This privacy policy sets out how Bongo Xpress uses and protects any information that you give Bongo Xpress when you use this website.

Bongo Xpress is committed to ensuring that your privacy is protected. We collect information about you when you use our mobile applications, websites, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us. This policy applies to drivers /pilots that use or register under the Bongo Xpress platform to perform delivery jobs (collectively “Pilots,” or individually “you”).

Bongo Xpress may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 28^th May, 2021.

1. The data we collect

• Data provided by users to Bongo Xpress, such as during account creation
• Data created during use of our services, such as location, app usage, and device data
• Data from other sources, such as Bongo Xpress partners and third parties that use our APIs.

1- Data provided by users. This includes:

• User profile:

We collect data when users create or update their pilot 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 identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of pilots, emergency contact information, user settings, and evidence of health or fitness to provide services using Bongo Xpress apps.

We may use the photos submitted by users to verify their identities, such as through facial recognition technologies. For more information, please see the section titled “How we use personal data.”

• Background check and identity verification:

We collect background check and identity verification information for the pilots. This may include information such as pilot history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on Bongo Xpress’s behalf. We also collect identity verification of the users who request alcohol delivery.

• Demographic data:

We may collect demographic data about users, including through user surveys. In some areas, we may also receive demographic data about users from third parties.

• User content:

We collect the information users submit when they contact our customer support, provide ratings or compliments for other users or delivery partners, or otherwise contact us. This may include feedback, photographs, signature or other recordings collected by users.

2- Data created during use of our services. This includes:

• Location data: 

We collect this data when the Bongo Xpress app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of your mobile device. We collect precise or approximate location data from the pilots’ mobile devices if they enable us to do so. The app collects this data from the time a task is created until it is finished, and any time the app is running in the foreground of their mobile device. We use this data to enhance your use of our apps, including to improve pick-up locations, enable safety features, and prevent and detect fraud.

This aps collects pilot’s location data, and links location data collected during a trip with pilot’s account, even if the pilot has not enabled us to collect location data from his/her device. This enables us to offer services to the pilot like receipt generation and customer support.

• Transaction information: 

We collect transaction information related to the use of our services, including the type of services requested or provided, trip details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.

• Usage data: 

We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.

• Device data: 

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

• Communications data: 

We enable users to communicate with each other and Bongo Xpress through our mobile apps and websites. For example, we enable pilots to call (audio/video), text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, we receive some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. We may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics.

• Audio recordings:

In certain jurisdictions, and where permitted by law, users can record the audio of their trips through an in-app feature. Recordings are encrypted and stored on users’ devices, and are only shared with Bongo Xpress if submitted to customer support by the users in connection with safety incidents.

3- Data from other sources. This includes:

• User feedback, such as ratings, feedback, or compliments.
• Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.
• Users or others providing information in connection with claims or disputes.
• Our business partners through which users create or access their accounts, such as payment providers, social media services, or apps or websites that use Bongo Xpress’s APIs or whose APIs Bongo Xpress uses.
• Our business partners in connection with the payment system (i.e. Visa Card) to the extent disclosed in the terms and conditions for the card.
• Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
• Insurance, vehicle, or financial services providers for the pilots.
• Partner transportation companies (for truck rental marketplace or pilots who use our services through an account associated with such a company).
• Publicly available sources.
• Marketing service providers.

We may combine the data collected from these sources with other data in its possession.

1. How we use personal data

This app collects and uses data to enable reliable and convenient transportation, delivery, and other services. We do not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

We use the data it collects for purposes including:

1- Providing services and features 

We use the data we collect to provide, personalize, maintain, and improve our products and services.

This includes using the data to:

• Create and update users’ accounts.
• Verify drivers’ and pilots’ identity, background history, and eligibility to work.
• Offer, process, or facilitate payments for our services.
• Offer, obtain, provide, or facilitate insurance, vehicle, invoicing, or financing solutions in connection with our services.
• Track and share the progress of deliveries.
• Enable features that allow users to share information with other people, such as when pilots submit a compliment about a merchant and the customers, refer a friend to our platform, or share ETA and location with their contacts.
• Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

2- Safety and security

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

• Screening pilots before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe pilots.
• Using data from pilots’ devices to help identify unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. We also use data to verify the type of vehicles they used to provide deliveries.
• In certain regions, using information derived from pilot’s license photos, and other photos submitted to us, for safety and security purposes. This includes Real-Time ID Check feature, which prompts drivers and delivery persons to share a selfie before going online to help ensure that the pilot using the app matches the Bongo Xpress account we have on file. This also includes comparing photographs that we have on file against photographs (i) of other users to prevent identity-borrowing, and (ii) from public databases to verify user identity.
• Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
• Using user ratings and feedback to encourage compliance with our Community Guidelines and as grounds for deactivating drivers and delivery persons with low ratings or who otherwise violated such guidelines in certain countries.

3- Customer support

We use the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

• Direct questions to the appropriate customer support person
• Investigate and address user concerns
• Monitor and improve our customer support responses and processes

4- Research and development

We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

5- Enabling communications between users

For example, a pilot may message or call (audio/video) to confirm a pickup/delivery location, a partner may contact a driver to retrieve a lost item.

6- Marketing

We may use the data we collect to market our services to our users. This includes sending users communications about Bongo Xpress services, features, promotions, studies, surveys, news, updates, and events.

We may also send communications to our users about products and services offered by our partners.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of our services, and user preferences and settings.

7- Non-marketing communications

We may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Bongo Xpress or its partners.

