Privacy Policy

SWEET RIDE LIMITED GLOBAL PRIVACY POLICY

Preface

Sweet Ride Limited (otherwise herein referred to as "Sweetride", "we", "us," or "our" depending on context) strongly believes in providing total privacy and protection to our customer's personal data. The information our customers give us is obtained with full consent, is processed legally, and is not sold, rented, loaned, or otherwise disclosed to third parties. This notice specifically applies to:

• Riders: Individuals who request or receive transportation and related services via their Sweetride account
• Drivers: individuals who provide transportation to Riders individually or through partner transportation companies

Our policies are created to protect the confidentiality and security of our customer's personal information. We only require the minimum amount of personal information to fulfil our customer service. Our privacy standards comply with the Nigeria Data Protection Regulation Act 2023, the General Data Protection Regulation (GDPR), and other applicable Laws.

Policy Overview

This Privacy Policy describes the process involved in the acquisition, processing, porting, storage, and disposing of your personal data in connection with our Services (which refers to all services, content, features, technologies, or functionalities supplied by us, as well as all related websites, apps, portals, mobiles applications, and tools. This Privacy Policy also governs your rights regarding the foregoing.

Scope and Consent

This policy is enforced after you consent and click "Accepted and Agreed To" access our products, services, content, features, technologies, or functions offered from our websites, related sites, portals, applications, and services. However, we are not responsible for the handling of information gotten by third-party customers/sites through the use of our tools, portal, and services and will not be held liable for any breach or misuse of collected information. You are therefore required to review the Privacy policy of such third-party customers/sites before using them.

Rights

You have the right of access to your personal data being processed by us which includes requesting for an update, rectification, erasure, asking for a copy of your personal data, a withdrawal of consent at any time, complaining to a data protection authority, without affecting the lawfulness of processing based on consent given before the withdrawal. You can request a restriction or deletion of your personal data based on the following:

• Non-legitimate grounds for the processing
• Unlawful processing
• Erasure is required for compliance with a legal obligation
• Inaccuracy of personal data
• Change in initial purpose

All requests shall be made in writing to us via email at info@usesweetride.com.

Use of Personal Information

The collection and use of personal data are guided by certain principles.

These principles state that personal data should:

• Be processed fairly, lawfully, and in a transparent manner.
• Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with such purposes.
• Be adequate, relevant, and limited to what is necessary to fulfill the purpose of processing.
• Be accurate and, where necessary, up to date.
• Not be kept for longer than necessary for processing.
• Be processed in accordance with the data subject's rights.
• Be kept safe from unauthorized processing, and accidental loss, damage, or destruction using adequate technical and organizational measures.

Personal Data Collected and Used by Us

Personal Data may be given to us directly by you or by people or companies authorized by you to act on your behalf. We may also collect Personal Data about you from third parties in connection with our Services. Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide the services envisaged or requested.

Automatic Information

In general, website users and logged-in users in the app who are not using our service do not need to provide personalized information to us. We may collect "aggregate data," i.e., group data with no personal identifiers such as IP address, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, and standard web log data and other information. We use this aggregate data to help us understand how our product, website, App, services, and other resources are being used and to improve usability. We also use it to enhance the quality and availability of our products and services.

Provided Information

Personal data that are provided and retained allow us to provide services to our users. We solely hold the information and engage in no contact-sharing program with other organizations.

The information collected is:

Data provided by users. This includes:

User profile information: We collect data when users create or update their Sweetride accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver's license and other government-issued documents (which may include identification numbers as well as birth date, gender, and photo), Bank verification number (Drivers). This also includes vehicle or insurance information of drivers, emergency contact information, user settings, and evidence of health or fitness to provide services using Sweetride apps.

Identity verification photos: This includes photos of users (such as, selfies) and/or their government-issued identifications (such as driver's licenses or passports). Such photos may be used to verify a user's identity, such as through facial verification technologies.

User content: We collect the data submitted by users when they contact Sweetride customer support, provide ratings or feedback for other users. 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 Sweetride.

Location data (driver): We collect precise or approximate location data from drivers' mobile devices when the Sweetride app is running in the foreground (app open and on-screen) or background (app open but not on-screen).

Location data (riders): We collect precise or approximate location information from riders' and order recipients' mobile devices if they enable us to do so via their device settings. Sweetride collects such data from the time a ride or order is requested until it is finished, and any time the app is running in the foreground (app open and on-screen). Riders may use the Sweetride apps without enabling the collection of location data from their mobile devices. However, this may affect certain features in the Sweetride apps. For example, a rider who has not enabled precise location data will have to manually enter their pickup address.

