Last updated May 21, 2024

Etravelcon Limited (also referred to as “Etravelcon”), is a Private Limited Company incorporated and duly registered under the Laws of the Federal Republic of Nigeria with its registered office at No. 4, Opposite Cedar Trust Hospital, Eneka-Igboetche Road, Off First Market Roundabout, Eneka, Rivers State, Nigeria.

In the exercise of its statutory powers, Etravelcon launched Clozadriva (same as Clozadriver), an application for Drivers with their vehicles and Clozaride, an application for passengers requesting rides.

Individuals using the Clozaride application, to request transportation or logistic services are referred to as “Passengers”, and Individuals using Clozadriva or Clozadriver application to provide these services to the passengers are referred to as “Drivers”.

The term “users”, “user”, “you” or “your” refers to the passenger (rider who requests, hires and/or receives a transportation service using any of our platforms) and/or the driver (person who use any of our platforms to connect and render transport and/or logistic services).

This “data use and privacy policy notice”, describes how and why we collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Download and use our mobile application (Clozadriva, Clozadriver and/or Clozaride), or any other application of ours that links to this privacy notice
• Engage with us in other related ways, including (but not limited to) funding your Pocket on Clozadriva, Clozadriver, any sales, marketing, or events.

(A) What information we collect

Personal Data

• Contact details: things like name, phone number and e-mail address. For some of our services we might require a little more, like your home address and country of residence.
• Profile information: things like your profile picture, saved addresses, language and communication preferences. For some of our services we might require a little more, like your driver license details.
• Payment information: like account number, bank name, the amount charged and the payment card used.
• Communication and correspondence records: such as when you engage with our inapp chat, or speak with our customer service agents.
• Other user-generated content: such as feedback submitted, ratings, reviews, comments and audio recordings taken during the trip (as part of our safety toolkit trip audio recording feature), where such feature is available.
• Information for promotions:From time to time, we may run car branding, referral and other promotional programs. If you wish to participate in such programs and receive bonuses, payments or other benefits, we may ask you to provide information such as your name, email, user ID, phone number, payment or banking information, home address, social media account, vehicle type and image.

A lack of (or inaccurate) personal data may prevent us from fulfilling our contract with you, or from doing something expected of us in law. It may also mean that we cannot operate your account. For example, we collect and process the personal data submitted by you in the course of installing and using the Etravelcon platform and it’s applications; refusing to allow access to location data via any of our App that requires it means that we cannot direct a driver to your location for pick-up, nor can we show you one of our own vehicles close to you for hire. We will not be able to fulfil our obligations to you in other circumstances, for example, should you refuse to undertake an identity verification check to ensure the integrity of your account, then the account may be suspended or blocked to prevent fraud.

(B) Information you provide

i. Clozadriva/Clozadriver App Requirements

(Drivers Registration/sign-up information)

1. Full Name (First Name and Last Name).
2. Email address.
3. Bank account number.
4. Bank name.
5. NIN Number.
6. Profile picture.
7. License data and status.
8. Vehicle information (such as type, make, model, year of manufacture, color, registration certificate data, license plate, vehicle inspection report, vehicle image, vehicl VIN number).
9. Proof of identity.
10. National/state identification numbers
11. ID document (including driver license, passport),
12. Proof of residency
13. Home address
14. Country of residence
15. Date of birth
16. Gender
17. Emergency contact (including next of kin full name, phone number and residential address)
18. Taxation identifier number (where applicable),
19. Relevant insurance (Where needed),
20. Driving record
21. Payment or banking information
22. Other documents which may be required by applicable regulation. Where permitted or required by law, we may additionally collect background checks and criminal records information. This information may be processed by authorized vendors on our behalf. Without providing such information, you will not be able to register as a Driver.

ii. Clozaride Requirements

(Passengers Registration/sign-up information)

1. Full Name (first name, and last name)
2. Phone number
3. Email Address
4. Date of Birth
5. Gender
6. City and Country
7. Profile picture/selfie for identification checks
8. National ID numbers
9. Credit Card details for online payment users
10. Social media accounts for safety purposes
11. Emergency contact numbers.

