Do More With Flex

PRIVACY POLICY

Flex Privacy Notice: Riders and Order Recipients When you use Flex, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

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

Flex Privacy Notice: Drivers and Delivery People Previous version of the Privacy Notice Illustration of passenger checking their phone

I. Overview

II. Data Collections and Uses

  a. Data we collect

b. How we use data

c. Core automated processes

d. Cookies and related technologies

e. Data sharing and disclosure

f. Data retention and deletion

III. Choice and Transparency

IV. Legal Information

a. Data controllers and Data Protection Officer

b. Our legal basis for using your data

  c. Legal framework for data transfers

d. Updates to this Privacy Notice

I. Overview

a. Scope This notice applies when you use Flex’s apps or websites to request or receive products or services, including rides or deliveries.

This notice describes how we collect and use your data if you request or receive products or services through Flex’s apps or websites, except when you use Flex Fleet, Flex Freight or its subsidiaries.

This notice specifically applies if you:

Request or receive mobility services, including rides and package delivery and return services through Flex Community, via your Flex account (a “Rider”). Request or receive food or other products and services for delivery or pickup, including via your FlexGO, FlexBITE or FlexDApp account, or through the guest checkout features that allow you to access delivery or pickup services without creating and/or signing into your account (an “Order Recipient”).

Receive services through Flex’s apps or websites requested by other account owners (a “Guest User”), including if you receive ride or delivery services ordered by FlexDApp, Domestic, National, or Flex for Business and Corporate customers (collectively, “Enterprise Customers”); or by friends, family members or other individual account owners, including via FlexCONNECT; or receive a gift card. 

Rent a vehicle through Flex Hailing Services (a “Hailing”). This notice does not describe Flex’s collection and use of your data if you use Flex to provide (instead of request or receive) services through Flex’s app or websites, including as a driver or delivery person. Flex’s notice describing our collection and use of such data is available here. Those who use Flex to either request, receive or provide services are referred to as “users” in this notice.

Our privacy practices are subject to applicable laws in the places in which we operate. The types of data processing that such laws require, allow, or prohibit vary globally. Therefore, if you travel across national, state or other geographic borders, Flex's data processing practices described in this notice may differ from those in your home country or territory.

II. Data collections and uses

a. The data we collect

Flex collects data:

1. That you provide

2. When you use our services

3. From other sources

Please go here for a summary of the data we collect and how we use it.

Flex collects the following data:

1. Data you provide: This includes:

** Data category

** Data types

a. Account information. We collect data when you create or update your Flex account.

Address

Email

First and and last name

Login name and password

Phone number

Payment method (including related payment verification information)

Profile images including avatars and emojis

Settings (including accessibility settings) and preferences

Flex partner loyalty program information

b. Demographic data. We collect demographic data if necessary to enable certain features.

For example:

We collect your date of birth and/or age to verify your eligibility to use age-restricted products or services, such as Flex for teens, or if you purchase alcohol, tobacco or cannabis products or illegal substance whatsoever are not allowed for use on the Flex platform.

We collect or infer your gender to enable Women Rider Preference, and for marketing and advertising.

We may also collect demographic data through user surveys.

Age or date of birth

Gender or inferred gender (using first name)

c. Identity verification information.

This refers to the data that we collect to verify your account or identity.

Government-issued identification documents, such as driver’s licenses, NIN, Voter’s Card,

BVN or passports (which may contain identification photos and numbers, expiration date, date of birth, and gender)

User-submitted selfies

d. User content. This refers to the data that we collect when you:

** Contact Flex for customer support or other inquiries.

** Use features that enable you to create Lists or reviews of restaurants or merchants

** Upload photos and recordings (including those submitted for purposes of customer support)

** Provide ratings or feedback for drivers, delivery people, restaurants or merchants, or they provide feedback regarding you.

Please go here for more information about how ratings provided by other users are determined and used on our website www.flex2ride.com homepage.

** Chat logs and call recordings

** Ratings or feedback

** Flex User created Lists or reviews of restaurants or merchants

** Uploaded photos and recordings, including in-app audio recordings

e. Travel information.

We collect travel itinerary information if you book bus, train or flight travel through Flex's apps. Dates/times of travel

2. Data collected when you use our services: This includes:

** Data category

** Data types

a. Location data. If you request a ride, we track your driver’s location during your trip, and link that data to your account. This allows us to display where you are on your trip.

We also determine your approximate location, and can determine your precise location if you allow us to do so through the settings on your phone. If you do, we will collect your precise location from the time you request a ride or order until the ride is finished or your order is delivered.