In addition, precise location data collected from a driver's device during a trip is linked to the rider's account, even if the rider has not enabled precise location data to be collected from their device. This data is used for purposes such as receipt generation, customer support, fraud detection, insurance, and litigation.

Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided; trip or order details (such as date and time, requested pick-up and drop-off addresses, distance travelled and items ordered); and payment transaction information (the amount charged, and payment method). We also associate a user's name with that of anyone who uses their promotion code.

Usage data: We collect data about how users interact with our services. This includes access dates and times, app features or pages viewed, browser type, app crashes and other system activity.

Device data: We collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.

Communications data: We collect data regarding phone, text or in-app communications between users that are enabled through Sweetride's apps. This includes date and time, as well as the content of text or in-app messages. We may also collect the content of phone calls solely where users are notified in advance that the call may be recorded.

Website Cookies

(small text files) when a user visits a website and these cookies are used to analyze aggregate user behavior on our website. Our websites ask permission of the visitor prior to setting cookies.

Should the visitor agree, our server shall only collect the following information:

• The visitor's IP address (including the domain name associated with the IP address, i.e., using reverse lookup).
• The date and time of the visit to the website.
• The pages visited on the website.
• The browser is being used.
• In addition, where this is available, we shall also collect:
• The country from which the visitor is accessing the website
• The language of the browser being used.
• The website from which the visitor is accessing our website.
• The search word used (if the site is accessed via a search engine).
• The type of connection and operating system.

We only use these data to improve the visitor's website experience. Please review our Cookie Policy to learn more about how we use cookies.

Third-Party Source

We may collect information from third-party websites such as social media sites that authorize us to access, store and use users' information which will be handled in accordance with this policy.

Surveys

In order to ensure that the services we offer meet your requirements, we may ask for your feedback in form of surveys and polls. Any feedback received from you shall only be used to improve our services and shall not be disclosed and are used for research and publication purposes.

Inquiries

When an inquiry is sent to us through our contact form, we use the personal data that you have stated in the contact form to send a response to you. Any personal data received from you shall not be used for any other purpose without your prior consent and knowledge and shall not be disclosed.

Duration Of Storage

We shall store your personal data until they are no longer necessary for the purpose for which we had collected it. Your information is only retained in accordance with legal and regulatory requirements for the collected data.

Data Storage and Security

We and our partners use a security-cleared data processor to store files and data on secure cloud-based servers hosted in Central America on Microsoft Azure. The data processors are certified under the applicable frameworks and thereby guarantee and operate an appropriate standard of data protection and data security. Regardless of where your information is processed, we apply the same protections described in this policy and you have the right (upon your request) to be informed of the appropriate safeguards for data protection in the foreign country. We protect your Personal Data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. All data is accessed via secure connections and stored on encrypted servers and encrypted storage services. We also use firewalls and physical access controls for our data centers and information access authorization controls.

Despite our efforts to establish a secure environment for the website, you should be aware that no information is completely secure on the internet. Therefore, you should always take the necessary safeguards and precautions on your equipment. In the event of an actual or suspected breach of your Personal Data, we will use our best effort to remedy the breach within one (1) month from the date we report the breach to you.

Children's Privacy

We do not use our platforms to knowingly solicit data from children or individuals under the age of Eighteen (18). Where a parent or guardian discovers that a child or individual under the age of Eighteen (18) has provided us with his/her Personal Data without their consent, he or she should contact us at info@usesweetride.com. and we shall immediately delete the user's account from our servers.

Accuracy Of Information

• We shall take reasonable steps to ensure personal data is accurate.
• Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
• We shall ensure that updated personal data reflect across all boards to which it is being used.

Archiving/removal

• To ensure that personal data is kept for no longer than necessary, we put in place a data retention policy for each area in which personal data is processed and review this process annually.
• This retention policy considers what data should/must be retained, for how long, and why.

Transfer of Personal Data

We do not rent or sell your personally identifiable information to other individuals or organizations. However, we may transfer your personal data to third parties when it is necessary to provide you with our service.

Third parties could include:

• Undertakings within Sweet Ride
• Business partners
• Professional advisors
• Legal or regulatory authority
• Application program interface (API) Users
• Security-cleared data processors/subcontractors are assisting us or the group with IT or other services.

When we transfer your personal data to business partners, you should be aware that they might have stored personal data concerning you collected through other means, e.g., if you have been in contact with them in another context.

We also transfer your personal data to the above or other third parties if we are obliged to do so according to legislation or in order to protect our or the group's interests in legal disputes.

Transfer of Personal Data to Third Countries

We partner with various technology vendors from time to time. This shall result in a transfer of personal data to a third country or international organization. In order to ensure an equal level of security for such transfer in accordance with the applicable laws, we have chosen to work only with vendors that have entered Standard Contractual Clauses on Data Protection with us.