(C) Information we collect automatically

• Location information: We collect users’ location data to enable ride request and ride request acceptance services, provide user support, ensure safety, detect fraud, and comply with legal requirements. We collect location information (including GPS coordinates and WiFi data) based on your Clozaride, Clozadriva or Clozadriver App settings and device permissions. These apps requires you grant permission/access to device location in other to function.
• Passengers (Clozaride): We collect your device’s precise location when the app is running in the foreground (app open and on-screen) and when the app is running in the background (app open but not on-screen) from the time you request a ride until it ends. Where applicable, Passengers may use the app without enabling it to collect precise location data from their mobile devices by directly inputting the pickup and drop-off address or coordinates into the app.
• Drivers (Clozadriva or Clozadriver): We collect your device’s precise location when the app is running in the foreground (app open and on-screen) and when the app is running in the background (app open but not on-screen) in the Driver mode. We may also collect precise location for a limited time after you exit Driver mode to detect and investigate ride incidents.
• Transaction information: We collect transaction information related to the services provided, including amount charged, payment transaction information, date and time the service was provided, route and distance traveled.
• Usage information: : We collect data about your use of our App Platforms, such as access dates and times, features or pages viewed, Platform crashes and other system activity. Where you provide express consent we may collect recordings of your in-app activities. We may also collect and use for marketing purposes the data related to third-party services you used before interacting with our Platforms.
• Communications information: We enable users to communicate with each other and with us through our App Platforms. To facilitate this, we receive data about the time and date of the communications and the content. We may use this data to provide user support and resolve disputes between users, identify violations of Etravelcon rules, ensure safety, and improve our App Platforms.
• Device information: We collect information about the device you use to access our App Platforms, such as your device name, brand and model, user agent, IP address, mobile carrier, network type, time zone settings, language settings, advertising identifiers, browser type, operating system and its version, screen parameters, battery state, and installed applications that can be used for authentication and anti-fraud purposes. We may also collect mobile sensor data, such as speed, direction, altitude, acceleration, deceleration, and other technical data.

(D) Information we obtain from other sources

• Third-party services: We may receive information about users from our service providers, which include background check and identity verification providers, insurance partners, financial services vendors and marketing service providers. If you choose to use a third-party communication application (such as WhatsApp) or sign up using a third-party service (such as Facebook), where this functionality is available, we may collect information from these services..
• State Authorities: We may receive information about users from law enforcement agencies and other government authorities as required or authorized by law.
• Other users or third parties: Third parties may provide us with information about you, for example in connection with referral programs or through user support (such as information related to an incident or complaint, including audio, video, images, and documents).

(E) How we use your information

We process your personal data so we can provide you with one or more of our transportation services:

• We connect you with a driver, or help you hire a vehicle: We collect and process personal data for the purpose of connecting passengers with drivers so you can be picked up and dropped off; or to show you where the nearest available hire vehicles are located, such as cars or vehicles. Instant messages directly in our applicable Apps are 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.
• We get you to where you want to go: We display your location data and the phone number of passengers to drivers to enable efficient pick-up and drop-off, and make the journey and route transparent. This data is collected only when the applicable App in the circumstance is activated.
• We make sure the App is optimal: We use contact details to notify passengers and riders of updates to the Etravelcon Platforms so you can keep using our services. We also gather limited data from the device that you use to connect you with our internet, mobile and telephone services, and to help keep your account safe through authentication and verification checks.
• We maintain and promote standards: We collect data about journey statuses, time and passenger ratings from driver feedback to encourage user safety, promote compliance with our terms and conditions, and make sure we’re providing a quality and enjoyable service to everyone. Customer support data and correspondence is collected for the purposes of feedback, and resolving disputes and service quality issues.
• We keep you informed: Your name, phone number and email address will be used to communicate with you for things like letting you know about important service updates.
• Entry into and performance of the contract (incl., provision of service): To provide the services contracted through the Etravelcon Platforms with you. This means that to give you the service we promised you, and to meet our terms and conditions, we’ll process your personal data to meet those obligations.
• Automated decision-making: : We connect Drivers and Passengers, based on such factors as availability and proximity, we determine user ratings, and deactivate users with low ratings, flag or temporarily suspend users who are identified as having engaged in fraud, unsafe or harmful activities. In some cases, such activities may lead to deactivation and recommending an average fare, based on such factors as distance, location and time. Where required by law, actions (including deactivation) based on such processing occur only after human review and/or the possibility to appeal. To object to a decision resulting from these processes, please contact us
• To protect rights and comply with legal requirements: We enhance compliance with license or permit requirements, and any other applicable laws and regulations, and to respond to law enforcement requests, government inquiries, subpoenas, court orders, legal claims in a bit to protect the rights and interests of Etravelcon, her various applications or platforms, our users and/or the public.

(F) How we share your information

i. With other Users: We share certain information about users to enable the scheduling and provision of rides:

• Passenger information shared with Driver includes name, profile picture (if uploaded), rating, pickup and drop-off locations, number of trips, offered fare, comments and contact information.
• Driver information shared with Passenger includes full name and profile picture, information about the vehicle and its photo, location before and during the trip, ratings and reviews, number of trips, age (for certain features) and contact information.
• When required to provide Passengers with receipts and invoices, we may share information about the origin and destination of the trip, the total duration and distance of the trip, itemization of the total fare, Driver’s name, and other information required by law.
• If you register with any of our Platforms via a referral link, we may share certain information about you, such as your name and trip count, with the user who referred you. This is to enable the referring user to check whether they are eligible for the referral bonus.
• For the purposes of services other than the transportation services provided via our Platforms, we will share the information with other users that is necessary for the provision of such services.

ii. With service providers: We may share your personal information for business purposes with providers of the following services:

