I. Introduction

When you use ALEFEXPRESS, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data (“data”) we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

II. Overview

Scope

this notice applies to users of ALEFEXPRESS’s services anywhere in Kenya, including users of ALEFEXPRESS apps, websites, features or other services.

This notice describes how alefexpress collect and use data. This notice applies to all our users. This notice specifically applies to:

• Riders: individuals who request or receive transport and related services via their account
• Drivers: individuals who provide transport to Riders individually
• Order recipients: individuals who request or receive food or other products and services for delivery or pick-up via their account. This includes individuals who use guest checkout features to access delivery or pick-up services without creating and/or logging in to their account
• Delivery persons: individuals who provide delivery services

All those subject to this notice are referred to as “users” in this notice.

Our privacy practices are subject to applicable laws in the Republic of Kenya. This means that we engage in the practices described in this notice only if permitted under the laws of the Republic of Kenya.

B. Data controller and transfer

ALEFEXPRESS operates, and processes personal data, wherever and whenever you travel, your data travels with you so we can offer you a seamless experience. We also respect your data protection rights whether you are in the Republic of Kenya or elsewhere.

We do so in order to fulfil our agreements with all our users, or based on users’ instructions or prior consent, order to respond to a request for personal data from a law enforcement agency. To provide additional safeguards to these data transfers, AALEFEXPRESS applies a robust internal procedure for processing these requests.ALEFEXPRESS only discloses personal data to law enforcement agencies in a manner that is consistent with the regulatory requirements of applicable laws, such as the ODPC.

To help provide equivalent data protection wherever you use our services, ALEFEXPRESS has implemented the following measures :

• policies and procedures to limit access to, and the processing of, personal data for defined purposes;
• specific training of personnel responsible for managing personal data;
• robust protection of data while it is in transit between ALEFEXPRESS apps and our servers, and when the data is processed on our servers. This includes encryption and the use of pseudonymised data to help protect users’ full identity against unauthorised disclosure.

For your convenience, the exercise of your data protection rights can be directed to ALFEXPRESS via any of the designated channels mentioned above, and will be handled centrally on behalf of the relevant controller. Questions, comments and complaints about ALEFEXPRESS’s data practices can be submitted through all our communication channels. You may also use this form to submit a question to ALEFEXPRESS’s Data Protection Officer and to ask us for a copy of the Standard Contractual Clauses or other transfer mechanisms in place for the data processing activity of your inquiry.

III. Data collections and uses

A. The data we collect

ALEFEXPRESS collects data:

• provided by users to ALEFEXPRESS, such as during account creation
• created during use of our services, such as location, app usage and device data
• from other sources, such as other users or account owners, business partners, vendors.

ALEFEXPRESS collects the following data:

1. Data provided by users. This includes:

• User profile information: We collect data when users create or update their accounts, or place orders via guest checkout features. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driving licence and other government-issued documents (which may include identification numbers as well as date of birth, gender and photo). This also includes vehicle or insurance information of drivers and delivery persons, emergency contact information, user settings and evidence of health or fitness to provide services using ALEFEXPRESS apps.
• Enhanced background check information (drivers and delivery persons): This includes information submitted during the driver/delivery person application process, such as driver history or criminal record (through Good conduct certificates provided by the DCI), licence status, known aliases and prior addresses, and right to work.
• Identity verification photos: This includes photos of users (such as selfies) and/or their government-issued identifications (such as driving licences or Identity cards). Please see the section titled “How we use personal data” for more information regarding how user photos are used for safety and security purposes, including identity verification.
• Demographic data: We may collect demographic data about users, such as date of birth/age, gender or occupation, when required for certain ALEFEXPRESS services or programmes, such as ALEFEXPRESS Cash, alcohol deliveries or safety features that allow women users to set a preference to provide or receive services to/from other women (“Women Rider Preference”).
  We may also infer demographic data from other data collected from users. For example, we may infer a user’s gender based on their first name to enable safety features, such as the Women Rider Preference, or to display personalised ads for third-party products or services. See the section titled “How we use personal data” below for more information.
  We may also collect demographic data through user surveys.
• User content: We collect the data submitted by users when they contact ALEFEXPRESS customer support ; provide ratings or feedback for other users, restaurants or merchant. This may include photographs, or audio or video recordings submitted by users in connection with a customer support request. This also includes metadata relating to the method you use to communicate with ALEFEXPRESS. The contents of photos and recordings submitted by users are subject to ALEFEXPRESS guidelines.