Third-Party Links

Please note that the Services may contain links to other websites not operated or controlled by us. We are not responsible for the content, accuracy, or opinions expressed in such websites, and such websites are not investigated, monitored, or checked for accuracy or completeness by us. Please remember that when you use a link to go from any of our Services to another website, our Policy is no longer in effect. You're browsing and interaction on any other website, including those that have a link on our site, is subject to the website's own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

Data Breach Notification

In the event of a data breach that may compromise the security of personal information, we are committed to notifying affected individuals in compliance with applicable data protection laws. Notifications will be sent via email or other means as required by law.

Marketing Communications

With your explicit consent, we may use your contact information to send you marketing communications about our products, services, and special promotions. You have the right to opt out of receiving these communications at any time.

Changes to This Policy

We may update this Policy from time to time without any prior notice to you or consent. Thus, you are advised to consult any of the platforms through which you use the Services periodically for any changes. We will notify you of any changes by posting the revised Policy on the Services. Please note that changes shall be effective immediately after they are updated.

Contact

If you want to lodge a complaint about our processing of your personal data or have further requests, please contact us directly at info@usesweetride.com. We maintain an incidence response plan used in dealing with incidents relating to unlawful disclosure, loss, alteration, destruction, and access to our customer's personal data collected, transmitted, stored, or processed. We will work with the appropriate authorities to resolve any issues that we cannot resolve with you directly.

Cookie Policy

Please read this cookie policy ("cookie policy", "policy") carefully before using the Services operated by SWEET RIDE LIMITED (otherwise herein referred to as "we," "us," or "our" depending on context).

What are Cookies?

Cookies are simple text files that are stored on your computer or mobile device by a website's server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, the website's domain name, and some digits and numbers as well as some personal identifiers such as: the user's name, Phone number, user picture and integration into Biometric and Face ID login features of your device.

Necessary Cookies

Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our website and using its features. For example, these cookies let us recognize that you have created an account and have logged into that account.

Functionality Cookies

Functionality cookies let us operate the site in accordance with the choices you make. For example, we will recognize your username and remember how you customized the site during future visits.

Performance Cookies

These are used to gather data on how users use our website and the pages visited most often. They monitor only the performance of our website as the user interacts with it. All data collected by these cookies are anonymous and are solely used to improve the functionality of our website.

How to delete Cookies?

If you want to restrict or block the cookies that are set by our website, you can do so through your browser setting. However, deleting strictly necessary and performance cookies from your browser may remove or limit your access to some functionality on this website.

Contacting us

If you have any questions about this policy or our use of cookies, please contact us.

Sweet Ride

General Terms for Drivers

1. DRIVER AGREEMENT

(a) This Driver Agreement (Agreement) is a legal agreement between you and Sweet Ride. It governs your use of (and access to) the Sweet Ride Application, onboarding, and your relationship with Sweet Ride.

(b) You acknowledge and agree that you are at least eighteen (18) years old and legally capable of entering into this Agreement by registering as a Sweet Ride Driver.

(c) You consent to receive communications related to the Services your Sweet Ride Account in electronic format.

(d) Please carefully review all the terms and conditions of our policies, as well as any other agreements that may apply to you. Such terms and conditions, as communicated to you by us through the Services or other methods, shall apply to your use of the Services, and such terms and limitations are included in this Driver Agreement.

(e) There are several sections to this Driver Agreement, and you should take the time to read them all carefully before signing. The headings are for the sake of reference. This Driver Agreement contains explanations for several capitalized phrases that may be found in the Definitions. The terms in this Agreement that have been underlined are hyperlinks to extra information on the website.

DEFINITIONS

a) App refers to the mobile application software, as well as the data that is associated with it and the media that is used in conjunction with it.

b) Business Day refers to any day other than a Saturday, Sunday, or public holiday on which financial institutions are open for business.

c) Services means services that Sweet Ride provides, including provision and maintenance of its App, Sweet Ride Platform, In-app Payment, customer support, communication between the Driver and the Passenger and other similar services.

d) Sweet Ride App or App refers to the smartphone application for Drivers and Passengers to request and receive Transportation Services

e) Sweet Ride Platform means technology connecting Passengers with Drivers to help them move around cities more efficiently.

f) Passenger means a person requesting Transportation Services by using the Sweet Ride Platform.

g) Driver (also referred to as "you") -- the person providing Transportation Services via the Sweet Ride Platform. Each Driver will get a personal Driver Account to use the App and Sweet Ride Platform.

2. ENTRY INTO THE AGREEMENT AND ONBOARDING

2.1. Prior to using the Sweet Ride Services, you must sign up by providing the requested information in the signup application on the website and uploading necessary documentation as required by us. Upon successful completion of the signup application, we will provide you with a personal account accessible via a username and password.