We also collect such data when you have the Flex app open on your phone’s screen.

You can use Flex without letting us collect your precise location. However, it may be less convenient for you, including because you will have to type your location into your phone instead of allowing us to detect it for you.

See “Choice and Transparency” section below for information on how to control whether Flex may collect your precise location data.

** Approximate location

** Precise location

b. Trip/order information. This refers to the details we collect about your trip or order, including orders placed via guest checkout features.

** Payment information (including amount charged and payment method)

** Proof of delivery (including photo or signature)

** Special instructions, allergies or food preferences

** Statistics derived from past trip/order information, such as

-Averages

-Cancellation rates

-Total trips/orders

-Trip or order details, including

-Date and time

-Requested pickup and dropoff addresses

-Distance traveled

-Restaurant or merchant name and location

- Items ordered

c. Usage data. This refers to data about how you interact with Flex’s apps and websites.

** App crashes and other system activity

** Access dates and times

** App features or pages viewed

** Browser type

d. Device data. This refers to data about the device(s) you use to access Flex services.

** Advertising identifiers

** Device motion data

** Device IP address or other unique device identifiers

** Hardware models

** Mobile network data

** Operating systems and versions

** Preferred languages

e. Communications data. This refers to the data we collect when you communicate with drivers and delivery people through Flex’s apps.

** Communication type (phone or text message)

** Content (including recordings of phone calls solely when users are notified of the recording in advance)

** Date and time

3. Data from other sources: These include:

** Data category

** Data types

a. Law enforcement officials, public health officials and other government authorities.

** Name and contact information

** Information relating to law enforcement, health or other investigations

b. Marketing partners and service providers. This includes banks in connection with cash back programs, and data resellers.

** Activity information

** Name and contact information

** User or device identifiers

c. Service providers who help us verify your identity or detect fraud.

** Confirmation of whether your account information relates to known persons

** Name and contact information

** Information relating to the wireless carrier associated with your phone number

** Information from government-issued identification documents such as driver’s licenses or passports (such as identification numbers, expiration date, date of birth, and gender)

d. Flex account owners. This refers to Flex account owners who request services for you (such as friends or family members), or who enable you to request services through their accounts (such as Enterprise Customers).

** Name and contact information

** Trip/order info

** Location

e. Flex business partners (account creation and access, and APIs). Flex may receive your data from business partners through which you create or access your Flex account, such as payment providers, social media services, or apps or websites that use Flex’s APIs or whose APIs Flex uses.

The information received from Flex business partners depends on which partners you use to create or access your Flex account, or the API used.

f. Flex business partners (debit or credit cards). Flex may receive your data from business partners in connection with debit or credit cards issued by a financial institution in partnership with Flex to the extent disclosed in the terms and conditions for the card.

** Debit or credit card activity information

g. Users or others providing information in connection with customer support issues, claims or disputes.

** Name

** Evidence relating to accidents, conflicts, claims or disputes (which may include photos or recordings of you)

h. Users participating in Flex’s referral programs. For example, if you are referred to Flex by another user, we receive your data from that user.

** Name and contact information

B. How we use data:

Flex uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use data:

** To enhance the safety and security of our users and services, and to prevent and detect fraud

** For marketing and advertising

** To enable communications between users

** For customer support

** For research and development

** To send non-marketing communications to users

** In connection with legal proceedings

1. To provide our services. Flex uses data to provide, personalize, maintain, and improve our services.

** Data uses

** Data used includes

a. Creating and updating your account

** Account

** Demographics

** Location

b. Enabling services and features. This includes:

** Enabling navigation to pickups and dropoffs, calculating ETAs and tracking the progress of rides or deliveries

** Matching you with available drivers or delivery people when you request transportation or deliveries

** Enabling features that involve data sharing, such as ETA sharing and fare splitting

** Enabling accessibility features

** Enabling features that involve account linking, such as linking with Flex partners’ loyalty programs

** Facilitating and optimizing rental car reservations, pickup and dropoff through Flex Fleet Account

** Data from other sources

** Demographics

** Device

** Ratings

** Travel

c. Calculating rider/recipient prices and driver/delivery person fares.

** Location

** Trip/order info

d. Processing payments and enabling payment and e-money products such as Flex payment system service by third-party APIs.

** Account

** Demographics

** Data from other sources

** Trip/order info

e. Personalizing your account. For example, we may present you with personalized restaurant or food recommendations, or trip suggestions, based on your prior orders, trips and delivery location.

** Account

** Demographics

** Data from other sources

** Trip/order info

f. Providing you with trip or delivery updates and generating receipts.

