This Privacy Policy and its Addendum(s) (“Policy”) describes how JustNep, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “JustNep”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of JustNep’s mobile applications and websites (respectively “Apps” and “Websites”), as well as products, features, and other services globally, operated by Justnep (collectively, “Services”).

This Policy applies to our customers, passengers, agents, vendors, suppliers, partners (such as driver and merchant partners), contractors and service providers (collectively “you”, “your” or “yours”).

“Personal Data” is any information that can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank, and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle, and insurance information, employment information and financial information.

I. COLLECTION OF PERSONAL DATA

We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession. If you have or are a party to multiple relationships with us (for example if you use our Services across our various business verticals, or if you are both a driver-partner/delivery partner as well as a passenger on our transport vertical or a customer on our other business verticals), we will link your Personal Data collected across your various capacities to facilitate your use of our Services and for the purposes described below.

You provide your Personal Data to us

We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

• complete a user profile or registration forms (such as your name, contact information and other identification information where needed);

• provide information to assess your eligibility to provide services as a JustNep driver partner or delivery partner (such as your driver’s license information, vehicle information and background check results (as legally permissible));

• interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);

• participate in contests or events organized by us (such as the pictures, audio files, or videos you may submit, which may include images of yourself);

• verify your identity through various means (such as social media logins, submission of selfie images or independently verified payment card information);

• fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation, and income information); and

• agree to take a ride with in-vehicle audio and/or video recording features.

In certain circumstances, you may need to provide your Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstance, may constitute a failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.

When our services are used

Personal Data may be collected through the normal operation of our Apps, Websites, and Services. Some examples are:

your location (to detect pick-up locations and abnormal route variations);

feedback, ratings and compliments;

transaction information (such as payment method and distance travelled);

information about how you interacted with our Apps, Website or Services (such as features used and content viewed);

device information (such as hardware model and serial number, IP address, file names and versions and advertising identifiers or any information that may provide indication of device or app modification);

personal data you enter in messages when you use our in-app communication features; and

personal data that may be captured through your interaction with us, our agents, in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).

From other sources

When we collect Personal Data, including but not limited to your name, contact information, and other identification information where needed from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include:

referral programmes;

our business partners, such as fleet partners, payment providers, ride-hailing partners and transport partners;

insurance and financial providers;

credit bureaus and other credit reporting agencies;

publicly available sources of data;

governmental sources of data;

when our users add you as an emergency contact; and

marketing services providers or partners.

Personal Data about driver partners

If you are a driver partner, we may collect:

telematics data (such as your speed, acceleration, and braking data);

device data (such as accelerometer data, GPS location, your IMEI number and the names of apps you have installed on your device);

your vehicle registration data; and

personal data that may be captured through your interaction with us, our agents, our in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).