2.2. You agree to provide us with your address information, vehicle particulars, valid means of identification, bank account information and clear passport photographs. Note that you are obliged to provide your bank requisites while filling the payment details upon registration. In case you are a legal person, you must insert the bank account of the company. We are not liable for any incorrect money transactions if you have provided wrong bank details.

2.3. All activities conducted under a Sweet Ride Account are those of the registered user. Any transactions you make through the Sweet Ride Account must be made on your own, and not on behalf of any other person or entity. We reserve the right to deny the establishment of multiple accounts for the same user. If duplicate accounts are discovered, Sweet Ride may cancel or combine these accounts without notifying you.

2.4. You acknowledge that we may handle personal data about you and personal data about other persons that you have supplied or will supply to us in the future in conjunction with this Agreement or Sweet Ride's Services. As such, you represent and warrant that:

your disclosure to us of any personal data relating to individuals other than yourself was or will be made in accordance with all applicable data protection and data privacy laws, and that such data is accurate, up to date, and relevant at the time of disclosure; and (ii) before providing any such personal data to us, you have read and understood our Privacy Policy and, in the case of personal data relating to an individual other than yourself, you have read and understood our Privacy Statement.

3. THE SWEET RIDE APPLICATION

3.1. On the condition that all preconditions have been fulfilled by you, we hereby grant you a license to use the Sweet Ride Application. The license does not grant you the right to sublicense or transfer any rights to the third persons.

3.2. In course of using the Sweet Ride Application you may not:

3.2.1. decompile, reverse engineer, or otherwise attempt to obtain the source code of the Sweet Ride App or other software of Sweet Ride;

3.2.2. modify the Sweet Ride App in any manner or form or to use modified versions of the Sweet Ride;

3.2.3. transmit files that contain viruses, corrupted files, or any other programs that may damage or adversely affect the operations on Sweet Ride App;

3.2.4. attempt to gain unauthorized access to the Sweet Ride App or any other Sweet Ride Services.

3.3. The License granted herein revokes automatically and simultaneously with termination of the Agreement. After termination of the Agreement, you must immediately stop using the Sweet Ride and we are entitled to block and delete your account without a prior notice.

3.4. All copyrights and trademarks, including source code, databases, logos and visual designs are owned by Sweet Ride and protected by copyright, trademark and/or trade secret laws and international treaty provisions. By using the Sweet Ride App or any other Sweet Rude Services you do not acquire any rights of ownership to any intellectual property.

4. PROVIDING THE TRANSPORTATION SERVICES

4.1. You hereby undertake to provide transportation services in accordance with this terms and conditions, Sweet Ride's code of conduct, as well as laws and regulations applicable in Nigeria. Please note that you are fully liable for any violation of any local laws and regulations.

4.2. You represent that you have all licenses (including a valid driver's license), permits, car insurance, liability insurance (if applicable), registrations, certifications and other documentation that are required by law. It is your obligation to maintain the validity of all documentation. Sweet Ride reserves the right to require you to present evidence and submit for review all the necessary licenses, permits, approvals, authority, registrations and certifications.

4.3. You must provide the transportation services in a professional manner in accordance with the business ethics applicable to providing such services and endeavor to perform the Passenger's request in the best interest of the Passenger. Among else, you (i) must take the route least costly for the Passenger, unless the Passenger explicitly requests otherwise; (ii) may not make any unauthorised stops; (iii) may not have any other passengers in the vehicle other than the Passenger and the passengers accompanying the Passenger; and (iv) must adhere to any applicable traffic acts and regulations, i.e must not conduct any actions that may disrupt driving or the perception of traffic conditions, including holding a phone in his/her hand while the vehicle is moving.

4.14. You hereby acknowledges that you are obliged to fully comply with all tax obligations that arise to you from the applicable laws in relation to providing the Transportation Services.

5. SWEET RIDE FEES

5.1. In order to use the Sweet Ride Services, you are obliged to pay to a Fee. The Fee is paid based on the Fare of each Transportation Service order that you have completed. The amount of the Fee is made available to you via e-mail, Sweet Ride App or other pertinent means. Please acknowledge that the Fee may change from time to time. We shall send you a prior notification of each such change.

6. IN-APP PAYMENTS

6.1. We may enable Passengers to pay for the Transportation Service via cards, carrier billing and other payment methods directly in the Sweet Ride App (i.e. In-app Payment). You hereby authorise us to act as your limited commercial agent solely for the purpose of collecting, on your behalf, the Fares or other fees paid by the Passenger via In-app Payment. Any payment obligation made by the Passenger via the In-app Payment shall be considered fulfilled as of the time that the payment has been made.

