The Scope of This Policy

This policy applies to all Karona24 users, including Riders and Drivers (including Driver applicants), and to all Karona24 platforms and services, including our applications, websites, technology, facilities, and other services (collectively, the “Karona24 Platform”). This policy applies only to personal information, not to aggregate information or information that does not identify you. Please remember that your use of the Karona24 Platform is also subject to our Terms of Use. Certain elements of the Karona24 Platform may operate under separate or additional terms or practices different from or in addition to those described in this policy; in those cases, you will be provided separate notice and information relevant to your use of those parts of the Karona24 Platform.

The Information We Collect

When you use the Karona24 Platform, we collect the information you provide, usage information, and information about your device. We also collect information about you from other sources like service providers, and optional programs in which you participate, which we may combine with other information we have about you. Here are the types of information we collect about you:

1. Information You Provide to Us

Account Registration. When you create an account with Karona24, we collect the information you provide us, such as your name, email address, phone number, birth date, profile photo, and payment information. You may choose to share additional info with us for your Rider profile, like saved addresses (e.g., home or work), and set up other preferences (such as your preferred pronouns).

Driver Information. If you apply to be a Driver, we will collect the information you provide in your application, including your name, email address, phone number, birth date, profile photo, physical address, government identification number (such as NUIT), driver’s license information, vehicle information, and car insurance information. We collect the payment information you provide us, including your M-pesa and bank numbers.

Ratings and Feedback. When you rate and provide feedback about the Karona24 Platform (including about Riders or Drivers), we collect all of the information you provide in your feedback.

Communications. When you contact us or we contact you, including through surveys or research projects, we collect any information that you provide, including the contents of the messages or attachments you send us.

1. Information We Collect When You Use the Karona24 Platform

Location Information. Great rides start with an easy and accurate pickup. The Karona24 Platform collects location information (including GPS and WiFi data) differently depending on your Karona24 app settings and device permissions as well as whether you are using the platform as a Rider or Driver:

• Riders: We collect your device’s precise location when you open and use the Karona24 app, including while the app is running in the background from the time you request a ride until it ends.
• Drivers: We collect your device’s precise location when you open and use the app, including while the app is running in the background. We also collect precise location for a limited time after you exit driver mode in order to detect ride incidents, and continue collecting it until a reported or detected incident is no longer active

Usage Information. We collect information about your use of the Karona24 Platform, including ride information like the date, time, destination, distance, route, payment, and whether you used a promotional or referral code.

Communications Between Riders and Drivers. We work with a third party to facilitate phone calls and text messages between Riders and Drivers without sharing either party’s actual phone number with the other. But while we use a third party to provide the communication service, we collect information about these communications and Karona24 Platform chat communications, including the participants’ phone numbers, the date and time, and the contents of SMS and chat messages. For security purposes, we may also monitor or record the contents of phone calls made through the Karona24 Platform, but we will always let you know we are about to do so before the call begins.

Other Users and Sources. Other users or public or third-party sources such as law enforcement, insurers, media, or pedestrians may provide us information about you, for example as part of an investigation into an incident or to provide you support.

How We Use Your Information

We use your personal information to:

• Provide the Karona24 Platform;
• Maintain the security and safety of the Karona24 Platform and its users;
• Build and maintain the Karona24 community.
• Provide customer support;
• Improve the Karona24 Platform; and
• Respond to legal proceedings and obligations.

Providing the Karona24 Platform. We use your personal information to provide an intuitive, useful, efficient, and worthwhile experience on our platform. To do this, we use your personal information to:

• Verify your identity and maintain your account, settings, and preferences;
• Connect you to your rides and track their progress;
• Provide various Karona24 Platform offerings to you, such as vehicles services and third party promotional advertisements that may be personalized to you;
• Calculate prices and process payments;
• Allow Riders and Drivers to connect regarding their ride and to choose to share their location with others;
• Communicate with you about your use of the Karona24 Platform and experience;
• Collect feedback regarding your experience;
• Facilitate additional services and programs with third parties; and

Maintaining the Security and Safety of the Karona24 Platform and its Users. Providing you a secure and safe experience drives our platform, both on the road and on our apps. To do this, we use your personal information to:

• Authenticate and verify users;
• Verify that Drivers and their vehicles meet safety requirements;
• Investigate and resolve incidents, accidents, and insurance claims;
• Encourage safe driving behavior and avoid unsafe activities;
• Find and prevent fraud; and
• Block and remove unsafe or fraudulent users from the Karona24 Platform.

Building and Maintaining the Karona24 Community. Karona24 works to be a positive part of the community. We use your personal information to:

• Communicate with you about events, promotions, elections, and campaigns;
• Personalize and provide content, experiences, communications, and targeted advertising to promote and grow the Karona24 Platform; and

Providing Customer Support. We work hard to provide the best experience possible, including supporting you when you need it. To do this, we use your personal information to:

• Investigate and assist you in resolving questions or issues you have regarding the Karona24 Platform; and
• Provide you support or respond to you.

Responding to Legal Proceedings and Requirements. Sometimes the law, government entities, or other regulatory bodies impose demands and obligations on us with respect to the services we seek to provide. In such a circumstance, we may use your personal information to respond to those demands or obligations.

How We Disclose Your Information

We do not sell your personal information to third parties for money — no one can buy the personal information we collect from and about you and we do not act as a data broker. However, we may need to share your personal information with third parties to deliver relevant personalized ads to you on and off the Karona24 Platform.

1. Sharing Between Karona24 Users

Riders and Drivers.

