Date: 13/02/2023

Version: v4.1

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BACKGROUND:

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SafeBodaunderstands that your privacy is important to you and that you care about howyour personal data is used. We respectand value the privacy of everyone who visits this website or uses ourapplication and will only collect and use personal data in ways that aredescribed here, and in a way that is consistent with our obligations and yourrights under the Data Protection and Privacy Act, 2019 and Regulations.

SafeBodais registered with the Personal Data Protection Office under RegistrationNumber: PDPO-202201-0121.

Pleaseread this Privacy Policy carefully and ensure that you understand it. By usingour site and, or our application, you give your affirmative consent that youhave read and accepted all the terms in this Privacy Policy. If you do not acceptand agree with this Privacy Policy, you must stop using Our Site/application immediately.

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• Definitions and Interpretation

In this Policy the following terms shall have the following meanings:  

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“Account”

means an account required to access and/or usecertain areas and features of Our Site or application;

“Cookie”

means a small text file placed on your computeror device by Our Site when you visit certain parts of Our Site and/or when youuse certain features of Our Site.Details of the Cookies used by Our Site are set out in Part 13, below; and

Site

means our website www.safeboda.comand/or the SafeBoda mobile application downloadable from the app store or playstore or from our website.

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• Information About Us

Our Site and application is operated by Guinness Transporters Limited,a limited liability company registered in Uganda under company number,8001000076656 and that operates in Uganda and Nigeria.

The registeredaddress for Uganda: Block 210, Plot 1704, Kyebando, P.O. Box 71605, Kampala,Uganda

TIN Number: 1008054819

Data Protection Officer:Catherine Kafumbe

Email address:catherine@safeboda.com

Telephone number:0200502050/0323502050

Postal Address: P.O. Box71605 Kampala, Uganda

We are regulated by Kampala Capital City Authority under Trading licensenumber 0006888456.

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• What Does This Policy Cover?

This Privacy Policy appliesto your use of our Site and, or application. Please note that we have nocontrol over how your data is collected, stored, or used by other websiteswhose links may be provided on our website and we advise you to check theprivacy policies of any such websites before providing any data to them.

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• What is Personal Data?

Personal data isdefined as any information relating to an identified or identifiable naturalperson (called a data subject) who can be directly or indirectly identified inparticular by reference to an identifier such as name, an identificationnumber, location data, an online identifier, or to one or more factors specificto the physical, physiological, genetic, mental, economic, cultural or socialidentity of that natural person.

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• What Are My Rights?

As a data subject, you havethe following rights, which we will always work to uphold:

a)           The rightto be informed about our collection and use of your personal data. This PrivacyPolicy should tell you everything you need to know, but you can always contact usto find out more or to ask any questions using the details in Part 14.

b)           The rightto access the personal data we hold about you. Part 12 will tell you how to dothis.

c)           The rightto have your personal data rectified if any of your personal data held by us isinaccurate or incomplete. Please contact us using the details in Part 14 tofind out more.

d)           The rightto be forgotten, i.e., the right to ask us to delete or otherwise dispose ofany of your personal data that we have. Please contact us using the details inPart 14 to find out more.

e)           The rightto restrict (i.e., prevent) the processing of your personal data.

f)            The rightto object to us using your personal data for a particular purpose(s).

g)           The rightto data portability. This means that, if you have provided personal data to usdirectly, we are using it with your consent or for the performance of acontract, and that data is processed using automated means, you can ask us fora copy of that personal data to re-use with another service or business in manycases.

For more information aboutour use of your personal data or exercising your rights as outlined above,please contact us using the details provided in Part 14.

Further information aboutyour rights can also be obtained from the Personal Data Protection Office.

If you have any cause forcomplaint about our use of your personal data, you have the right to lodge acomplaint with the Personal Data Protection Office.

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• What Data Do We Collect?

Depending upon your use of our Site and, or application, we may collect some or all of the following personal and non-personal data including but not limited to;-

• Name;
• Date of birth;
• Gender;
• Address;
• Email address;
• Telephone number;
• Business name;
• Job title;
• Profession;
• Payment information;
• Information about your preferences and interests;
• IP address;
• Web browser type and version;
• Operating system;
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

We use the information you give to;

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1. Identify you
2. Locate you
3. Pair you with a rider
4. Link you to an approved payment system (Safeboda wallet)
5. Improve the service such as saving common destinations
6. Connect services like “Send” and “Share” with your contacts
7. For product research development
8. To provide measurements and analytics
9. Communicate with you (share marketing communications on our products)
10. Generally, improve your user experience.
11. For Legal and Compliance purposes withthe law

• How Do You Use My Personal Data?