6.2. You shall not refuse payment by the Passenger via the In-app Payment, or influence the Passenger against the use of the In-app Payment.

7. CUSTOMER SUPPORT

We provide the Drivers customer support regarding the use of the Sweet Ride Services. We have the right to stop providing the customer support services in case you are in delay with any of the payments for more than 5 (five) calendar days.

8. RATINGS AND ACTIVITY

To guarantee high-quality service and provide additional reassurance to Passengers, you hereby acknowledge that the Passengers may provide you a rating and leave feedback regarding the quality of the Transportation Services that you have provided. Your average rating will be linked to your Driver´s account and will be available to Passengers at Sweet Ride App. If we find out the rating or comment is not given in good faith, this rating or comment may not be projected in the calculations of your rating.

9. RELATIONSHIP BETWEEN YOU, US AND THE PASSENGERS

9.1. You hereby acknowledge and agree that we are a marketplace connecting Passengers with Drivers to help them move around cities more efficiently, we are not a transport service provider. You acknowledge that you are providing the Transportation Services on the basis of a contract for carriage of passengers and that you provide the Transportation Services either independently or via a company as an economic and professional activity.

9.2. You acknowledge that no employment agreement nor an employment relationship has been or will be established between you and us. You also acknowledge that no joint venture or partnership exists between you and us. You may not act as an employee, agent or representative of us nor bind any contract on behalf of us. If due to the implication of mandatory laws or otherwise, you shall be deemed an employee of us, you hereby agree to waive any claims against us that may arise as a result of such implied employment relationship.

10. INTELLECTUAL PROPERTY RIGHTS

10.1. We own the intellectual property rights in the Sweet Ride App, including the Website, App, API, and other associated platfomrs. You may not modify, copy, reproduce, republish, upload, post, transmit, translate, sell, create derivative works, exploit, or distribute in any manner or medium (including by email or other electronic means), the Services, or any Sweet Ride Material unless explicitly authorized in this Agreement.

10.2. You acknowledge that all rights, title, and interest in and to the Services, together with its codes, derivative works, organization, structure, interfaces, any documentation, data, trade names, trademarks, trade secrets, proprietary information, or other related materials is, and always shall remain our sole and exclusive property. Except for the right to use the Services, as expressly provided herein. This Agreement does not grant you any rights to, or in, patents, copyrights, database rights, trade secrets, trade names, trademarks (whether registered or unregistered), or any other rights or licenses concerning the Services.

10.3. Our name, the Services, and all related names, logos, product and service names, designs, and slogans are copyright and trademarks belonging to us. You must not use such marks without our prior written permission. All other names, logos, product and service names, designs, and slogans on the Services are the trademarks of their respective owners.

10.4. Any feedback, comments, or suggestions you may provide regarding the Services is entirely voluntary and we will be free to use such feedback, comments, or suggestions as we see fit and without any obligation to you.

11. LIMITATION OF LIABILITY

11.1. To the maximum extent permitted by applicable law, we shall not be liable to you for any cause whatsoever, regardless of the form of the action. As permitted by applicable law, we exclude all conditions, warranties, representations, or other terms which may apply to our Services or any content on them, whether express or implied. We will not be liable to any user for any loss or damage, whether direct or indirect, incidental, or special, consequential, or punitive, even if foreseeable, arising under or in connection with the use of, or inability to use our Services and you hold us harmless in respect of:

i. any loss of profits, loss of business, loss of revenue, loss of contracts, loss of goodwill, loss of anticipated earnings or savings (whether direct, indirect, incidental, or consequential); or

ii. any loss of use or value or damage of any data or equipment (including software), waste management, operation, or other time (whether direct, indirect, incidental, or consequential); or

iii. Any special, indirect, punitive, incidental, or consequential loss arising in connection therefrom.

12. INDEMNITY

12.1. You hereby agree and undertake to fully indemnify and keep us harmless from and against all actions, claims, costs (including legal costs on a full indemnity basis), losses, charges, expenses, and damages which we may suffer or incur as a result of:

i. any fraud, negligence, dishonesty, or misconduct (criminal or otherwise) relating to the transactions perpetrated by you, your servants, agents, employees, or contractors or the fraud, dishonesty, or misconduct (criminal or otherwise) perpetrated by a third party as a result of the negligence or default of you, your servants, agents, employees, or contractors.

ii. any loss arising from any fraud or dishonesty arising from a breach of security of your software or hardware by a third party on the Services.

12.2. You shall not hold us liable or responsible for any action, claim, cost, expense, damage, and loss, including consequential loss or damage or loss of profit, which you may suffer or incur as a result of a breakdown in the Services or when the Services is not available by reason of circumstances beyond our control or arising directly or indirectly out of your use of the Services.