** Account

** Trip/order info

g. Informing you of changes to our terms, services, or policies.

** Account

** Trip/order info

h. Performing necessary operations to maintain our services, including to troubleshoot software bugs and operational problems.

Account

Device

Usage

2. For safety, security, and fraud prevention and detection. Flex uses data to help maintain the safety and security of our services and users.

** Data uses

** Data used includes

a. Verifying your account, identity or compliance with safety requirements. This includes:

** Verifying that you are who you say you are by cross-checking the account information you provide during signup (such as name, email, telephone number, date of birth or payment information) against third-party databases.

** Verifying that your account is being used by you and not someone else by:

** Collecting your ID number and/or a photo of your ID, and completing a verification to confirm that the ID is valid, unaltered and that no other account is associated with that document

** Collecting a real-time selfie that we compare against the photo on your ID to confirm that it’s the same person.

** Verifying your identity and/or age by collecting a photo of your ID when you receive delivery of age-restricted items like alcohol, tobacco or cannabis, or use products like Flex Fleet and Flex Connect

** Verifying, when you rent a bike or scooter through Flex, that you are wearing a helmet, or other mandatory safety gear, by collecting a real-time selfie and using object verification technology

** Verifying your eligibility to subscribe to a Flex Hub for Students membership Account

** Data from other sources (third-party databases)

** Identity verification info

** User content

b. Preventing, detecting, and combating fraud, including by Guest Users.

** Account

** Demographics

** Data from other sources

** Trip/order info

** Data from other sources (driver data)

Usage

c. Predicting and helping avoid pairings of users that may result in increased risk of conflict, or where one user has previously given the other a low (for instance, one star) rating.

** Account

** Trip/order info (including cancellation rates)

** Usage

** User content (ratings and reported incidents)

d. Providing live support from safety experts during trips or deliveries.

** Account (phone, user name, vehicle details)

** Trip/order info

** User content

** Location

3. For marketing and advertising. Flex uses data (except Guest Users’ data) to market its services, and those of Flex partners.

** Data uses

** Data used includes

a. Personalizing marketing communications and ads relating to Flex products and services, and those offered by other companies. For example, Flex may:

** Send push notifications suggesting your favorite destinations or merchants, or in-app messages offering discounts or promotions for products or merchants similar to those you’ve previously ordered

** Display personalized ads on Flex or other companies’ apps or websites

** Personalize sponsored listings, discounts or promotions for restaurants and merchants available on Flex

** Account

** Data from other sources

** Demographics (including inferred gender)

** Device

** Location

** Trip/order info

** Usage

b. Displaying ads that are targeted based on data about your current trip or delivery request, including time of request and services requested. For example, if you request a trip to a supermarket, we may display in-app ads for third-party products that may be available at that supermarket.

** Account

** Data from other sources

** Demographics (including inferred gender)

** Device

** Location

** Trip/order info

** Usage

c. Measuring the effectiveness of the marketing communications and ads described above.

** Account

** Device

** Usage

4. To enable communications between users.

** Data uses

** Data used includes

For example, a driver may message or call you to confirm a pickup location, you may call a driver to retrieve a lost item, or a restaurant or delivery person may contact you with information about your order.

Account

** Device

** Usage

5. For customer support.

** Data uses

** Data used includes

This includes investigating and addressing user concerns, monitoring and improving our customer support responses and processes, and identifying potential participants in research studies relating to customer support issues.

** Account

** Device

** Usage

** User content

** Location

** Trip/order info

** Data from other sources

** Identity verification info

6. For research and development.

** Data uses

** Data used includes

We use data for analysis, research and product development, including training machine learning models. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our services, and develop new services and features.

** Account

** Device

** Usage

** User content

** Location

** Trip/order info

** Data from other sources

** Identity verification info

7. For non-marketing communications.

** Data uses

** Data used includes

This includes surveys and communications regarding elections, ballots, referenda and other political processes that relate to our services. For example, we may notify you of ballot measures or pending legislation relating to Flex’s services where you live.

** Account

** Location

8. For legal proceedings and requirements.

** Data uses

** Data used includes

We use data to investigate or address claims or disputes relating to use of Flex’s services; to satisfy requirements under applicable laws, regulations, operating licenses or agreements, insurance policies; or pursuant to legal process or governmental request, including from law enforcement.

** Account

** Device

** Usage

** User content

** Location

** Trip/order info

** Data from other sources

** Identity verification info

C. Core automated processes

** Flex uses automated processes to enable certain parts of our services, including functions essential to our business such as matching, pricing and fraud prevention and detection.

