Privacy Policy

International Privacy Policy for Travelers and Riders of Dymond Fleets

At Dymond Fleets, we are dedicated to safeguarding your data. This privacy notice outlines our commitment and provides comprehensive information about the data we collect, how we use it to enhance your transportation experience and ensure your safety, and the options and controls available to you. Additionally, this notice explains your privacy rights and the regulatory frameworks that protect individuals' data privacy. Dymond Fleets, operating under the laws of the Federal Republic of Nigeria, is responsible for managing and processing your personal data, unless otherwise specified.
Should you have any inquiries regarding your data or this privacy policy, please contact our Data Protection Officer at info@dymondfleets.com or through our postal address at 67 Tombia Extension Road, Rivers State, Nigeria. When emailing, kindly use an appropriate subject line related to your privacy concerns.
In this document, "us" or "we" refers to Dymond Fleets, a privately registered company with registration number 7122064 under the laws of Nigeria. "You" or "your" pertains to the individual utilizing Dymond Fleets' transportation services, specifically as a passenger or rider through the Dymond Fleets App.
Here is the rewritten version of the section regarding the personal data handled by Dymond Fleets:

1. Personal Data Handling

At Dymond Fleets, we handle essential data selectively to ensure optimal service delivery on our transportation platform. The categories of data we handle include:
Contact Information: This includes personal details like your name, phone number, and email address. For specific services, we may require additional information, such as your residential address.
Profile Information: This comprises details such as your profile picture, saved addresses, language preferences, and communication settings. Certain services may necessitate more information, such as your driver's license details.
Geolocation: This involves determining the precise location of a person or object. It helps identify your pick-up location, locate nearby vehicles, track travel progress, and determine trip endpoints.
Payment Details: We handle information such as total billing amounts and the credit card used for payment.
Communication Records: This includes interactions via our in-app chat and conversations with customer support.
Device Installation Data: When our app is installed on a device, we collect limited identification data like the device's IP address.
Transportation Service Usage Information: This covers data related to journey status, timings, and evaluations of commuter behaviour based on driver feedback.
Vehicle Sensor Information: This includes details like vehicle speed, engine power, driving style indicators (e.g., abrupt braking), and passenger weight variations.
User-Generated Content: This encompasses submitted feedback, photographs of parked electric vehicles, and audio recordings from our safety toolkit's trip audio recording feature (where applicable). For more details, contact Dymond Fleets at info@dymondfleets.com.
In addition to the above sources, we may gather data from:
Drivers and Third Parties: They provide information related to services, potential claims, and disputes.
Referral Engagement: Individuals actively participating in referral efforts may also provide data, which we obtain from the referring user.
Insufficient or incorrect personal data may impede our ability to fulfill contractual obligations or comply with legal requirements. For instance, refusal to share geolocation data via the app may prevent us from guiding a driver to your location or displaying nearby available vehicles. Similarly, declining identity verification may lead to account suspension or termination to prevent fraud, thereby affecting our ability to serve you effectively.

2. Purpose of Data Processing

We collect and analyze your personal information to provide you with one or more of our transportation services:
Connecting Passengers and Drivers: Our primary goal is to facilitate connections between passengers and drivers, including locating available vehicles for hire. We use personal data to link passengers with drivers for pick-up and drop-off services or to provide information about nearby hire vehicles, such as cars. Processing includes managing instant messages within the Dymond Fleets app to support service delivery and resolve disputes between drivers and customers. This processing is also essential for security, service enhancement, and analytical purposes.
Facilitating Transportation Services: We assist in transportation to desired destinations by providing drivers with geolocation data and passengers' phone numbers during ride-hailing. This ensures efficient pick-up and drop-off while maintaining journey transparency. Geolocation data collection occurs exclusively during app usage and stops upon app termination. In some regions, drivers receive a temporary number that redirects to the passenger's phone number, facilitating effective communication.
Optimizing Travel Experience: Our aim is to ensure seamless travel by utilizing geolocation data to navigate and address service quality concerns. We also require location information for accurate billing, battery recharging, and fleet maintenance, especially regarding rented vehicles.
App Optimization and Security: Contact information is used to notify passengers and riders about app updates, ensuring continued service utilization. We collect limited device data to enhance account security through authentication and verification checks.
Route Optimization: We gather data on passenger and rider routes to assess geographic coverage, optimize advice to drivers on optimal routes, and strategically position hire vehicles for client convenience.
Payment Processing: Payment information is collected to facilitate passenger payments for ride-hailing and rental vehicles.
Standards and User Safety: Data on journey statuses, duration, and passenger ratings, collected through driver feedback, helps enhance user safety, ensure compliance with terms and conditions, and deliver high-quality service. Customer support data aids in obtaining feedback and resolving service-related disputes and concerns.
Communication Updates:* Personal information is utilized to communicate journey completion, send confirmation slips and receipts, and provide important service updates.
Vehicle Sensor Analysis: We analyze vehicle sensor data for security purposes, identifying potentially hazardous driving patterns and sending notifications to promote secure driving practices. Notifications regarding significant weight changes aim to encourage responsible driving without major repercussions for individuals.
Legal Claims Processing: Personal data may be processed for initiating, carrying out, or defending legal claims, including protection against damages or other claims requiring examination.
Please refer to Clause 3 below for a comprehensive list of additional purposes under legitimate interest for processing your personal data.