12.3. We believe it is of utmost importance to protect our other users and we may in furtherance of protecting the other users, exercise our rights to restrict or deny you access or usage of the Services. Therefore, if we exercise our right to deny you or restrict your access to the Services, we will not be responsible for any consequences of our failure to provide you with access to the Services, including any delay, damage, or inconvenience that may result from such restriction or denial of access.

13. GENERAL DISCLAIMER OF WARRANTY

13.1. The Services are provided to you "as is," without any representation or warranty, express or implied, of any kind, including, but not limited to, warranties of merchantability, non-infringement, or fitness for any particular purpose. We do not warrant the accuracy or completeness of the service, the suitability of the content, or the reliability of any advice, opinion, statement, or other information displayed or distributed through the Services.

13.2. We give no assurance that the Services will meet any or all requirements you may have, whether or not advised to you. Furthermore, we give no assurance that the running of the Services will be incessant, uninterrupted, or error-free, that defects will be corrected, or that the Services is free of viruses or other harmful components.

13.3. We cannot guarantee and do not promise any specific results from the use of the Services. You, therefore, use the Services at your own sole risk.

13.4. The Services may be temporarily unavailable from time to time for maintenance or other reasons. We assume no responsibility for any error, omission, interruption, deletion, defect, delay in operation or transmission, communications line failure, theft or destruction, or unauthorized access to, or alteration of user communications. We are not responsible for any problems or technical malfunction of any telephone network or lines, computer online systems, servers or providers, computer equipment, software, failure of email or players on account of technical problems or traffic congestion on the Internet or on the Services or combination thereof, including injury or damage to Users or to any other person's computer related to or resulting from participating or downloading materials in connection with the web and/or in connection with the Services.

13.5. We assume no liability for any and all problems caused by any data, network, database, software, hardware, or other operational environmental factors not within our direct control and we shall not be responsible for correcting such problems.

13.6. No information or advice provided on the Services, by us, or by our employees or agents shall create any warranty.

14. FORCE MAJEURE

We will not be liable for any delay or failure to perform our obligations if and to the extent such delay or failure results from circumstances beyond our control. Such events include but are not limited to acts of God, fire, flood, invasion, war, revolution, uprising, insurrection, social/public unrest, public disturbance, strike, riots, fire disaster, storm, acts of terrorism, plague, epidemic, pandemic, outbreaks of infectious disease or any other public health crisis, including quarantine or other employee restrictions, and any other circumstance which may hinder or delay the performance of our obligations under this Customer Agreement.

15. CUSTOMER COMMENTS, INQUIRIES, COMPLAINTS, AND RESOLUTION OF DISPUTES

15.1. If you have any comments or questions, please contact us via our Customer Support page here.

15.2. When contacting us, please provide your name, phone number, and any other information necessary to identify you, your Sweet Ride Account, and the transaction over which you have feedback or questions.

15.3. You agree that Agreement shall be governed by and construed in accordance with the Laws of the Federal Republic of Nigeria.

15.4. If any dispute or difference arises as to the validity, interpretation, effect or rights and obligations under this Agreement, we shall use our best endeavors to reach an amicable settlement of the dispute.

15.5. If any such dispute is not settled within thirty (30) Business days, the we hereby agree to submit such dispute to the exclusive jurisdiction of the Nigerian Courts.

16. ASSIGNMENT

You may not transfer or assign any rights or obligations you have under this Agreement without our prior written consent in its sole and absolute discretion. We reserve the right to transfer or assign this Agreement or any right or obligation under this Agreement at any time.

17. MODIFICATIONS

17.1. We reserve the right to change, modify and update this Customer Agreement at any time.

17.2. Any aspect of the Services may be amended, changed, modified, supplemented, deleted, or updated without prior notice at our sole discretion. You should therefore pay attention to communications from us about updates.

17.3. Your continued use of the Services after any modifications to this Customer Agreement shall mean you accept those modifications.

GLOBAL PRIVACY NOTICE FOR DRIVERS

Sweetride RC1939452 located in Kano, Nigeria, is the controller of the personal data of drivers and has appointed data protection.

This privacy notice for drivers provides information about how Sweetride operations (hereinafter "Sweetride", "we", "us") process the personal data of persons providing transportation services via the Sweetride platform, i.e., drivers. The privacy notice describes what data we collect and why we process it, how we keep personal data safe and what choices and controls are available to the data subjects (hereinafter also "you"). You can also find information about your privacy rights in the privacy notice.

If you are a driver on the Sweetride platform, please read this privacy notice as it contains important information about the processing of your personal data as well as information about our requirements when you process passengers' personal data.

Please note, that our websites and apps may contain links to other third-party websites. If you follow a link to any of those third-party websites, know that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or their processing of your personal data. Please check these policies before you submit any personal data to such third-party websites.