8- Legal proceedings and requirements 

We may use the personal data we collect to investigate or address claims or disputes relating to use of our services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

9- Automated decision-making

We use personal data to make automated decisions relating to use of our services. This includes:

• Enabling dynamic pricing, in which the price of a trip, or the delivery fee is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic etc.
• Matching available pilots to users requesting services. Users can be matched based on availability, proximity, and other factors.
• Determining pilots and their ratings, and deactivating pilots with low ratings.
• Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm Bongo Xpress, its users, and others. In some cases, such as when a user is determined to be abusing our referral program, such behavior may result in automatic deactivation.
• Using driver location information, and communications between pilot and partner, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a pilot is delaying a pickup in order to induce a cancellation, we will not charge the partner a cancellation fee and will adjust the amounts paid to the pilot to omit such a fee. To object to such adjustment, please contact our customer support.

1. Cookies and third-party technologies

We use cookies and other identification technologies on our apps, websites, emails, and online ads for the different purposes.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. We use 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
• Analyzing site traffic and trends, and generally understanding the online behaviors 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.

1. Data sharing and disclosure

1- With other users

This includes sharing:

• Customers’ first name, rating, and pickup and/or drop-off locations with pilots.
• Delivery recipients’ first name, delivery address, and order information with their delivery pilot and senders. We may also share ratings and feedback, or other information to the extent required by law, with the partner (merchant) and delivery pilot.
• For pilots, we may share data with the customer(s), recipients(s) and partner(s)/senders, including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; length of use of the Bongo Xpress app; contact information (depending upon applicable laws); and pilot profile, including compliments and other feedback submitted by past users.

We also provide customers and partners with digital bill containing information such as a breakdown of amounts charged, pilot’s first name, photo, route map, and such other information required on invoices.

• For those who participate in Bongo Xpress’s referral program, we share certain personal data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus.

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 customer when requested by that partner.
• Our business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, we 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 other partners and their users in connection with promotions, contests, or specialized services.

3- With the general public

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

4- With the Bongo Xpress account owner

If a user requests trip or create a task using an account owned by another party, we may share their task or trip information, including real-time location data, with the owner of that account. This occurs, for example, when:

• A customer uses booking form for business use,
• A pilot uses an account owned by or associated with a Bong Xpress Fleet partner company or delivery partner

5- With Bongo Xpress subsidiaries and affiliates

We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, we process and store data in the super admin dashboard on behalf of its partners and others subsidiaries and affiliates.

6- With delivery partners & business partners

We provide data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

• Payment processors and facilitators
• Background check and identity verification providers (pilots)
• Cloud storage providers
• Google, in connection with the use of Google Maps in Bongo Xpress’s apps (see Google’s privacy policy for information on their collection and use of data)
• Facebook, in connection with the use of the Facebook Business Tools in Bongo Xpress’s apps and websites (see Facebook’s privacy policy for information on their collection and use of data)
• Marketing partners and marketing platform providers, including social media advertising services
• Data analytics providers
• Research partners, including those performing surveys or research projects in partnership with Bongo Xpress or on Bongo Xpress’s behalf
• Vendors that assist us to enhance the safety and security of its apps
• Consultants, lawyers, accountants, and other professional service providers
• Fleet partners and other local delivery partners
• Insurance and financing partners
• Vehicle solution vendors or third-party vehicle suppliers

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

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

This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect our rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services.

This also includes sharing personal 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 personal data other than as described in this notice if we notify the user and they consent to the sharing.

1. Data retention and deletion

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

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 the reasons stated in this policy.

We retain user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the category of user to whom the data relates, the type of data, and the purposes for which we collected the data.

Users may request deletion of their account at any time through the Settings > Privacy menus in the Bongo Xpress app, or through Bongo Xpress’s website.

Following an account deletion request, we delete 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 pilots, this generally means that we retain their account and data for a minimum of 7 years after a deletion request. For customers (recipients), their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.

1. Grounds for processing

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of Bongo Xpress’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consents.

A- To provide requested services and features

In order to provide our services, we must collect and use certain personal data. This includes:

• User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their trips, orders, and accounts; and enable users to make payments or receive earnings.
• Background trip information, which is used to verify an applicant’s eligibility to be a pilot.
• Pilot location data, which we use to track trips and assist with navigation.
• Usage data, which is necessary to maintain, optimize, and enhance Bongo Xpress’s services, including to determine incentives, connect users and pilots, and calculate costs of trips and driver earnings.
• Transaction information.
• Information relating to customer support.

B- For purposes of the legitimate interests of us or other parties

This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of Bong Xpress’s apps. We also use usage data to prevent matching of users and pilots for whom there is higher risk of conflict (for instance, because they have been the subject of prior complaints from other users).

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing our Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

C- To fulfill Bongo Xpress’s legal obligations

For example, Bongo Xpress is subject to laws and regulations that require it to collect and retain data about our users’ trips and deliveries, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

We may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. We may also share information with public health authorities and ICT Ministry where required or permitted by law.

D- With consent

We may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

Choice and transparency

When you visit our portals and use this app, you are accepting the practices described in this Privacy Policy.

We may change the data privacy practices and update this privacy policy as and when the need arises, and the same will be made available on the website. But our commitment to protect the privacy of website users will continue to remain. We suggest that you regularly check this privacy policy to apprise yourself of any updates. Your continued use of website or provision of data or information thereafter will imply your unconditional acceptance of such updates to this privacy policy.

We, Bongo Xpress, abide by all the rules and regulations under National E-commerce Policy 2021.  Please contact us at support@bongoxpress.com and let us know if you have any questions or comments about our policies or practices.