Privacy Policy for Hupify Ltd.
Hupify Ltd (“Hupify”, “we”, “our”, or “us”) operates a technology platform that connects users with independent drivers, transport providers, and logistics operators.
Hupify acts as an independent data controller in respect of personal data processed through the Platform.
This Privacy Policy explains how we collect, use, disclose, store, and protect personal data in accordance with the Nigeria Data Protection Act 2023 (NDPA) and other applicable laws.
By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy.
This Privacy Policy is governed by applicable data protection laws, including the Nigeria Data Protection Act 2023 (NDPA), and any applicable regulations or guidance issued by the Nigeria Data Protection Commission (NDPC).
Where applicable, other laws relating to transportation, safety, financial transactions, and cybersecurity may also apply.
We collect personal data necessary for the operation, security, and improvement of the Platform.
3.1 Personal Data may include:
3.1.1 name, phone number, email address
3.1.2 date of birth, address
3.1.3 government-issued identification (e.g., NIN, driver’s licence)
3.1.4 payment and financial information (processed via secure third-party providers)
3.1.5 vehicle and driver-related information
3.1.6 ratings, feedback, and communications
3.2 Sensitive Personal Data (where applicable) may include:
3.2.1 identity verification data
3.2.2 biometric data (where required for verification or fraud prevention)
Such data is processed only where strictly necessary and in accordance with applicable law.
3.3 Automatically Collected Data:
3.3.1 GPS/location data (real-time and historical)
3.3.2 device and technical data
3.3.3 usage data and analytics
3.3.4 trip history and preferences
We process personal data for the following purposes:
4.1 account registration, identity verification, and onboarding;
4.2 facilitating transportation, logistics, and related services;
4.3 Safety, security, and fraud prevention;
4.4 payment processing and financial reconciliation;
4.5 compliance with legal and regulatory obligations;
4.6 dispute resolution and enforcement of contractual terms;
4.7 platform improvement, analytics, and service optimisation; and
4.8 marketing and communications, where consent has been obtained or permitted by law.
We process personal data on one or more of the following lawful bases:
5.1 performance of a contract;
5.2 compliance with legal obligations;
5.3 legitimate interests, including safety, fraud prevention, and platform integrity;
5.4 consent, where required under applicable law.
Where processing is based on consent, you may withdraw consent at any time, subject to legal or contractual limitations.
We may share personal data with:
6.1 service providers and processors acting on our instructions (e.g., payment processors, cloud providers, mapping services);
6.2 independent third parties where necessary for service delivery (e.g., drivers, logistics providers);
6.3 regulatory authorities, law enforcement agencies, or courts where required by law or legal process;
6.4 professional advisers, insurers, auditors, or compliance partners where necessary;
6.5 affiliates within our corporate group for operational purposes.
All recipients are required to implement appropriate data protection and confidentiality measures in accordance with applicable law..
7.1 You have rights under applicable data protection laws, including:
7.1.1 right to be informed
7.1.2 right of access
7.1.3 right to rectification
7.1.4 right to erasure (subject to legal limitations)
7.1.5 right to restrict processing
7.1.6 right to data portability
7.1.7 right to object to processing
7.2 You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).
8.1 We retain personal data only for as long as necessary for the purposes for which it was collected, including compliance with legal, regulatory, tax, accounting, fraud prevention, and dispute resolution requirements.
8.2 Retention periods may vary depending on the nature of the data and applicable legal obligations, after which data is securely deleted or anonymised.
9.1 We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, or alteration.
9.2 Such measures may include encryption, access controls, monitoring systems, and security testing. However, no system is completely secure, and we do not guarantee absolute security.
Where personal data is transferred outside Nigeria, we ensure that appropriate safeguards are implemented in accordance with applicable data protection laws, including contractual protections, adequacy mechanisms, or other lawful transfer frameworks.
The Platform is not intended for persons under the age of eighteen (18). We do not knowingly collect personal data from minors. Where we become aware of such data, we will take steps to delete it in accordance with applicable law.
We may use cookies and similar technologies to improve functionality, analytics, and user experience. Users may manage preferences through device or browser settings, subject to functional limitations.
Hupify maintains internal data protection policies, procedures, and controls, including the appointment of a Data Protection Officer (DPO), staff training, incident response processes, and periodic compliance reviews.
Where a data breach is likely to result in risk to your rights and freedoms, we will notify affected individuals and relevant authorities in accordance with applicable law and regulatory requirements.
We may update this Privacy Policy from time to time. Material changes will be communicated through the Platform or other appropriate channels. Continued use of the Platform after such updates constitutes acceptance of the revised policy.
For data protection inquiries or to exercise your rights, please contact:
Data Protection Officer (DPO)
Hupify Ltd
Email: [email protected]
By accessing or using the Platform, you acknowledge that you have read, understood, and agree to the collection, use, and processing of your personal data in accordance with this Privacy Policy.