1. Personal data we process

We may process different categories of driver's personal data. The data categories are as follows:

• General data such as name, e-mail, phone number, place of residence, Bank Verification Number (BVN), National Identification Number (NIN), and Bank account number, (data is provided to us by the driver). Vehicle image, proof of ownership, licence plate number etc.
• Geolocation data such as geolocation of drivers and driving routes (data is gathered via Sweetride system when a driver uses the Sweetride app)
• Information about vehicles (including registration number and compliance status) (data is provided to us by the driver).
• Usage data such as driver's engagement and driver's engagement and interactions on the marketplace and driver ratings (including driver score).
• Identification/verification data such as driver's license, photo, and identity documents.
• Offences data such as data about criminal convictions and offences, where permitted under local laws and regulations.
• Communication and correspondence records such as: When the driver engages with our in-app chat ("Send a message" Option), or speak with our customer service agents, the date and time of the communication, and its content.
• Information required under applicable law for taxation purposes: Such as your taxpayer identification number, place of birth, financial account identifier, information of each member state in which you are a resident.
• User generated content: Such as audio recordings generated during the trip (as part of our safety toolkit trip audio recording feature, where such feature is available - or any other content submitted like files in connection with a customer support request.

2. Purposes of the processing.

We process driver's personal data for different purposes. The main purposes are as follows:

1. For our service provision, we collect and process personal data for the purpose of connecting passengers with drivers to help them move around cities more efficiently.
2. For our service provision, geolocation and driving routes are processed to analyse the geographical area and give suggestions to the drivers.
3. Driver's license, profession, identity documents and criminal convictions and offences are processed to determine compliance with the legal requirements and the suitability of pursuing a profession as a driver and are law abiding citizens.
4. For our service provision, the Sweetride app displays the driver's photo, name and vehicle details for the passengers to identify the driver and vehicle.
5. You will receive summaries from the Sweetride driver portal, which will include your efficiency and ratings as a driver.
6. Summary and ratings about drivers are necessary to provide reliable services for passengers.
7. Personal data related to instant messages directly in the Sweetride app is processed in order to provide service and customer support (including resolving disputes between driver and rider), for security purposes as well as to improve our products and services, and for analysis.
8. We collect and use information about a driver's engagement and interaction on the marketplaceD, and their ratings (including driver score) to encourage user safety, ensure drivers comply with the driver terms, and make sure we're providing a quality and enjoyable service to everyone.
9. We may process all personal data about you for the establishment, exercise or defence of legal claims.

Please see additional purposes under legitimate interest.

3. Legal basis.

We mainly use following legal basis to process driver's personal data:

Performance of contract: Personal data is processed for the performance of the contract concluded with the driver. The prerequisite for the use of the Sweetride services is the processing of driver's identification and geolocation data. In addition, in order to provide our service to the driver, we process general data, vehicle data, usage data, communications data.

Legitimate interest: Personal data (excluding special categories of personal data) may be processed on the ground of legitimate interest if we have concluded a legitimate interest assessment, including for the following purposes:

• investigating and detecting fraudulent payments, fraud and other malicious or unlawful activities and/or safety or security incidents: General data, identification/verification data, communication data and usage data may be processed;
• making recordings and logs: Depending on your location, we may record messages and orders given both on our premises and/or using means of communication (e-mail, phone calls to customer support and riders, the Sweetride app, etc.) as well as information and other activities we have performed. If necessary, we use these recordings for investigations, proof and protection against claims, and/or for quality assurance.

Depending on the particular circumstances, we may, from time to time rely on alternative legal basis when it is more appropriate to do so, these may include:

When it is necessary to comply with a legal obligation such as for processing data when the law requires it, including, for example, if there is a valid legal request to disclose personal information to a third party such as a court or regulatory authority;

When it is necessary to protect your vital interests, or those of others, for example in the event of an emergency or an imminent threat to life; and/or when you have given us clear consent to do so for another specific purpose for which you have been fully informed.

Where personal data is processed for a new purpose other than that for which the personal data are originally collected and the processing is not based on the data subject's consent, we carefully assess the permissibility of such new processing. We will, in order to ascertain whether processing for a new purpose is compatible with the purpose for which the personal data are initially collected, take into account, inter alia: Any link between the purposes for which the personal data are collected and the purposes of the intended further processing;

The context in which the personal data are collected, in particular regarding the relationship between you and us; the nature of the personal data, in particular whether special categories of personal data are processed or whether personal data related to criminal convictions and offences are processed; the possible consequences of the intended further processing for you; and the existence of appropriate safeguards, which may include encryption or pseudonymisation.

