceptance of the updated policy.

16. Contact Information