Privacy Policy
Last Updated: 27th March 2024
Data Protection Notice
Background
TREKK website is owned by TREKK Transport Services Limited, which is the data controller of your personal data.
We take care of your data and undertake to guarantee its confidentiality and security.
TREKK recognizes the weight and value that your privacy rights carry as guaranteed under the 1999 Constitution of the Federal Republic of Nigeria; The Nigerian Data Protection Regulation, and other applicable privacy laws governing Nigeria and its people. TREKK is a law-abiding entity saddled with the primary assignment of improving the lives of people in various communities through the creation of sustainable, alternative transportation methods. We thus understand how crucial to reaffirm our commitment to providing you notice about how TREKK Rides, Released Parties and our affiliate and subsidiary companies (together, “TREKK” or “We”, or “Us”, or “Our”) handle your information.
This TREKK Privacy Policy (the “Privacy Policy”) applies to the information, that we collect and process about users of our Services, and those who communicate with us about our Services, interact with us on social media, attend our events, participate in our surveys, contests and promotions, or are subscribed to our marketing and informational communications (the “Interactions”).
In this Privacy Policy, “Services”:
a) TREKK websites that link to this Privacy Policy, including any versions optimized for viewing on a mobile device (the “Sites”),
b) TREKK mobile applications (each an “App”),
c) TREKK e-scooters (each a “Scooter”), and
d) the features and services available through our Sites, Apps and Scooters
TREKK Privacy Policy explains our User’s Privacy rights regarding:
a. what kinds of information we may gather during your use of the Services and related other Interactions,
b. why we gather such information;
c. how we use your information when we might store, disclose and protect your information,
d. and your rights and choices regarding the information that we collect and process.
As a user of any of Our Services, you accept this Privacy Policy when you sign up for or use Our products, Services, Content, Technologies, or Functions offered on our Platforms and all related sites and services (“Services”).
This Privacy Policy contains the following sections:
Your Privacy Right
The Information We Collect: From Users, Automatic information, and Third-party
Use and Processing of Information and Nigeria's Legal Bases
Data Confidentiality Rights
Link to Other Websites and Premises
Cookies and Other Online Tracking Technologies
Security
Disclosure of Your Information
Contact Information
Governing Law
Your Privacy Right
This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information. It applies to the TREKK website and all database applications, services, tools and physical contact with us regardless of how you access or use them.
The Information We Collect
TREKK collects information related to our Services and Interactions directly from Our users, which are automatically related to their use of the Services and our Interactions, as well as from third parties. We may combine the information we collect from these various sources.
Information You Provide to Us through:
Account registration, management, profile creation and modification
Account access and use, as well as uploading content to the Services and other associated activities
Scooter use
Access to and use of the Sites and Apps
Submission of payment information
Event registration and attendance
Participation in surveys, contests, rallies, sweepstakes and promotions sponsored by TREKK Scooters
Signing up to receive newsletter, waitlist, community ambassador, or other information via email, text or instant messages from TREKK Scooters
Customer service, technical support, damaged or accident reports and other related communications
Participation in communities, commenting on blog entries, interacting with us on social media, and participating in other forums
Submission of an application or resume to work at TREKK.
The types of information we collect directly from you are your name, e-mail address, password, National Identification Number (NIN), Bank Verification Number (BVN), pins, photo, phone number, postal address, other contact information, credit card and billing details, including billing address, communications preferences, payment and transaction history, where required your birthdate and driver’s license, international passport, information or other identification card, and any other information you submit to the Services or otherwise provide to us. We also collect certain demographic data if you provide it to us including age, gender, preferred language, ethnicity, race/tribe, and current location.
TREKK App permissions
In order to use our services, we need access to certain functions of your device (so-called “permissions”). Depending on your operating system, you must explicitly grant permission or you can revoke it in each case. Any data that we may access as part of the authorizations will only be used for the purposes stated in this Data Protection Act.
Camera Access to your camera function is required to scan the QR code placed on the vehicle before renting.
Location We need information about your location to show you if there are scooters near you and how to get there. Furthermore, we process information about your location when you use the app or rent a scooter to improve our services and personalize them for you.
Automatically Collected Information
TREKK also collects information through automated and technical means as you browse our Sites, use our Apps, or otherwise use the Services:
Device and Online Usage. We collect information about your computer, browser, mobile or other device that you use to access the Services. We may use cookies, pixels, log files and other similar technologies to collect such information, including IP address, MAC address, IMEI number, Bank verification number, IMSI number, Sim, device identifiers and other unique identifiers, browser type, browser language, operating system name, and version, device name and model, referring and exit pages, dates and times you access our Services, the length of time that you are logged into or using our Services, the links you click or features you use, software crash reports and session identification number. Please see the “Use of Cookies and Other Online Tracking Technologies” section below or our Cookie Notice for more information.
Location Info and Scooter Usage. We automatically collect and store location information from your device and from any Scooters you use. We collect and store the location information (e.g., city, Estate, University, State or zip code where available) associated with the IP address of the device you use to access the Services, as well as, with your permission, your mobile device’s location information using GPS or Bluetooth (you can change your location/Bluetooth settings for your mobile device; however, certain features may not be available through the App if you do so).
Analytics: We compile and analyse information derived from the use of our Services, such as aggregate usage patterns, user preferences, peak demand times, common routes and other information.
Data collection by our vehicles
Our scooters contain Internet of Things devices “IoT ” or telematics units that send data (including the scooter's location and diagnostic data, e.g. battery status) at regular short intervals. This permits us to determine where our scooters are and at what speed they are moving. The IoT devices send data in real-time regardless of whether a scooter is currently rented or not.