Data from other sources. These include:

• users participating in our referral programmes. For example, when a user refers another person, we receive the referred person’s data from that user.
• ALEFEXPRESS account owners who request services for or on behalf of other users (such as friends or family members), or who enable other users to request or receive services through their business accounts
• users or others providing information in connection with claims or disputes.
• vendors who help us verify users’ identity, background information and eligibility to work, or who screen users in connection with sanctions, anti-money laundering or know-your-customer requirements.
• insurance, vehicle or financial services providers for drivers and/or delivery persons.
• partner transport companies (for drivers or delivery persons who use our services through an account associated with such a company).
• publicly available sources.
• law enforcement officials, public health officials and other government authorities.

B. How we use personal data

ALEFEXPRESS uses data to enable reliable and convenient transport, delivery and other products and services. We also use such data:

• to enhance the safety and security of our users and services
• for customer support
• for research and development
• to enable communications between users
• for marketing and advertising
• to send non-marketing communications to users
• in connection with legal proceedings

ALEFEXPRESS does not sell or share user data with third parties for purposes of their direct marketing, except with users’ consent.

We use the data we collect:

1. To provide our services. we uses data to provide, personalise, maintain and improve our services.

This includes using data to:

• create/update accounts.
• enable transport, delivery and other services/features, such as:
• using location data to navigate rider pick-ups and order drop-offs, calculate ETAs and track the progress of rides or deliveries.
• features that involve data sharing, such as sharing a driver’s first name and vehicle information with riders to facilitate pick-ups, user profile and trip details for ETA sharing and fare splitting, and user ratings and compliments.
• match available drivers and delivery persons to users requesting services. Users can be matched based on availability, location/proximity, user settings/preferences and other factors such as likelihood to confirm a trip based on their past behaviour or preferences.
• features that involve account linking, such as linking of email loyalty reward programs.
• dynamic pricing, in which the price of a trip, or the delivery fee for food delivery orders, is determined based on factors such as estimated time and distance, predicted route, estimated traffic and the current number of users requesting or providing services.
• process payments.
• personalise users’ accounts.
• provide users with trip or delivery updates, generate receipts and inform them of changes to our terms, services or policies.
• perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems.
  ALEFEXPRESS performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users, or on the grounds that they are necessary for purposes of ALEFEXPRESS’s and its users’ legitimate interests.

2. Safety and security. We use data to help maintain the safety, security and integrity of our services and users. This includes:

• verifying users’ identity and eligibility to provide transport or deliveries, including through reviews of enhanced background checks, to help prevent use of our services by unsafe drivers and/or riders.
• using data from drivers’ or delivery persons’ devices to detect unsafe driving behaviour such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. We also use data from delivery persons’ devices to verify the type of vehicles they used to provide deliveries.
• using driver location information, and communications between riders and drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine that a driver is delaying a rider pick-up in order to induce a cancellation, we will not charge the rider a cancellation fee and will adjust the amounts paid to the driver to omit such a fee.
• using driver location information, and communications between riders and drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine that a driver is delaying a rider pick-up in order to induce a cancellation, we will not charge the rider a cancellation fee and will adjust the amounts paid to the driver to omit such a fee.
• using user ratings, reported incidents and other feedback to encourage compliance with our guidelines as grounds for deactivating users with low ratings.
• using driver data (such as location, ratings and gender where legally permitted) and rider data (such as ratings, origin and destination) to help avoid pairings of users that may result in increased risk of conflict (for instance, because one user previously gave the other a one-star rating).
• sharing user’s name, location, phone number, vehicle details and other relevant information with third-party companies that support the management and de-escalation of interpersonal conflicts that may occur between users while on a trip or in the process of making a delivery.
  ALEFEXPRESS performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users, and/or for purposes of the legitimate safety and security interests of app, our users and members of the general public.