• Payment processing and transaction fulfillment, user and technical support, background checks, identity verification, insurance, Database, cloud storage, content delivery, in-app messaging, in-app calling, push notifications, anti-fraud, advertising, marketing, and analytics, research and surveys, payment of bonuses and provision of other benefits related to our promotions, consultants, lawyers, accountants, auditors, other professional services and airports.
• Etravelcon rely on Google to provide most of the services listed above. Google, as independent Controller, process data for their own purposes and we do not control such processing: - Google, in connection with the use of Google Maps (see privacy policy ), Firebase (see Firebase Data Privacy Inquiries ). We also rely on Emailjs (see Emailjs Privacy Policy ) to send email of your signup information as well as your account deletion information to our official email directly from the apps for processing.

iii. Within the corporate group: We may share your information with a parent, subsidiary, or an affiliate of our corporate group as part of our global operations. In connection with a business transfer. We may transfer personal information in connection with a substantial corporate transaction in which personal information is among the assets to be transferred.

iv. For legal reasons: We may disclose your personal information when it is necessary to protect rights and comply with legal obligations.

v. With your consent: We may share your personal information for other purposes pursuant to your consent or at your direction.

(G) Your rights and choices

Accessing, receiving and updating your information: You may access, review and update your information either in your account settings in the app.

Deleting your account and data: You can delete your account through the App settings. You may not be able to delete your account if there is an unsettled debt or an unresolved issue related to your account (for example, an unresolved complaint). We may retain certain information after your account is deleted provided there is a legitimate basis for such.

Sharing location information: Your device may have controls that determine what information we collect. For example, you can prevent your device from sharing location information through your device’s system settings.

Right to data portability: You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you, in certain circumstances. This only applies to information you have given us.

Objections and withdrawal of consent: You have the right to object to us processing your information where processing is based on our legitimate interests. You can also withdraw consent to processing at any time where processing is based on your consent. In particular, you may exercise these rights by:

• Unsubscribing from marketing emails and messages.You can opt out of marketing emails and messages by using the “unsubscribe” link or the mechanism noted in such emails and messages.

Restrictions: You can request that we limit our use of your data. We may continue to process your data after such a request to the extent required or permitted by law.

Right to complain to the supervisory authority: Under the local law, you may have the right to file a complaint with your local supervisory authority.

(H) How we protect your information

• Any personal data collected in the course of providing our services is kept safe. Only authorized employees of Etravelcon 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) or to provide customer support when necessary.
• We take reasonable and appropriate technical, legal, and organizational security measures to protect your personal information from any unauthorized action including but not limited to access, disclosure, alteration, or destruction leading to loss, theft, or misuse of your data.
• We do our best to affirm our commitment to safeguarding your information. We regularly review our security measures to consider available new technology and methods. Since absolute security does not exist either on or off the Internet, we cannot guarantee the absolute security of your information, especially against maliciously intended acts by third parties where the cost for the successful attack multiplies several times the value of the data possibly compromised. Nevertheless, we make commercially reasonable efforts to keep your information safe.

(I) How we store your information

We keep your personal information for as long as you have an account with us. We may retain certain information after account termination for legitimate reasons:

• We will retain transactional information (such as data about rides and payments) for as long as needed to meet our tax obligations.
• We will retain the information for the period required by the licensing regulator (where applicable). The retention period will vary depending on your location and the type of data.
• We will retain correspondence and other documentation for as long as this is required for compliance with statutory document retention obligations.
• If there is a legal claim or dispute or any possibility thereof, we will retain corresponding information until the claim is satisfied/dispute is resolved or the statute of limitation expires.
• We will also retain data relevant to prevent fraud, to ensure users safety, to comply with our legal obligations for a period needed to fulfill these purposes.

(J) How We Resolve Dispute

• Disputes relating to the processing of personal data are resolved through customer support (info@etravelcon.com).
• You have the right to lodge 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.

(K) General disclosures

Telephone monitoring: Telephone conversations may be monitored and recorded for quality assurance and training purposes

Protecting children: Clozadriver and Clozaride apps are not directed to children (as defined in the local laws). Should we discover that we hold personal information of a child, we will use reasonable endeavors to delete this data and ensure that it is not further used or shared. If you believe a child has provided us with personal information, please contact us

Third-party collections: Certain third parties may use automatic information collection technologies, including cross-site tracking technologies, to collect personal information. These third parties may include your internet service provider, web browser, mobile service provider, mobile device manufacturer, online advertisers, and data analytics companies. Additionally, our Platform may contain links to third-party platforms. Clicking on such links means that the respective platform may collect your personal information. We are not responsible for the privacy practices of third parties

Changes: We may update this policy from time to time to reflect the changes in laws or in how we operate. When we update this policy, we will notify you by updating the “Last Updated” date at the top of this page and by posting the new Privacy Policy and providing any other notice required by applicable law. When you use our Platforms, you are agreeing to the most recent terms of this policy.

Contact us

Please, contact us