Further to clause 6, we useyour data for the necessary performance of a contract with you and because youhave consented to the use of your personal data, or because it is in ourlegitimate business interests to use it. Your personal data may also be usedfor the following purposes:

●       Providingand managing your Account;

●       Providingand managing your access to Our Site and, or application;

●       Personalisingand tailoring your experience on Our Site and, or application;

●       Supplyingour services to you. Your personal details are required in order for us to enter into a contract with you.

●       Personalisingand tailoring our services for you.

●       Communicatingwith you. This may include responding to emails or calls from you.

●       Supplyingyou with information that you have the option to opt-out at any time.

●       For purposes of “KnowYour Customer” or Customer Due Diligence under the law.

We may also use yourpersonal data for marketing purposes, which may include contacting you byemail, telephone, text message or anyother means, with information, news,and offers on our services. You will not be sent any unlawful marketing orspam. We will always work to fullyprotect your rights and comply with our obligationsunder the law, and you will always have the opportunity to opt-out.

Third Parties whose contentappears on Our Site may usethird-party Cookies, as detailed below in Part 13. Please refer to Part 13 formore information on controlling cookies. Please note that we do not control the activities of suchthird parties, nor the data that they collect and use themselves, and we adviseyou to check the privacy policies of any such third parties.

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• How Long Will You Keep My Personal Data?

We store data until it is nolonger necessary to provide our services or until your account is deleted -whichever comes first. This is a case-by-case determination that depends onthings like the nature of the data, why it is collected and processed, andrelevant legal or operational retention needs in accordance with the law.

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• How and Where Do You Store or Transfer My Personal Data?

We will only store ortransfer your personal data to countries that have adequate data protectionstandards/laws or where you have consented to the processing or storing ofpersonal data outside Uganda. We may in certain instances such as for analyticspurposes or for the reasons in 6 and 7 above share your data with externalthird parties, that may be based out of your jurisdiction. In any such case, weshall ensure any such data is transferred securely and following best practicein your jurisdiction.

Data at SafeBoda is storedin renown and secure servers. Data from the SafeBoda applications is stored inAWS Relational Database Service (RDS). SafeBoda uses Postgres SQL as thedatabase engine and all access to the database are confidential and passwordprotected.

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• Do You Share My Personal Data?

We may share your personal data with processors and other companiesin our group and this may include subsidiaries, a holding company or any otherentity that is a party to a merger and/or acquisition of an interest inSafeBoda.

We may sometimes contract with the following data processors tosupply certain services. These may include payment processing, delivery, andmarketing. In some cases, those parties may require access to some or all ofyour personal data that we hold.

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• WizRocket, trading as Clevertap, and based in the USA – the purpose for this is to process information about how customers use the SafeBoda application and optimise user experience. Please find Clevertap’s privacy policy here.

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• Appsflyer, a data processor that helps with data optimization and marketing purposes. Please find Appsflyer’s privacy policy here.

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• Infobip, a data processor that helps with security access to the SafeBoda application. Please find Infobip’s privacy policy here.

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• Trengo, a data processor that helps to process customer communications through WhatsApp, Twitter, Facebook and email. Please find Trengo’s privacy policy here.

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• Twilio, a data processor that helps to manage WhatsAppcommunications. Please find Twilio’s privacy policy Twilio Privacy Notice here.

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• Appruve, a data processor that helps to manage our KYC process. Please find Appruve’s privacy policy here.
  
  
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• StanbicBank through Flexipay, a data processor for the purposes of processing billsand payments. Please find Stanbic Bank’s privacy policy Privacy and security statement | Stanbic Bank here.
  
  
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• Bank of Uganda, as a regulator under the National Payment Systems Act for purposes of Legal Compliance. Please find Bank of Uganda’s Privacy Policy Bank of Uganda| Privacy Policy here.

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• Financial Intelligence Authority, as a regulator under the Anti-Money Laundering Legislation for purposes of Legal compliance. Please find Financial Intelligence Authority’s Privacy Policy FIA Website Privacy Policy| Financial Intelligence Authority here.
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If any of your personal data is required by a processor, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law. Without prejudice, you are advised to read the privacy policies of any processors we may contract.

