PRIVACY POLICY

I. Introduction
II. Overview
III. Data collections and uses
IV. Choice and transparency
V. Updates to this notice

INTRODUCTION
When you use Prime, 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 we collect, how it’s used and shared, and your choices regarding this data

OVERVIEW
A. Scope
This notice applies to users of Prime’s services anywhere in the world, including users of Prime’s apps, websites, features, or other services.

B. Data controller and transfer
Prime are the data controllers for the personal data collected in connection with use of Prime’s services in the Africa. Prime is the data controller for the personal data collected in connection with use of Prime’s services everywhere else.

Prime the data controllers for the personal data collected in connection with use of Prime’s services in Africa. If you’re a driver in the Zambia, Prime entity holding the relevant operator license is a controller for complying with licensing requirements.

Prime is the data controller for the personal data collected in connection with use of Prime’s services everywhere else. Prime operates, and processes personal data, globally. We may also transfer such data to countries other than the one where our users live or use Prime’s services. We do so in order to fulfill our agreements with users, such as our Terms of Use, or based on users’ prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law.

Questions, comments, and complaints about Prime’s data practices can be submitted through our email Prime@sanga.co.zm. You may also use this email to submit a question to Prime’s Data Protection Officer.


DATA COLLECTIONS AND USES
A. The data we collect
Prime collects personal data:
• provided by users to Prime, such as during account creation
• created during use of our services, such as location, app usage, and device data
• from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities

B. How we use personal data
Prime uses personal data to enable reliable and convenient transportation, delivery, and other products and services. We also use such data:
• to enhance the safety and security of our users and services
• for customer support
• for research and development
• to enable communications between users
• to send marketing and non-marketing communications to users
• in connection with legal proceedings
Prime does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

C. Cookies and third-party technologies
Prime and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Prime 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 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.

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

E. Data retention and deletion
Prime retains user data for as long as necessary for the purposes described above.
Users may request deletion of their accounts at any time. Prime may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.

Prime retains 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 type of data, the category of user to whom the data relates, and the purposes for which we collected the data.

Following an account deletion request, Prime deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers and delivery persons, this generally means that we retain their account and data for a minimum of 5 years after a deletion request. For riders and delivery recipients, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.

CHOICE AND TRANSPARENCY
Prime enables users to access and/or control data that Prime collects, including through:
• privacy settings
• device permissions
• in-app ratings pages
• marketing choices
Prime also enables users to request access to or copies of their data, changes or updates to their accounts, or deletion of their accounts, or that Prime restricts its processing of user personal data.

UPDATES TO THIS NOTICE
We may occasionally update this notice.
We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Prime apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.
Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

Location Data (Partner and User)

We collect this data when the app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.

We collect precise or approximate location data from user's and partner's mobile devices if they enable us to do so. We collect this data from the time a job is requested 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 improving pick-up locations, enable safety features, and prevent and detect fraud.

The app does use third-party services that may collect information used to identify you.

Link to the privacy policy of third party service providers used by the app