** Flex relies on automated processes to enable essential parts of our services, including matching (pairing users requesting and providing transportation and/or delivery services), pricing (calculating the amount owed for such services) and fraud detection and prevention. These processes allow Flex to provide a seamless, and safe, experience to millions of users globally every day.

This section describes how automated matching, pricing, and fraud prevention and detection processes work, including how they impact your Flex experience and the personal and non-personal data used to enable these processes.

You may contact Flex here if you have questions or concerns regarding these processes.

1. Matching

Flex uses algorithms to efficiently match Riders and drivers, or delivery people and Order Recipients. This helps us minimize wait times for you, and enable efficiency for drivers and delivery people.

The matching process is triggered when you request transportation or deliveries through Flex. Our algorithms then evaluate various factors to determine the best match, including your location, requested destination, the proximity and availability of drivers or delivery people, traffic conditions, and historical data (including, in some markets, whether the specific Rider and driver have previously reported having negative experiences with each other).

The trip or delivery request is then communicated to the driver/delivery person matched through this process. Once a trip or order is accepted, we send confirmation of the match to you and the driver/delivery person.

We are constantly refining our matching process to provide the best experience to all users on our platform and may consider different factors depending on the location where you use Flex.

Additional information on Flex’s matching process is available here.

2. Pricing

When you request transportation or a delivery, Flex uses algorithms to determine the price you pay based on a variety of factors, including:

The type of service you request (for instance, FlexBUDGET, FlexPREMIUM, FlexVIP)

** Your location

** Estimated time and distance to destination

** Availability and proximity of drivers or delivery people

** Time of day

** Traffic conditions

** Historical data such as traffic patterns and seasonal trends.

Your price may also vary depending on tolls or surcharges incurred, tips, discounts, promotions and subscriptions, and route-based adjustments.

The price may also vary depending on surge pricing, which automatically goes into effect when there are more Riders in a given area than available drivers. This encourages more drivers to serve the busy area over time and shifts Rider demand, to maintain reliability and restore balance.

Additional information on Flex’s pricing process is available here.

3. Fraud prevention and detection

Flex uses algorithms and machine learning models to prevent and detect fraud against Flex or our users. This includes efforts to monitor for account takeovers, suspicious user behaviors, and unauthorized access attempts, including by third-party aggregators.

These tools look for patterns that may indicate fraudulent behavior, such as those that vary significantly from typical user behavior. To do this, Flex performs real-time monitoring of information collected from or generated by users, including location data, payment information, and Flex usage. We also examine historical data and compare it against real-time data to help detect suspicious behavior.

Flex may limit your access to its services, or require that you undertake a particular action such as verifying your identity before allowing such access, if it detects potential fraudulent activity.

You may contact Flex customer support here if you have questions or concerns about these processes.

D. Cookies and related technologies

Flex and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice, and Flex’s Cookie Notice. Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and ads. Flex uses cookies and similar technologies for purposes such as:

** Authenticating users

** Remembering user preferences and settings

** Determining the popularity of content

** Delivering and measuring the effectiveness of advertising campaigns

** 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 ads on our behalf across the internet or for other companies’ products and services on our apps, and to track and report on the performance of those ads. These entities may use cookies, web beacons, SDKs and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

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

E. Data sharing and disclosure

We share your data with other users where necessary to provide our services or features, at your request, or with your consent. We also share data with our affiliates, subsidiaries, service providers and partners, for legal reasons, or in connection with claims or disputes.

Flex may share data:

1. With other users

** This may include sharing data with:

** Recipient

** Data shared

** Your driver

** Account

** First name

** Rating

** Pickup and/or dropoff locations

** Settings and preferences

** Other Riders during shared rides

** Account

** First name

** Restaurants/merchants you order from, and your delivery person

** Delivery address (including with restaurants/merchants that use their own delivery people to fulfill your order)

** Order info

** Items ordered (which may include drug prescriptions)

** Special instructions, allergies or food preferences

** User content

** Feedback

The owner of any Flex account you use. This includes if you use an account linked to a Family profile, or request or receive ride or delivery services as a Guest User of an Enterprise Customer’s account. In addition, if you create an account using an email address affiliated with a Flex for Business account owner (i.e., your employer), we may share your account data (such as name and email address) with such account owner, to help you expense trips or orders to that Flex for Business account.

Account

Trip/order info

Other recipients in your group order

Account

First name

Order info

Special instructions or allergies information

Items ordered

People who refer you to Flex. We may share your data as necessary to determine their referral bonus

Trip/order info

Trip count

Other FlexBITE users. We share your data if you post a review of a restaurant or create a List of your favorite restaurants on FlexBite, and set sharing of the List to "Public."