By using the SafeBoda site/application, You (the User) give to Us (SafeBoda) your consent to collect, use and process your data for the purposes and in the manner indicated herein and in the terms of use.

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• How Can I Control My Personal Data?

We provide you with the ability toaccess, rectify, port and erase your data. To learn more, visit the settings onthe App.

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• How Can I Access My Personal Data?

If you want to know whatpersonal data we have about you, you can ask us for details of that personaldata and for a copy of it (where any such personal data is held). This is knownas a “subject access request”.

All subject access requestsshould be made in writing and sent to the email or postal addresses shown inPart 14. We do not charge for a subject access request but if your request is‘manifestly unfounded or excessive’ (for example, if you make repetitiverequests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within the timelinesprovided under the law. Normally, weaim to provide a complete response, including a copy of your personal datawithin that time. In some cases, however, particularly if your request is morecomplex, more time may be required up to a maximum of three months from thedate we receive your request. You will be kept fully informed of our progress.

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• How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on yourcomputer or device. First-party Cookies are those placed directly by us and areused only by us. We use Cookies to facilitate and improve your experience ofour Site and to provide and improve our services.We have carefully chosen theseCookies and have taken steps to ensure that your privacy and personal data isprotected and respected at all times.

By using our Site, you mayalso receive certain third-party Cookies on your computer or device.Third-party Cookies are those placed by websites, services, and/or partiesother than us.

Before Cookies are placed onyour computer or device, you will be shown a pop-up requesting your consent toset those Cookies. By giving your consent to the placing of Cookies you areenabling us to provide the best possible experience and service to you. Youmay, if you wish, deny consent to the placing of Cookies; however certainfeatures of our Site may not function fully or as intended. You will be giventhe opportunity to allow only first-party Cookies and block third-partyCookies.

Certain features of our Sitedepend on Cookies to function. These Cookies are shown in the table below. Yourconsent will not be sought to place these Cookies, but it is still importantthat you are aware of them. You may still block these Cookies by changing yourinternet browser’s settings as detailed below, but please be aware that ourSite may not work properly if you do so. We have taken great care to ensurethat your privacy is not at risk by allowing them.

The following first-partyCookies may be placed on your computer or device:

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Name of Cookie a8e9740699b2669e9785cceddf8b3c3c

Purpose Session tracker for safeboda.com

Strictly Necessary Yes

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and the following third-party Cookies may be placed on your computer or device:

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Name of Cookie _gid   |  Provider Google Analytics  |  Purpose Used to distinguish users.

Name of Cookie _ga  |  Provider Google Analytics  |  Purpose Used to count and track page views

Name of Cookie _gat  |  Provider Google Tag Manager  |  Purpose Used to store and track conversions

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In addition to the controlsthat we provide, you can choose to enable or disable Cookies in your internetbrowser. Most internet browsers also enable you to choose whether you wish todisable all Cookies or only third-party Cookies. By default, most internetbrowsers accept Cookies, but this can be changed. For further details, pleaseconsult the help menu in your internet browser or the documentation that camewith your device.

You can choose to deleteCookies on your computer or device at any time, however you may lose anyinformation that enables you to access our Site more quickly and efficientlyincluding, but not limited to, login and personalisation settings.

It is recommended that youkeep your internet browser and operating system up-to-date and that you consultthe help and guidance provided by the developer of your internet browser andmanufacturer of your computer or device if you are unsure about adjusting yourprivacy settings.

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• How Do I Contact You?

If you have any questions about this policy, you can contact us as described below.

Email: team@safeboda.com

Telephone: 0200502050/0323502050

Twitter: @SafeBoda

Instagram: @safeboda

Facebook: SafeBoda

• Changes to this Privacy Policy

We may change this Privacy Policy from time to time and in someinstances without notice to you. This may be necessary, for example, if the lawchanges, or we change our business in a way that affects personal dataprotection.

Any changes will beimmediately posted on our Site and, or application and you will be deemed tohave accepted the terms of the Privacy Policy on your first use of our Site and, or application following thealterations. We recommend that you check this page regularly to keepup-to-date.

By your use of our Site and,or application, you, by affirmative action, consent to these terms. Please donot use our Site and, or application or services if you do not consent to theseterms.

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