We process data in connection with the rental in particular for the following purposes:
to determine whether a scooter is located in the respective TREKK business zone of operation or whether the end of the rental should take place outside the area of operation, as this is contrary to our General Terms and Conditions. In this case, our Scooters may trigger an alarm function ("geofencing").
in case of an unusually long period of use (especially if the scooter is not moved), we may terminate the rental.
requests to our customer service (e.g. a booking cannot be completed, Scooter cannot be located, assistance in case of accident).
as proof in the event of an accident or damage.
for billing purposes. We note in your booking history the start and end points of your trips as well as parking locations, if applicable.
to improve our services by analyzing the aggregated statistics of locations where users make bookings and end trips, as well as frequent routes, we can optimize the distribution of our scooters.
Information We Collect from Third-Party Sources
In some cases, we may collect user information from third parties.
Third Party Platforms and social media sites. When you interact with us or post content about us on third-party social media platforms – like Facebook, Twitter, Google+, Tumblr, LinkedIn, medium, YouTube or Pinterest – we may collect certain information about that interaction; the information that we may collect is based on your settings on and the policies of these social media platforms. We may also allow you to post certain information from these platforms to your TREKK Scooters profile, and permit you to log in to the Services using your third-party social media account, in which case you will be asked to consent to our access and collection of certain information from your social media profile, subject to the policies of that platform. A relevant example is Facebook.
Other Third-Party Sources. We also may collect information about you that we may receive from business partners, marketers, analysts and other sources to, enable us to verify and update the information contained in our records and better customize the Services for you. We may also collect information from credit reporting agencies and your bank or banks to determine your creditworthiness, credit score and credit usage, in compliance with and to the extent permitted by applicable laws.
Referrals. We may from time to time conduct a referral service so that you may introduce people you know to our Services, in accordance with applicable local laws. If you choose to use our referral service to tell someone about our Services, we will provide you with a template message and referral code to send to your friend. We will not collect the referral’s information unless he/she signs up to use the Services with the referral code.
Payment processing
To process the payment, we use external service providers to whom we transmit the data required for payment processing (first and last name, email address, telephone number, start and end time of the trip, payment ID, payment method, any further data about the means of payment, invoice number, language, zone/region).
For the legal basis of the data processing carried out by the payment service providers under their own responsibility, please refer to the data protection policies of the respective payment service providers:
Paystack 126 Joel Ogunnaike Street, Ikeja GRA, Ikeja, Lagos, Nigeria ("Stripe"). For more information kindly see Paystack ("Stripe") privacy policy
How We Use and Process Information
Generally, we use the information we collect from and about you to provide and operate the Services, respond to user requests, for customer service and support, to protect our rights and those of others, to send marketing communications, to help us personalize user experiences and to improve the Services.
Contractual agreement With You: Our processing is necessary to undertake our obligations under a contract with you or to perform steps requested by you before entering into a contract with you for instance, to verify the information you have provided to us and provide the Services to you.
Our Legitimacy: Our processing is necessary for our legitimate interests, including to protect the security of our Services; to protect the health and safety of others; to establish, protect and defend our legal rights and interests; to monitor and protect our Vehicles; to prevent fraud and verify identity and authorization of users; to personalize user experiences and content; to understand and analyze usage trends; and to improve our Services in the communities we serve.
Legal Compliance: Where our processing is required to comply with applicable law as stated in the constitution of Nigeria (for example, to maintain your payment transaction history for tax reporting purposes).
Your Consent: Giving us your consent as defined by applicable law.
In addition, we may process information to the extent necessary to protect the health, safety or vital interests of any person and to establish, protect and defend our legal rights
Data Confidentiality Rights
Your information is regarded as confidential and will not be divulged to any third party except under legal and/or regulatory conditions. You have the right to request sight of, and copies of any and all information we keep on you if such requests are made in compliance with the Freedom of Information Act and other relevant enactments. While TREKK is responsible for safeguarding the information entrusted to us, your role in fulfilling confidentiality duties includes but is not limited to, adopting and enforcing appropriate security measures such as non-sharing of passwords and other platform login details, adherence with physical security protocols on our premises, dealing with only authorized officers of the Agency.
Links to Other Websites and Premises
Certain transaction processing channels, blog posts, and News media may require links to other websites or Organizations other than Ours. Please note that TREKK is not responsible and has no control over websites outside its domain. We do not monitor or review the content of other party’s websites which are linked to our website or media platforms. Opinions expressed or materials appearing on such websites are not necessarily shared or endorsed by us, and TREKK should not be regarded as the publisher of such opinions or materials. Please be aware that we are not responsible for the privacy practices, or content of these sites. We encourage our users to be aware of when they leave our site and to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site yourself, before disclosing any personal information to them. TREKK will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information.
Cookies
Cookies are small files placed on your computer’s hard drive that enable the website to identify your computer as you view different pages. Cookies allow websites and applications to store your preferences in order to present contents, options or functions that are specific to you. Like most interactive websites, our website uses cookies to enable the tracking of your activity for the duration of a session. Our website uses only encrypted session cookies which are erased either after a predefined timeout period or once the user logs out of the platform and closes the browser. Session cookies do not collect information from the user’s computer. They will typically store information in the form of a session identification that does not personally identify the user.
Security
We will always hold your information securely. To prevent unauthorized access to your information, TREKK has implemented strong controls and security safeguards at the technical and operational levels. This site uses Secure Sockets Layer/Transport Layer Security (SSL/TLS) to ensure secure transmission of your personal data. You should see the padlock symbol in your URL address bar once you are successfully logged into the platform. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission.
Legal disclosure:
We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
Contact information:
If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may send an email to info@trekkscooters.com.
Governing Law
This Privacy Policy is made pursuant to the Nigeria Data Protection Act (2023) and other relevant Nigerian laws, regulations or international conventions applicable to Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.