Account

First name

User content

Lists

Reviews

2. Upon request or with your consent

This may include sharing data with:

Recipient

Data shared

Users with whom you use data-sharing features. This includes features that allow you to share your ETA and location, or split your fare.

Depending on the feature used, may include:

Account

Location

Trip/order info

Flex business partners. We share data with companies whose apps or websites you access through Flex, including for purposes of promotions, contests or specialized services. Depending on the app or website you access through Flex, and for what purpose, may include:

Account

Device

Trip/order info

Emergency services. We enable you to share your data with police, fire, and ambulance services in the event of an emergency or after certain incidents. For more information, please go to the "Choice and Transparency" and "Emergency data sharing" sections below.

Account

Name

Phone number

Location

Trip/order info

Requested pickup/dropoff

Insurance companies. If you are involved in an incident, or report or submit a claim to an insurance company relating to Flex's services, Flex will share data with that insurance company for the purpose of adjusting or handling that claim.

Data necessary to adjust or handle the claim, which may include:

Account

Communications between users

Device

Location

Trip/order info

Usage

User content

Merchants or Restaurants. If you add a restaurant or merchant loyalty membership number to your user account, we share that data with the restaurant/merchant when you place an order with them.

We also enable you to share your phone number, email and/or order info with restaurants or merchants to receive marketing communications from them.

Account data

Email

Phone number

Restaurant/merchant loyalty membership number

Order info

3. With Flex service providers and business partners

These include the third parties, or categories of third parties, listed below. Where a third party is identified, please go to their linked privacy notices for information regarding their collection and use of personal data.

Accountants, consultants, lawyers, and other professional service providers.

Ad and marketing partners and providers, including ad and marketing publishers (such as social media platforms), ad networks and advertisers, third-party data providers, ad technology vendors, measurement and analytics providers, and other service providers. Flex uses these vendors to reach or better understand current and potential users of Flex services or of our advertising partners, and measure and improve ad effectiveness.

Cloud storage providers.

Customer support platform and service providers.

Google, in connection with the use of Google Maps in Flex's apps.

Identity verification and risk solutions providers.

Payment processors and facilitators, including Cards, Wallets and other electronic payment system.

Providers of bikes and scooters that can be rented through Flex apps, such as Qlink, Lime, Patronas Cycle and Tembici.

Research partners, including those performing surveys or research projects in partnership with Flex or on Flex's behalf.

Social media companies, including X, Meta and TikTok, in connection with Flex's use of their tools in Flex's apps and websites.

Service providers that assist Flex to enhance the safety and security of Flex apps and services.

Service providers that provide us with artificial intelligence and machine learning tools and services.

Third-party vehicle suppliers, including fleet and rental partners.

This also includes ad intermediaries, such as Criteo, Google, Rokt, The Trade Desk, TripleLift and others. We share data including advertising or device identifier, hashed email address, approximate location, current trip or order information, and ad interaction data with these intermediaries to enable their services and for such other purposes as are disclosed in their privacy notices. You may opt out from ad personalization here. For more information regarding these intermediaries' privacy practices, including how to submit requests to them relating to their handling of personal data, please go to their privacy notices linked above.

4. With Flex subsidiaries and affiliates

We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

5. For legal reasons or in the event of a claim or dispute

Flex may share your data if we believe it's required by applicable law, regulation, operating license or agreement, legal process or governmental request, insurance policy, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing data with law enforcement officials, public health officials, other government authorities, insurance companies, or other third parties as necessary to enforce our Terms and Conditions, user agreements, or other policies; to protect Flex's 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. In the event of a dispute relating to use of another person's credit card, we may be required by law to share a user's data, including trip or order information, with the owner of that credit card.

For more information, please see Flex's Guidelines for the Nigerian Law Enforcement, Guidelines for Law Enforcement Authorities - Outside Nigeria, and Guidelines for Third Party Data Requests and Service of Legal Documents.

We may also share 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.

F. Data Retention and Deletion

Flex retains your data for as long as necessary for the purposes described above. Users may request account deletion through the Flex apps and websites.

Flex retains your data for as long as necessary for the purposes described above, which varies depending on data type, the category of user to whom the data relates, the purposes for which we collected the data, and whether the data must be retained after an account deletion request for the purposes described below.