3. Customer support. ALEFEXPRESS uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.
ALEFEXPRESS performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users or for purposes of ALEFEXPRESS’s legitimate interest in monitoring and improving its customer support services.

5. Enabling communications between users. For example, a driver may message or call a rider to confirm a pick-up location, a rider may contact a driver to retrieve a lost item, or a restaurant or delivery person may call an order recipient with information about their order.

6. Marketing and Advertising. ALEFEXPRESS uses data (other than Guest Users’ data) to market its services and those of partners. This may include:

Sending emails, text messages, push notifications and in-app messages or other communications marketing or advertising products, services, features, offers, promotions, sweepstakes, news and events.

This may include using location, trip and order history, and usage data to send marketing communications that are personalised based on users’ observed or inferred interests and characteristics. For example, we may send push notifications suggesting a user’s favourite destinations or merchants, or in-app messages offering discounts or promos for products or merchants similar to those a user has previously ordered or ordered from.

Displaying advertising on third-party apps or websites. This includes using location, trip and order history, and usage data, and sharing hashed email addresses and device or user identifiers with advertising partners (such as Facebook and TikTok), to personalise such ads to users’ interests.

Measuring the effectiveness of ads, and of third-party ads displayed in our apps or in connection with our services.
We do not sell or share users’ data with third parties for purposes of their direct marketing or advertising, except with users’ consent. However, in order to display and measure the effectiveness of personalised third-party ads, we may share data with advertising intermediaries, such as advertising or device identifier, hashed email address, IP address, approximate location, and current trip or order information. These intermediaries may use or share the data for their own purposes.

7. Non-marketing communications. ALEFEXPRESS may use data to send surveys and other communications that are not for the purpose of marketing the services or products of ALEFEXPRESS or its partners. We may also send users communications regarding elections, ballots, referenda and other political processes that relate to our services
ALEEFEXPRESS performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users, or for purposes of ALEEFEXPRESS and its users’ legitimate interests in informing users of events that may have an impact on their use of our services.

8. Legal proceedings and requirements. We use data to investigate or address claims or disputes relating to use of our services, to satisfy requirements under applicable laws, regulations, or operating licences or agreements, or pursuant to legal process or governmental request, including from law enforcement.

we perform the above activities on the grounds that they are necessary for purposes of ALEFEXPRESS legitimate interests in investigating and responding to claims and disputes relating to use of our services and features, and/or necessary for compliance with applicable legal requirements.

C. Cookies and third-party technologies

ALEFEXPRESS uses cookies and other identification technologies on our apps, websites, emails and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media and advertisements. ALEFEXPRESS uses cookies and similar technologies for purposes such as:

• authenticating users
• remembering user preferences and settings
• determining the popularity of content
• delivering and measuring the effectiveness of advertising campaigns
• analysing site traffic and trends, and generally understanding the online behaviours and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the internet and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

Please see NOTICE for more information regarding the use of cookies and other technologies described in this section.

D. Data sharing and disclosure

Some of services and features require that we share data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries and partners, for legal reasons or in connection with claims or disputes.

ALEFEXPRESS may share data:

1. With other users

This includes sharing:

• riders’ first name, rating, and pick-up and/or drop-off locations with drivers.
• riders’ first name with other riders in a car sharing trip. Riders in car sharing trips may also see the drop-off location of the other riders.
• order recipients’ first name, delivery address and order information with the restaurant or merchant and, for order deliveries, with the delivery person. We may also share ratings and feedback, or other information to the extent required by law, with the restaurant or merchant and, for order deliveries, the delivery person.
• for drivers and delivery persons, we may share data with the rider(s), order recipient(s) and restaurants or merchants, including name and photo; vehicle make, model, colour, number plate and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; period of time since they signed up to be a driver or delivery person; contact information; and driver or delivery person profile, including compliments and other feedback submitted by past users.
  We also provide riders and order recipients with receipts containing information such as a breakdown of amounts charged, driver or delivery person’s first name, photo and route map. We also include other information on those receipts if required by law.
• for those who participate in ALEEFEXPRESS’s referral programme, we share certain data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral reward.