3. Legal Basis for Data Processing

We process personal information based on legitimate justifications as outlined in the methods described above. Before taking any action with your data, we ensure there is a valid legal basis for processing.
Contractual Services: Personal data is processed to fulfill contractual obligations through our company's app. This includes providing promised services and complying with terms and conditions.
Legitimate Interest: We often process personal data based on legitimate interest grounds after conducting a legitimate interest evaluation. Our legitimate interests include delivering an innovative, customized, secure, and profitable service to our passengers and partners, unless these interests are outweighed by other considerations. We process personal data (excluding special categories) for the following purposes under legitimate interest:
Investigating and identifying fraudulent payments, malicious activities, unlawful actions, safety incidents, or security events across all data types.
Ensuring network and system protection and integrity, and addressing suspected or confirmed illicit activities promptly.
Documenting and evaluating communications and instructions through various methods such as email, phone calls, and the Dymond Fleets app, for inquiries, substantiation, quality assurance, and safeguarding against claims.
Developing and maintaining features for service security.
Establishing, exercising, or defending legal claims, including internal investigations, assigning claims, utilizing debt collection agencies, and seeking legal advice.
Other Legal Grounds: Depending on circumstances, we may use other legal grounds such as:
Compliance with legal obligations, including responding to legitimate legal requests to disclose personal information to third parties like courts or regulatory authorities.
Safeguarding critical interests or those of others in emergencies or life-threatening situations.
Explicit consent from individuals for specific purposes, where they have been fully informed.
In countries where legitimate interest is not a legally acceptable reason, we rely on another valid legal basis as mentioned above.
When personal data is used for a different purpose than its original acquisition, and this usage is not based on individual permission, we evaluate whether this new usage is allowed. We consider factors like:
The connection between the reasons for collecting personal data and the reasons for planned additional processing.
The context in which the personal data is collected, especially the relationship between you and us.
The specific characteristics of the personal data, including sensitive categories or criminal convictions.
The potential impacts of additional processing on individuals.
The presence of security and privacy measures like encryption or pseudonymization.
Here's the rewritten version of the section on recipients of personal data by Dymond Fleets:

4. Recipients of Personal Data

Dymond Fleets collaborates exclusively with reputable partners and authorities, disclosing information only with valid justifications and limiting sharing to what is necessary. We do not sell your personal information.
Ride-Hailing Drivers: Passenger personal data is shared with ride-hailing drivers only when a ride is initiated through our app. In such cases, drivers gain access to passenger name, phone number (which may be hidden in certain countries), rating, and geolocation data. Access to passenger name and telephone number is available for 24-48 hours post-service. In some regions, the telephone number may be hidden. This access enables drivers to address passenger concerns, such as returning lost items.
Feedback Anonymity:* Passenger feedback on ride-hailing service quality remains anonymous. Your provided rating is confidential and accessible only to you and Dymond Fleets.
- *Trusted Representatives:* Passenger data may be shared with our trusted representatives, affiliates, agents, and others based on passenger location. Data processing by these entities follows the stringent standards outlined in this privacy notice, with additional information available on the country-specific customer website.
- *Legal Obligations:* We may disclose information to external recipients under legal obligations, such as Court Orders or collaboration with data protection supervisory authorities for complaint resolution or investigations. Additionally, we may address inquiries, including those from law enforcement entities, if legally mandated in that jurisdiction, serving a public interest, impacting users within that jurisdiction, and aligning with globally acknowledged norms. We always ensure a legitimate justification for sharing information and document our decision.
Here's the rewritten version of the sections on data protection, user entitlements, and mechanisms of authority:

5. Data Protection and Access

All personal data collected during our service provision is stored in highly secure data centers provided by Dymond Fleets. Access to personal data is restricted to authorized staff members of our company and partners, who can view the data solely for resolving issues related to service use, such as transportation service disputes.
We only access personal data as required to provide customer service in specific countries. For research and scientific purposes, all data, including bulk geolocation data, undergoes anonymization, ensuring individuals cannot be identified from it.