For example, we retain data:

For the life of your account if such data is necessary to provide our services (such as account data)

For defined periods as necessary, including as necessary to meet tax, insurance, legal or regulatory requirements (for example, we retain transaction information for 7 years)

You may request that we delete your account through the Privacy menus in the Flex app, or through Flex's website (Riders and Order Recipients here; Guest Users here).

Following an account deletion request, we delete your account and data, except as necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to your account (such as an outstanding credit or an unresolved claim or dispute). We generally delete data within 90 days of an account deletion request, except where retention is necessary for the above reasons.

III. Choice and Transparency

Flex enables you to access and/or control data that Flex collects, including through:

Privacy settings

Device permissions

In-app ratings pages

Marketing and advertising choices

You may also request access to or copies of your data, make changes or updates to your account, request account deletion, or request that Flex restrict its processing of your data.

1. Privacy Settings

You can set or update your preferences regarding location data collection and sharing, emergency data sharing, and notifications in Flex's Privacy Center, which is accessible via the Privacy menu in the Flex apps.

Location data collection

You can enable/disable Flex's collection of your mobile device location data through your device settings, which are accessible via the location sharing menu in the Privacy Center in Flex's apps.

Share live location

You can enable/disable Flex's sharing of your mobile device real-time location data with your drivers or delivery people through your device settings, which are accessible via the Account > Settings > Privacy > Location sharing menu in Flex's apps.

Gender identity

You can update your gender information through the Account > Settings > Privacy > Ads and Data > Gender Identity menu in Flex's apps.

Emergency data sharing

You may enable Flex to share your data with emergency police, fire and ambulance services if necessary during a trip. If you do, we will share data including your name and phone number; approximate location at the time the emergency call was placed; the car's make, model, color, and license plate information; pickup and dropoff locations; and your driver's name.

You can enable/disable this feature via the Location sharing menu in the Privacy Center in Flex's apps, or the Safety Center.

Notifications: discounts and news

You may enable Flex to send push notifications about discounts and news from Flex here.

Third-party app access

You may authorize third-party applications to access your Flex account data to enable additional features. You can review/withdraw access by third-party applications here.

2. Device permissions

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

3. In-app ratings pages

After every trip, drivers and Riders can rate each other on a scale from 1 to 5. An average of the ratings you receive is displayed to your drivers.

You can find your average rating in the Account section of the Flex app, and also access a breakdown of your average rating in Flex's Privacy Center.

4. Marketing and advertising choices

Personalized marketing communications from Flex

You can choose here whether Flex may personalize marketing communications (such as emails, push notifications and in-app messages) about Flex products and services.

You may also choose here whether to receive any marketing emails or push notifications from Flex.

Data Sharing and Tracking

You can choose here whether Flex may share your data with third parties, or collect data regarding your visits and actions on third-party apps or websites, for purposes of personalized ads.

Personalized ads

You can choose whether Flex uses your Flex trip, order or search history to personalize the ads you see on Flex or FlexGO, FlexBITE, FlexSTAY, FlexBOAT and others.

Cookies and Related Technologies

For information on how to control Flex's use of cookies and related technologies, including for purposes of displaying personalized ads, please see our Cookie Notice.

5. User data requests

Flex provides a variety of ways to learn about, control, and submit questions and comments about Flex's handling of your data. In addition to the methods indicated below, you may also submit data requests via our Privacy Inquiry Form here.

Data access and portability

Depending on where you are located, you may have the right to access your data and to portability of your data.

Regardless of your location, you can access your data, including your profile data and trip or order history, through the Flex apps or website.

You can also use our Explore Your Data to view a summary of certain information about your account, such as your rating, trip or order count, rewards status, and how long you've been using Flex.

You can also use our Download Your Data feature to download a copy of the most requested data relating to use of Flex, including account, usage, communications, and device data.

Changing or updating data

You can edit your name, phone number, email address, payment method, and profile picture through the Settings menu in Flex's apps.

Deleting data

You may request that Flex delete your account through Flex's Privacy Center.

Objections, restrictions and complaints

You may request that we stop using all or some of your data, or that we limit our use of your data. This includes objecting to our use of data that is based on Flex's legitimate interests. Flex may continue to process data after such objection or request to the extent necessary to provide our services, or required or permitted by law.

In addition, depending on your location, you may have the right to file a complaint relating to Flex's handling of your data with the data protection authority in your country.

IV. Legal Information

A. Data controllers and Data Protection Officer

Flex2ride Global Services. is the sole controller of the data processed by Flex when you use Flex's services nationwide and globally, except where it is a joint controller with other Flex partners and affiliates.