2. At the user’s request

This includes sharing data with:

• Other people at the user’s request. For example, we share a user’s ETA and location with a friend when requested by that user, or a user’s trip information when they split a fare with a friend.
• business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, ALEFEXPRESS may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurants, merchants or other business partners and their users in connection with promotions, contests or specialised services.
• Emergency services: We offer features that enable users to share their data with police, fire and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”.

3. With the general public

Questions or comments from users submitted through public forums such as blogs and social media pages may be viewable by the public, including any data included in the questions or comments submitted by a user.

4. With the account owner

If a user receives services through an account owned by another party, we may share their trip or order information, including location data, with the owner of that account. This occurs, for example, when:

• a rider uses their employer’s ALEFEXPRESS for Business profile
• a driver or delivery person uses an account owned by or associated with an partner transport company or restaurant
• a rider takes a trip or a delivery recipient receives an order arranged by a friend or under a family profile

5. With service providers and business partners

These include:

• payment processors and facilitators
• enhanced background check and identity verification providers
• cloud storage providers
• Google, in connection with the use of Google Maps in ALEEFEXPRESS’s apps (see Google’s privacy policy for information on their collection and use of data)
• marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers and other service providers to reach or better understand our users and measure advertising effectiveness
• consultants, lawyers, accountants and other professional service providers
• insurance and financing partners
• third-party vehicle suppliers, including fleet and rental partners

7. For legal reasons or in the event of a dispute

ALEFEXPRESS may share users’ data if we believe it’s required by applicable law, regulation, operating licence or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing data with law enforcement officials, public health officials, other government sharing data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company.

8. With consent

We may share a user’s data other than as described in this notice if we notify the user and they consent to the sharing.

E. Data retention and deletion

we retain user data for as long as necessary for the purposes described above.

We may retain user data for as long as necessary for the purposes described above. The period for which we retain user data is determined by the type of data, the category of user to whom the data relates and the purposes for which we collected the data.

The length for which we retains user data may further be determined by legal and regulatory requirements, purposes of safety, security and fraud prevention, or by issues relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.

For example:

• We retain user data of riders and order recipients that is processed in order to provide our services, such as the user profile information and credentials, for the lifetime of the user’s account.
• We retain certain categories of data of all users for a period unrelated to the lifetime of the user’s account to avoid fraudulent use of the app. The period for which the data is retained will be determined by the necessity of the data for purposes of safety, security and fraud prevention, as well as legal and regulatory requirements. Examples include incomplete driver applications, which are retained for 1 year, and rejected driver applications and customer service communications on safety incidents, which are retained for 4 years.
• Pursuant to legal and regulatory requirements, for purposes of safety, security and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute, we may retain certain categories of data after the deletion of the user’s account, such as user profile information and vehicle and tax data. This generally means that we retain their account and data for 3 years after a deletion request.

Users may request deletion of their accounts at any time. We may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.

Users may request deletion of their account at any time through the Settings > Privacy menus in the app, or through our website t, we deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements; for purposes of safety, security and fraud prevention; or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers and delivery persons, this generally means that we retain their account and data for the applicable statutory retention period after a deletion request. For riders and order recipients, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.

IV. Choice and transparency

ALEFEXPRESS enables users to access and/or control data that ALEFEXPRESS collects, including through:

• privacy settings
• device permissions
• in-app ratings pages
• marketing choices

ALEFEXPRESS also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts or request that ALEFEXPRESS restrict its processing of user data.

