Privacy Policy

Effective Date: March 5, 2026

1. Introduction

Welcome to Dele ("we," "our," or "us"). We are committed to protecting your privacy and ensuring transparency about how we collect, use, and safeguard your personal information. This Privacy Policy explains our practices regarding data collection and use in compliance with Nigerian Data Protection Regulation (NDPR) 2019 and international standards.

2. Information We Collect

Personal Information:

• Account Information: Name, phone number, email address, password (encrypted)
• Profile Data: Profile photo, preferences, membership tier
• Identity Verification: Government-issued ID, driver's license (for drivers only)

Location Data:

• Precise Location: GPS coordinates when booking or during rides
• Pickup/Dropoff Addresses: Saved locations for convenience
• Real-Time Tracking: During active rides only (with your permission)

Payment Information:

• Payment methods (credit/debit cards, bank accounts)
• Transaction history
• Note: Card details are processed securely by Paystack (PCI-DSS Level 1 certified). We never store full card numbers.

Usage Data:

• Ride history (pickup, dropoff, fare, duration)
• App interactions, features used
• Device information (model, OS, app version)
• IP address, browser type

3. How We Use Your Information

We use your data to:

• Provide Services: Match riders with drivers, process payments, enable P2P transfers
• Safety & Security: Verify identities, prevent fraud, investigate incidents
• Customer Support: Respond to inquiries, resolve disputes
• Improve Experience: Personalize recommendations, optimize routes
• Communications: Send ride updates, promotions (opt-out available)
• Legal Compliance: Tax reporting, regulatory requirements
• Research & Analytics: Aggregate data for business insights (anonymized)

4. Data Sharing & Disclosure

We do NOT sell your personal data. We share information only with:

Service Providers:

• Drivers: Name, phone number (masked), pickup/dropoff location (for ride fulfillment)
• Payment Processors: Paystack (for secure payment processing)
• SMS Provider: Termii (for OTP and ride notifications)
• Map Services: Google Maps (for routing and geocoding)

Legal & Safety:

• Law enforcement (when legally required)
• Courts (in response to subpoenas)
• Government agencies (tax, regulatory compliance)
• Emergency responders (in life-threatening situations)

Business Transfers:

• In case of merger, acquisition, or sale of assets (you will be notified)

5. Data Security

We implement industry-standard security measures:

• Encryption: HTTPS/TLS for all data transmission
• Password Protection: Bcrypt hashing (industry-standard)
• End-to-End Encryption: P2P payment notes (RSA-4096 + AES-256)
• Access Controls: Role-based permissions, multi-factor authentication for staff
• Regular Audits: Security reviews, penetration testing
• Data Minimization: Collect only necessary information

Note: No system is 100% secure. While we strive to protect your data, we cannot guarantee absolute security against all threats.

6. Your Rights & Choices

Under NDPR and international standards, you have the right to:

• Access: Request a copy of your personal data
• Correction: Update inaccurate or incomplete information
• Deletion: Request account and data deletion (subject to legal retention)
• Portability: Receive your data in machine-readable format
• Object: Opt-out of marketing communications
• Restrict Processing: Limit how we use your data
• Withdraw Consent: Revoke location or notification permissions

7. Location Data Details

When We Collect Location:

• When you open the app (to show nearby drivers)
• When booking a ride (pickup/dropoff)
• During active rides (real-time tracking for safety)

When We DON'T Collect Location:

• When app is closed (no background tracking without explicit permission)
• When location services are disabled

Control Your Location:

• iOS: Settings → Privacy → Location Services → Dele → "While Using"
• Android: Settings → Apps → Dele → Permissions → Location → "Only while using the app"

Note: Disabling location will prevent ride booking functionality.

8. Children's Privacy

Dele is not intended for users under 18 years old. We do not knowingly collect data from minors. If we discover we have collected information from a child, we will delete it immediately. Parents/guardians who believe their child provided data should contact us at privacy@dele.cx.

9. Data Retention

We retain data for:

• Active Accounts: Duration of account + 1 year after deletion
• Ride History: 7 years (tax and legal compliance requirements)
• Payment Records: 7 years (financial regulations)
• Chat Logs: 90 days (customer support)
• Location Data: 1 year (anonymized after 30 days)

After retention periods, data is securely deleted or anonymized.

10. International Transfers

Your data is primarily stored in Nigeria. If transferred internationally (e.g., to cloud service providers), we ensure:

• Adequate data protection measures (GDPR-equivalent safeguards)
• Standard Contractual Clauses with processors
• Compliance with NDPR cross-border transfer requirements

11. Cookies & Tracking

Essential Cookies: Authentication, session management (necessary for app function)

Analytics: Aggregate usage data (anonymized, no personal tracking)

Third-Party Cookies: We do NOT use third-party advertising or tracking cookies

Control cookies: Browser settings or in-app preferences

12. Third-Party Services

We integrate with:

• Paystack: Payment processing (Privacy Policy)
• Google Maps: Mapping and routing (Privacy Policy)
• Termii: SMS delivery (Privacy Policy)

These services have their own privacy policies. We are not responsible for their practices.

13. Marketing Communications

We may send:

• Transactional: Ride updates, receipts (cannot opt-out)
• Promotional: Offers, new features (opt-out available)

Opt-out: Settings → Notifications → Promotional or reply "STOP" to SMS

14. Changes to This Policy

We may update this policy periodically. Changes will be:

• Posted here with a new effective date
• Notified via in-app message (for material changes)
• Emailed to registered users (for significant changes)

Continued use after changes constitutes acceptance.

15. Nigeria Data Protection Regulation (NDPR) Compliance

Dele complies with NDPR 2019. We are registered with the National Information Technology Development Agency (NITDA).

Data Protection Officer (DPO):

• Email: dpo@dele.cx
• Responsibilities: Oversee compliance, handle data subject requests

File Complaints:

• NITDA: https://nitda.gov.ng
• Email: info@nitda.gov.ng

16. Contact Us