6. Legal Entitlements and Authority Mechanisms

Our goal is to ensure you maintain full control over your data. We provide users with access to and management of their personal information, including profile data and journey history, through the app's control features.
- *Right to Access:* You can access your personal data using our app and request copies of your information from us, with exceptions for rights of others that may limit information access.
- *Right to Rectification:* You can access and modify personal data through our app, requesting corrections for inaccuracies or additional information to address perceived incompleteness.
- *Right to Erasure:* In specific situations, you have the right to request deletion of your personal data from our records.
- *Right to Restrict Processing:* You can request limitation on the handling of your information under specific conditions, restricting data to certain purposes like legal claims or rights assertion.
- *Right to Object to Processing:* If we process your information based on legitimate interests, you can object, including objecting to automated processing or profiling with a substantial impact on your rights, and request human intervention or rationale explanation.
- *Data Portability Rights:* In certain instances, you can request transfer of your information from us to another organization or receive it yourself, limited to the information you provided.
Instant communications within our app are retained for 60 days, unless related to a reported incident, in which case they are stored for 6 months. Here's the rewritten version of the sections on data retention and direct marketing:

7. Data Retention

Dymond Fleets retains user data for the duration necessary to fulfill stated purposes. Data retention durations vary based on data type, associated transportation services, and collection reasons. Personal data is retained as long as your passenger account is active. Upon account cancellation, data is erased according to our retention schedule and regulations, unless needed for legal obligations, accounting, dispute resolution, or fraud prevention purposes.
- *Financial Data:* Retained for 24 months post last trip completion. Further accounting data is kept for seven years after the latest transaction.
- *Investigations and Disputes:* Data is retained as required by internal, legal, and regulatory obligations during criminal investigations, fraud cases, or payment disputes until resolution or statute of limitations expiry.
- *Journey History and Usage Data:* Retained for three years before undergoing anonymization. Vehicle sensor data is stored for six months.
- *App Inactivity:* If the Dymond Fleets app remains inactive for 24 months, we contact you to confirm account retention. Unresponsive accounts are terminated, and data erased, unless necessary for specified purposes.
- *Audio Recording Data:* Stored for 24 hours on the device, automatically destroyed thereafter unless shared with customer support for reports, in which case retention extends for investigative or legal purposes up to three days.

8. Direct Marketing

We send direct marketing messages to your email or phone only with explicit permission or under a soft opt-in arrangement. Messages are customized based on your service usage data. To opt out of direct marketing, use the "Unsubscribe" link in our emails or opt-out within the app's profile section.
Here's the rewritten version of the section on automated decision-making:

9. Automated Decision-Making

Automated decision-making involves computer algorithms and artificial intelligence making decisions without human intervention. We utilize automated decision-making to issue warnings and implement ride-hailing service suspensions, ensuring reduced error rates, enhanced efficiency, and heightened safety compared to manual processes. When determining the need for a warning or suspension, we consider your transportation service usage data, including journey status (e.g., cancellations, no-shows) and behavioral assessments by drivers. Additional details on automated decision-making are available [here](link to information page).
- *Suspensions:* Ride-hailing suspensions last for six months, after which access is reinstated.
Automated decision-making is also used for fraud checks to ensure proper payment for services and protect riders from fraudulent transactions. It may authenticate your identity and aid in resolving complaints. Complaints submitted via our chat function generate an automatic response, reviewed by a human agent for final decisions. If automated processing significantly impacts your rights, you have the right to request human intervention and object to automated decisions or profiling. You can voice your perspective and contest decisions by contacting customer support through our app. You may also request an explanation of automated decision-making reasoning. Some cases may not allow objection to automated decision-making per regulations. Clear information on your rights and objection procedures will be provided.

10. Conflict Resolution

Disputes regarding personal data handling can be initially resolved through our customer assistance via phone call or email at (info@dymondfleets.com). Please caption the email appropriately. You can also contact our Data Protection Officer at the same email address if necessary. Additionally, the country's Data Protection Inspectorate serves as our supervisory authority. If you believe we have unlawfully processed your data or not fulfilled our legal duties, you have the right to file a complaint with the supervisory authority.

11. Enhancing Message Quality

We trust that you have easily understood our privacy notice. Data protection laws are crucial as they enhance regulations and bolster your rights to access information. While some of these laws may seem complex, they are generally based on fundamental logic. We prioritize our responsibilities regarding the security and confidentiality of your data. Dymond Fleets will consistently update this privacy notice as part of our commitment to safeguarding your privacy and providing enhanced transparency.