A. Privacy settings

The Settings > Privacy menu in the app allows riders and order recipients to set or update their preferences regarding location data collection and sharing, emergency data sharing and notifications. Our PRIVACY SETTINGS is also available in web version.

• Location data collection (riders and order recipients)
  Riders and order recipients can enable/disable us to collect location data from their mobile devices through their device settings, which can be accessed via the Settings > Privacy > Location menu.
• Share Live Location (Riders)
  Riders can enable/disable ALEEFEXPRESS to share their real-time location data from their mobile devices with their drivers through their device settings, which can be accessed via the Settings > Privacy > Location menu.
• Emergency Data Sharing
  Riders may enable ALEEFEXPRESS to share real-time location data from their mobile devices with emergency police, fire and ambulance services. Such data may include approximate location at the time the emergency call was placed; the car’s make, model, colour and number plate information; the rider’s name and phone number; pick-up and drop-off locations; and the driver’s name.
  Riders may enable/disable this feature via the Settings > Privacy > Location menu, or the Safety Centre.
  Drivers and delivery persons can also enable/disable Emergency Data Sharing via the App settings > Emergency Data Sharing menu, or the Safety Toolkit.
• Notifications: account and trip updates
• We provide users with trip status notifications and updates related to activity on their account. These notifications are a necessary part of using the app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Settings > Privacy menu.
• Notifications: discounts and news
  Users may enable ALEFEXPRESS to send push notifications about discounts and news from ALEFEXPRESS. Push notifications may be enabled or disabled through the Settings > Privacy menus in the app.
• Communications from restaurants and merchants br

B. Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.

C. In-app ratings pages

After every trip, drivers and riders are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, rider ratings are available to drivers from whom they request transport, and driver ratings are available to their riders.

This 2-way system holds everyone accountable for their behaviour. Accountability helps create a respectful, safe environment for drivers and riders.

Riders can see their average rating in the main menu of the app.

Drivers can see their average rating after tapping their profile photo in the Driver app.

Delivery persons may also be rated by order recipients, restaurants and merchant.

D. Marketing and advertising choices

we provide users with the following choices regarding how their data is used for purposes of marketing and advertising:

• Personalised marketing communications from ALEFEXPRESS: Users may choose whether to receive communications (such as emails, push notifications and in-app messages) about products and services that are personalised based on their data to make it more relevant to them. Users may also choose whether to receive any marketing email.
• ads: Users may choose whether their data is used and shared with advertising partners to deliver personalised ads about products and services on third-party apps and websites, or to measure the effectiveness of such ads.
• Restaurant and merchant ads: Users may choose whether we may use their order and search history to display personalised ads for restaurants or merchants that are available on Food delivery.
• Third-party ads: Users may choose whether we may use their data to display ads for third party products or services that are personalised based on users’ observed or inferred interests and characteristics.
• Cookies and related technologies: For information on how to control ALEEFEXPRESS’s use of cookies and related technologies, including for purposes of displaying personalised ads.

E. User data requests

ALEFEXPRESS provides users with a variety of ways to learn about, control and submit questions and comments about our handling of their data.

• Accessing data: Users can access data including their profile data and trip or order history through the apps or via website. Users can also view an online summary of information about their account, such as number of trips or orders, rating, rewards status and number of days since they’ve been a user. Users can also request access to their data
• Data portability: Users can request a copy of their data. Users may also request a copy of their data.
• Changing or updating data: Users can edit the name, phone number, email address, payment method and photo associated with their account through the Settings menu in the apps or driver portal. Users may also request to update or correct their data.
• Deleting data: Users may request deletion of their account at any time through privacy settings or in the Settings > Privacy menus in the app.
• Objections, restrictions and complaints: Users may request that we stop using all or some of their data, or that we limit our use of their data. This includes objecting to our use of data that is based on our legitimate interests. We may continue to process data after such objection or request to the extent required or permitted by law.

V. Updates to this notice

We may occasionally update this notice.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.

Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.