Flex2ride Global Services. ("FLEX") is controller of the data processed by Flex when you use Flex's services globally, except that:

Flex2ride LLC., are controllers of the data of users of Flex's payment and e-money services through third-party APIs and licensing.

Flex2ride Global Services and affiliates are together with Flex's joint controllers of the data of users of Flex's third-party payment and e-money services within the jurisdictions where Flex products and services are offered, for users of those services where used.

You may also contact Flex's Data Protection Officer at flex2ride.com/privacy, or by mail to Flex2ride Global Services. (Suite 6, Plot 12 Block 56 Adebayo Doherty Street, Road 14, Lekki Phase 1, Lagos - NG), regarding issues relating to Flex's processing of your personal data and your data protection rights.

B. Our legal basis for using your data

Depending on where you use our services, and our purpose for using your data, Flex relies on the following legal bases for processing your data:

Necessity to perform our contract with you

Consent

Flex's legitimate interests

Legal obligation

Data protection laws in some countries and areas, including the EEA, UK, Switzerland, Brazil and United States, only allow Flex to use your data when certain circumstances defined under those laws apply. This is called having a "legal basis" for using your data. The applicability of these legal bases may depend on your location. The chart below indicates the legal bases that Flex has under those laws when they do apply, and it uses your data for the purposes described in this notice.

Legal basis

Description

Data uses

Contract

When you set up your Flex account and/or request a ride or delivery from Flex, we are entering into a contract defined by our Terms and Conditions to provide you those services.

This legal basis applies when we must use your data in order to provide the services you request and meet our responsibilities under that contract.

Consent

This legal basis applies when we notify you of how we will collect and use your data, and you voluntarily agree to that use of your data (in some cases, by enabling that collection and use through a device or Flex setting).

Where we rely on consent, you have the right to withdraw your consent at any time, in which case we will cease that collection and use of your data.

Personalizing ads relating to products and services offered by other companies

Processing health data, or other sensitive data, depending on the region you live in.

Legitimate Interests

This legal basis applies when Flex has a legitimate purpose for using your data (such as for purposes of safety, security, and fraud prevention and detection), its processing of data is necessary for that purpose, and the benefit of such purpose is not outweighed by risks to your privacy (such as because you would not expect Flex's use of your data, or because it would prevent you from exercising your rights).

Displaying ads that are targeted based on data about your current trip or delivery request

Predicting and helping avoid pairings of users that may result in increased risk of conflict

Preventing, detecting and combating fraud.

Verifying your account, identity or compliance with safety requirements

Providing live support from safety experts during trips or deliveries

Measuring the effectiveness of the marketing communications and ads

Personalizing marketing communications and ads relating to Flex products and services, and those offered by other companies

For non-marketing communications

For research and development

Legal Obligation

This legal basis applies when we are required to use your data to comply with the law.

For legal requirements and proceedings

C. Legal framework for data transfers

Flex operates, and processes user data, globally. We comply with applicable legal frameworks relating to the transfer of data.

Flex operates, and processes user data, globally. This may result in processing of your personal data in countries, including the United States, whose data protection laws may differ from those where you live or are located.

This includes processing of your data on Flex's servers in Nigeria, and transferring or enabling access to your data globally, in order to:

Provide you services wherever you request them

Provide you access to your information, such as trip / order history, wherever you request it

Provide access to and responses from Flex's customer service agents

Respond to requests for information by governments or law enforcement, as necessary

Flex is committed to protecting your personal data regardless of where you are located or where, or by whom, your personal data is processed. This includes implementing global measures to protect users' data, including:

Securing user data when in transit, including through encryption, and at rest.

Mandating company-wide training regarding privacy and data security.

Implementing internal policies and procedures to limit access to, and use of, users' data.

Limiting government and law enforcement access to user data, except where required by law; there are imminent threats to safety; or users have consented to the access.

Please see Flex's Government Transparency Report for more information regarding our practices relating to law enforcement requests.

When we transfer user data from within our operational locations, we do so on the basis of the necessity to fulfill our agreements with you, consent, adequacy decisions regarding the country of transfer (available here, here or here, and transfer mechanisms such as the Standard Contractual Clauses adopted by the regulatory bodies and their Data Privacy Framework, as set forth by the Department of Commerce. Such data remains subject to the GDPR or equivalents after such transfer. Users may contact Flex regarding the above, or to request copies of applicable Standard Contractual Clauses here.

