PRIVACY POLICY FOR PASSENGERS
This Privacy Policy informs you about how we protect and manage your personal data. It
explains the types of information we collect, how we use it to provide you with transportation
services, and your rights regarding your data. It also outlines the choices and controls
available to you. We are committed to safeguarding your privacy in compliance with data
protection laws.
Enviable Transport Services is the sole controller of your personal data, unless otherwise
stated. Our postal address is:
26 Finbarrs Road
Umuahia 440436
Nigeria
We have appointed a Data Protection Officer (DPO) to oversee our data protection practices.
You can contact the DPO at privacy@ets.com.ng or via the postal address above. Please mark
any correspondence with “Data Protection Officer.”
1. INTRODUCTION
“Us” or “we” refers to Enviable Transport NIG LTD, a private limited company registered
under the laws of Nigeria with registration code 1680164. “You” or “your” refers to the
passenger or rider who uses our transportation services via the Enviable app.
2. INFORMATION WE COLLECT
We only collect data necessary to provide our services effectively. This includes:
2.1. Contact Details: Name, phone number, and email address. Some services may
require additional information, such as a home address.
2.2. Profile Information: Profile picture, saved addresses, language, and communication
preferences. Certain services may also require a valid ID.
2.3. Geolocation: Pickup location, trip progression, and destination.
2.4. Payment Information: Details of charges and payment methods.
2.5. Communication Records: Interactions with customer service.
2.6. Device Information: Limited data like IP address.
2.7. Service Usage Data: Journey details, times, and driver-assessed behaviour.
2.8. User-Generated Content: Photos of parked vehicles and other submissions.
3. HOW WE USE YOUR INFORMATION
We use your personal data to:
3.1. Connect You with Drivers: Facilitate ride-hailing and vehicle hire services.
3.2. Navigate Your Journey: Utilize geolocation for efficient pickups and drop-offs.
3.3. Ensure Service Quality: Use location data to address service issues and maintain
our fleet.
3.4. Optimize App Performance: Notify you of updates and ensure account security.
3.5. Process Payments: Handle transactions for our services.
3.6. Maintain Standards: Use feedback and usage data to ensure safety and quality.
3.7. Communicate Important Information: Send receipts, updates, and service
notifications.
4. LEGAL BASIS
We process your personal data based on:
4.1. Contractual Necessity: To provide the services you request.
4.2. Legitimate Interests: For business operations, fraud prevention, and network
security.
4.3. Legal Compliance: To fulfill legal obligations or respond to lawful requests.
4.4. Vital Interests: In emergencies to protect you or others.
4.5. Consent: Where you have provided explicit consent for specific purposes.
Refusal to provide certain data may prevent us from fulfilling our obligations or providing
our services.
5. INFORMATION SHARING AND DISCLOSURE
We share your data only when necessary and with trusted partners:
5.1. With Drivers: For ride-hailing services, drivers see passenger details.
5.2. Post-Service Communication: Drivers retain access to passenger details for a
limited time to resolve issues.
5.3. Anonymized Feedback: Passenger ratings are anonymized.
5.4. Legal Obligations: We comply with court orders and legal requests where
applicable.
6. SECURITY AND ACCESS
Personal data is stored securely in Amazon Web Services data centres. Access to data is
restricted to the following:
6.1. To authorized personnel for service-related purposes.
6.2. For research and scientific purposes, data is anonymized to protect individual
identities.
7. YOUR RIGHTS AND CONTROLS
You have control over your personal data:
7.1. Access: View your data through the Enviable app.
7.2. Rectification: Correct inaccurate or incomplete information.
7.3. Restriction: Request restricted processing under certain circumstances.
7.4. Objection: Object to processing based on legitimate interests.
7.5. Data Portability: Request transfer of your data to another organization or to
yourself.
8. CHILDREN’S PRIVACY
Our services are not intended for individuals under 18. We do not knowingly collect data
from minors. Parents and guardians can request deletion of data if their child has provided it.
9. CHANGES TO PRIVACY POLICY
We may revise this Privacy Policy to reflect updates in our practices or changes in legal
requirements. When significant changes are made, we will notify users by posting the
updated policy on our website or through other communication channels. By continuing to
use our services after these updates are communicated, you acknowledge and accept the
revised terms of the policy.
10. YOUR RIGHT TO ACCESS
You can access your personal data via the Enviable app. You may request for copies of your
personal information, subject to some exemptions, such as when we have to balance the rights of
others.
11. YOUR RIGHT TO RECTIFICATION
You can access and update your personal data via the Enviable app. You have the right to ask us
to rectify information you think is otherwise inaccurate. You also have the right to ask us to
complete information you think is incomplete.
12. ACCOUNT DELETION
To delete your account, contact our support team. Account deletion results in loss of access to
services: preferences, remaining account balances and related records will be permanently
removed. You will also be opted out of communications, except for administrative emails
related to the deletion process.
Note: Uninstalling the Enviable app does not delete your data. If the app is inactive for three
years, we will reach out to confirm if you wish to keep your account active. If no response is
received within a reasonable time, the account and data will be deleted unless required for
any purpose mentioned earlier in this Privacy Policy.
13. YOUR RIGHT TO RESTRICTION OF PROCESSING
You have the right to request that we restrict the processing of your personal information under
specific circumstances. This means that while the restriction is in place, we may only use your
data for limited purposes, such as handling legal claims, fulfilling legal obligations, or protecting
your rights or the rights of others.
14. YOUR RIGHT TO OBJECT TO PROCESSING
You can object to data processing based on legitimate interests. You may also object to any
automated decision made and request a human review.
15. YOUR RIGHT TO DATA PORTABILITY
You have the right to request for transfer of your data to another organization or to yourself.
This applies to only data you provided to us.
16. DATA RETENTION
We retain data only as long as necessary for the purposes described in this Privacy Policy.
We have varying retention periods for different types of data; the transportation service it
relates to and the purpose for which it was collected.
16.1. Personal and Account Data: Retained as long as your account is active.
16.2. Financial Data: Retained for three years and where required for accounting purposes will be retained for seven years
16.3. Data Related to Crime: Retained as long as necessary or as required by law.
16.4. Dispute Data: Retained until resolved.
16.5. Journey History: Retained for three years, then anonymized.
17. DIRECT MARKETING
We may send direct marketing messages to your e-mail address and/or phone number when
you consent, or on a soft opt-in basis. We may personalize direct marketing messages using
the information on how you use ours services, such as how frequently you use the Enviable
app and your transportation preferences.
If you no longer wish to receive direct marketing messages, you may unsubscribe at any time
using the link in our emails, or opt-out in the profile section of the Enviable app.
18. AUTOMATED DECISION MAKING
We use automated decision-making for certain processes, such as issuing warnings or service
suspensions. You have the right to contest such decisions and opt for a human review.
19. CONTACT US
For privacy-related inquiries, disputes, or data protection concerns, contact our customer
support at info@ets.com.ng or our Data Protection Officer at privacy@ets.com.ng.
20. SUMMARY
We take your privacy seriously and are committed to protecting your data. This policy will be
updated as needed to ensure compliance and transparency.