4. Recipients

Your name and photo is disclosed to passengers, when you have received their order. When you have accepted the passenger's order, passengers will see driver's name, vehicle, phone number, photo and geolocation data. Passengers also see driver's personal data in the receipt.

Depending on the location of the driver, the personal data may be disclosed to the Sweetride local subsidiaries, representatives, affiliates, agents, fleet owners etc). Processing of personal data by will occur under the same conditions as established in this privacy notice.

We may disclose information under a court order or where we cooperate with a data protection supervisory authority in handling complaints or investigations. We may also share your personal data with law enforcement or other public authorities (such as tax authorities), including responding to requests when the information is required by law or furthers a public interest task. In any scenario, we'll always satisfy ourselves that we have a lawful basis on which to share the information, and we'll make sure that we document our decision.

5. Security and access

Any personal data collected in the course of providing services is transferred to and stored in the data centers only authorized employees of Sweetride company and partners have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding transportation services).

Sweetride can access personal data to the extent necessary to provide customer support in the respective states.

Digital Ocean is our data storage platform.

6. Processing passengers personal data

You may not process the personal data of passengers without the permission of us. You may not contact any passenger or collect, record, store, grant access, use or cross-use the personal data provided by the passenger or accessible to you via the Sweetride app for any reason other than for the purposes of fulfilling the transportation services.

You must comply with the rules and conditions for processing of personal data of passengers as set forth in the privacy notice for passengers. If you violate the requirements for the processing of personal data of passengers, we may terminate your drivers account and claim damages from you.

7. Access, correction, retention, deletion and data portability

Personal data can be viewed and corrected in Sweetride driver dashboard.

As a data subject you have following rights:

• you have the right to access and to request copies of your personal data.
• you have the right to request that we correct any information that is inaccurate. You can change certain data yourself within the Sweetride driver dashboard.
• you have the right to request that we erase your personal data, under certain conditions (e.g., we are processing your personal data under your consent). Data that is processed pursuant to a legal obligation or where we have an overriding legitimate interest may not be deleted upon request.
• you have the right to request that we restrict the processing of your personal data, under certain conditions (e.g., we are processing your personal data under consent).
• you have the right to object to our processing of your personal data, under certain conditions (e.g., we are processing your personal data under legitimate interest). You may submit an objection to any automated decision we have made, and ask that a person reviews it.
• you have the right to request that we transfer the data that you have given us to another organization, or directly to you, under certain conditions. This only applies to information you have given us.
• if we process your personal data using consent as legal basis, then you have the right to withdraw your consent at any time (e.g., by unsubscribing or using privacy controls in driver portal). Withdrawing your consent won't change the legality of processing done before withdrawal.
• in cases where we use automated processing or profiling that has a significant effect on your rights, you may, under certain circumstances, have the right on grounds relating to your particular situation to object to the processing of personal data concerning you based on automated decisions/profiling and to require human intervention. You may also be entitled to an explanation regarding the logic of making an automated decision.
• you have the right to file a complaint to the supervisory authority if you believe that we have processed your personal data unlawfully or have not complied with our legal obligations. You may also have a right to seek a judicial remedy

your personal data will be stored as long as you have an active driver's account. If your account will be closed the personal data will be stored for additional 3 year period.

data necessary for accounting purposes shall be stored for 7 years.

in the event that there are formal investigations of a criminal offence, fraud or false information having been provided, the data will be stored as long as necessary according to the internal, legal, and regulatory requirements.

in the event of disputes, the data shall be retained until the claim is satisfied or the expiry date of such claims.

we respond to the request for deleting and transferring personal data submitted by an e-mail within a month and specify the period of data deletion and transfer.

the retention period for the data about instant messages directly in the Sweetride app messages is 30 days, except cases where messages are related to a reported incident - in which case we will store them for 6 month.

the retention period for audio recording data generated through our audio trip recording feature is:

24 hours, while stored locally on the device of the person who generates the recording. The recordings are automatically deleted after 24 hours if a report to Sweetride's customer support team is not created and the recording is not explicitly shared with Sweetride's customer support team as part of the report.

Recordings shared and investigated by Sweetride will be automatically deleted after 7 days unless the retention period is manually extended for investigation/legal reasons.

8. Dispute resolution

Disputes relating to the processing of personal data are resolved through customer support (info@usesweetride.com) or by contacting Sweetride's data protection officer auwal

Our supervisory authority is the nigerian data protection inspectorate

We hope you have found this privacy notice easy to understand.

Data protection laws are important. They strengthen rules and enhance your information rights. Many of these rules may appear complicated, but most are grounded in common sense. We take our responsibilities with your data seriously. Sweetride will continue to make changes to this privacy notice as part of our commitment to protecting your privacy and affording you even more transparency.