FLEX has certified to the Regulation that it adheres to (1) the Data Privacy Framework Principles regarding the processing of personal data received from within in reliance on the existing policies; and (2) the Nigerian Data Privacy Framework Principles regarding the processing of personal data received from within in reliance on the DPFP. In the event of a conflict between this notice and the Principles mentioned above, the Principles shall govern. In the event that the Nigeria, EU-US DPF or the Swiss-US DPF are invalidated for our users in diaspora, Flex will transfer data that is subject to these certifications in reliance on the other data transfer mechanisms described above.

If you live in the EEA, UK or Switzerland, please note the following:

Scope.: Flex's DPF certification applies to personal data originating from the Nigerian Regulatory Bodies.

Access.: You have the right to access your personal data that is subject to Flex's DPF certification. For information on how to exercise this right, please see "Choice and Transparency" above.

Onward transfer.: Flex is responsible for the transfer of personal data, subject to its certification to third parties. For information regarding the parties to whom Flex may transfer personal data, please see "Data sharing and disclosure" above.

Request from law enforcement.: Flex is required under applicable law to share user data, including that which may be subject to Flex's certification, pursuant to legal process or governmental request, including from law enforcement.

Investigation and enforcement.: Flex is subject to the investigatory and enforcement powers of the Nigerian Trade Commission.

D. Updates to this Privacy Notice

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

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

DATA PROVIDERS

Data Provider Attribution

DataOne is an automotive data source providing data to solution and service providers in North America across many sectors including automotive marketing, transportation, and risk management. http://www.dataonesoftware.com

Google search results may be reordered or augmented by Flex.

INEGI

Red Nacional de Caminos 2016

Información Vectorial de Localidades Amanzanadas y Números Exteriores 2016

Marco Geoestadístico Nacional 2016

Data © OpenStreetMap contributors, https://www.openstreetmap.org/copyright

OPIS DATA © OPIS, LLC. All Rights reserved.

Data supplied by TomTom and its suppliers is supplied on an "as-is" and "all-faults" basis and their liability is excluded in full to the maximum extent permitted by applicable law.

LOCATION INFORMATION

How Flex uses rider location information

You'll see a request prompted by your device for permission to share your location information when you sign up for Flex, which includes location data collected via Bluetooth and nearby wifi signals. For the best service available, the app by default asks you to turn on location services "while using the app" using "precise location."

We use location data to:

Find drivers that are near you and help them navigate to your pickup spot

Display trip history in your receipts

Understand and resolve support tickets

To troubleshoot and solve software bugs

Location settings options

For iOS devices

Always: We may collect location information at any time, even when you're not actively using the Flex app. If a service needs Always, we'll ask for your permission when you enable the service.

While Using the App: We may collect location information when the app is visible on your screen or when you have requested a ride and during your trip. You'll get an iOS notification on screen if location is being collected in the background when you are in the While Using setting.

Never: This option disables location services for the Flex app. You can still use the app, but you'll need to enter your pickup and dropoff locations manually. Location information will be collected from the driver during your trip and linked to your account, even if you have disabled location services for your app.

Precise Location: This option disables precision location services for the Flex app. When off, you can still use the app, but you'll need to enter your pickup and dropoff locations manually. Precise Location information will be collected from the driver during your trip and linked to your account, even if you have disabled precise location services for your app.

For Android devices

While Using the App: We may collect location information when the app is visible on your screen or when you have requested a ride and during your trip. You'll get a notification on screen if location is being collected in the background when you are in the While Using setting.

Only this time: This option enables the location services for the Flex app only for this instance. If you select this option, you'll be prompted again with the location permissions the next time you use the Flex app.

Don't allow: This option disables location services for the Flex app. You can still use the app, but you'll need to enter your pickup and dropoff locations manually. Location information will be collected from the driver during your trip and linked to your account, even if you have disabled location services for your app.

Approximate Location: This option disables precision location services for the Flex app. When selected, you can still use the app, but you'll need to enter your pickup and dropoff locations manually. Approximate Location information will be collected from the driver during your trip and linked to your account, even if you have disabled precise location services for your app.

You can always manage your location settings in your device's location preferences under the Flex app.

Sharing with cities and governments

In some instances, we're required to share information about the orders placed with our service with cities, governments and local transportation authorities.

To meet these requirements, we collect geolocation and timestamp data from the vehicles on our platform. This data provides cities with information on where each order starts, stops, and the route taken. None of the order data we provide to cities is collected from your personal mobile device or directly identifies you, but the data could be identifiable to you, with some effort. In such cases, we'll inform you before the trip.

There are special circumstances, such as preventing fraud and responding to safety incidents, where Flex may collect background location for any user in the While Using setting. A notice would appear in such a case.

We treat your location information in accordance with our User Privacy Notice.