Rider information shared with Driver: As part of surfacing the ride request and enabling the ride, we share with the Driver the Rider’s pickup and destination, location, name, profile photo, rating, Rider statistics (like approximate number of rides and years as a Rider), and information the Rider includes in their Rider profile (like preferred pronouns) as well as any additional stops the Rider inputs into the Karona24 app. Once the ride is finished, we also eventually share the Rider’s rating and feedback with the Driver. (We remove the Rider’s identity associated with ratings and feedback when we share it with Drivers, but a Driver may be able to identify the Rider that provided the rating or feedback.)

Driver information shared with Rider: Upon a Driver accepting a requested ride, we will share with the Rider the Driver’s name, profile photo, preferred pronouns, rating, real-time location, and the vehicle make, model, color, and license plate, as well as other information in the Driver’s Karona24 profile, such as information Drivers choose to add (like country flag and why you drive) and Driver statistics (like approximate number of rides and years as a Driver).

1. Disclosures to Service Providers to Provide the Karona24 Platform, and Other Parties

Depending on whether you’re a Rider or a Driver, Karona24 may disclose the following categories of your personal information to provide you with a variety of the Karona24 Platform’s features and services:

• Personal identifiers, such as your name, address, email address, phone number, date of birth, government identification number (such as NUIT), driver’s license information, vehicle information, and car insurance information;
• Financial information, such as M-pesa number, and any other payment information you provide us;
• Commercial information, such as ride information, Driver/Rider statistics and feedback, and Driver/Rider transaction history; and
• Location data;

We disclose those categories of personal information to these other parties and service providers to fulfill the following purposes:

• Maintaining and servicing your Karona24 account;
• Processing or fulfilling rides or other offerings of the Karona24 Platform;
• Providing you customer service;
• Processing transactions and payments;
• Processing Driver applications;
• Verifying the identity of users;
• Detecting and preventing fraud and unsafe activity;
• Processing insurance claims;
• Providing Driver loyalty and promotional programs;
• Providing marketing and advertising services to Karona24, including to provide targeted and cross-contextual behavioral advertising personalized to you;
• Providing requested emergency services;
• Providing analytics services to and by Karona24; and
• Undertaking research to develop and improve the Karona24 Platform.

1. For Legal Reasons and to Protect the Karona24 Platform

We may disclose your personal information in response to a legal obligation, or if we have determined that disclosing your personal information is reasonably necessary or appropriate to:

• Comply with any applicable federal, state, or local law or regulation, civil, criminal or regulatory inquiry, investigation or legal process, enforceable governmental request, or requirement as condition to operate (e.g., operating permit, license or agreement).
• Respond to legal process (such as a search warrant, subpoena, summons, or court order).
• Enforce our Terms of Service;
• Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate country or local law; or
• Exercise or defend legal claims, protect against harm to our rights, property, interests, or safety or the rights, property, interests, or safety of you, third parties, or the public as required or permitted by law.

How We Store and Protect Your Information

We retain your information for as long as necessary to provide you and our other users the Karona24 Platform. This means we keep your profile information for as long as you maintain an account. We retain transactional information such as rides and payments for at least seven years to ensure we can perform legitimate business functions, such as accounting for tax obligations. We also retain your information as necessary to comply with our legal obligations, resolve disputes and enforce our terms and policies. If you request account deletion, we will delete your information as set forth in the “Deleting Your Account” section below.

We take reasonable and appropriate measures designed to protect your personal information. But no security measures can be 100% effective, and we cannot guarantee the security of your information, including against unauthorized intrusions or acts by third parties.

Your Rights And Choices Regarding Your Data

As explained more below, Karona24 provides ways for you to access and delete your personal information as well as exercise applicable data rights that give you certain control over your personal information.

All Users

Email Subscriptions. You can always unsubscribe from our commercial or promotional emails by clicking unsubscribe in those messages. We will still send you transactional and relational emails about your use of the Karona24 Platform.

Push Notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Karona24 Platform (such as receiving a notification that your ride has arrived).

Profile Information. You can review and edit certain account information you have chosen to add to your profile by logging in to your account settings and profile.

Location Information. You can prevent your device from sharing location information through your device’s system settings. But if you do, this may impact Karona24’s ability to provide you our full range of features and services. You may also control some elements of sharing your location with Karona24 in your Karona24 account settings.

Accessing Your Information. You can see information we have about you by logging into your account and viewing things like your profile, settings, and preferences (like preferred pronouns and address shortcuts such as home and work), ride history, or payment information. In addition, you may have some information included in things we have sent to you, such as ride receipts.

Deleting Your Account. You can delete your Karona24 account as long as there are pending issues such as if there is an issue with your account related to trust, safety, or fraud. When we delete your account, we may retain certain information for legitimate business purposes or to comply with legal or regulatory obligations. For example, we may retain your information to resolve open insurance claims, or we may be obligated to retain your information as part of an open legal claim. When we retain such data, we do so in ways designed to prevent its use for other purposes.

Children’s Data

Karona24 is not directed to children, and we don’t knowingly collect personal information from children under the age of 16. If we find out that a child under 16 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 16 has given us personal information, please contact us.

Changes to This Privacy Policy

We may update this policy from time to time as the Karona24 Platform changes and privacy law evolves. If we update it, we will do so online, and if we make material changes, we will let you know through the Karona24 Platform or by some other method of communication like email. When you use Karona24, you are agreeing to the most recent terms of this policy.

Contact Us

If you have any questions or concerns about your privacy or anything in this policy, including if you need to access this policy in an alternative format, we encourage you to contact us.