Last updated: July 7th, 2023

I.  Introduction

When you use Silver Fleet, you entrust us with your personal information. We value and prioritise your trust, which is why we are dedicated to maintaining the utmost privacy standards. We believe in transparency and want to ensure that you have a clear understanding of how we handle your personal data.

This notice provides details about the personal information ("information") we collect, how we use and share it, and the choices you have regarding your data. We encourage you to review this notice in conjunction with our privacy overview, which provides an overview of our key privacy practices.

II. Overview

A.  Scope

This notice outlines how Silver Fleet and its affiliates collect and utilise data. It is applicable to all Silver Fleet users. Specifically, this notice applies to the following:

Passengers: Individuals who request or receive transportation and related services through their Silver Fleet accounts.

Drivers: Individuals who provide transportation to passengers.

Guest users: Individuals who receive Silver Fleet services ordered by other Silver Fleet account owners. This includes services arranged by Silver Fleet’s corporate Customers, as well as services arranged by friends, family members, or other individual account owners.

All individuals covered by this notice are referred to as "users." Our privacy practices comply with applicable laws in the jurisdictions where we operate. This means that we only engage in the practices described in this notice if permitted under local data protection laws.

If you have any questions about our practices in a particular country or region, please contact us using the provided contact information or the addresses below.

B.  Data Controller

Silver Fleet Limited (Plot 3 Kagera Road, Nakasero, Kampala, Uganda) is the data controller for the data collected in connection with the use of Silver Fleet's services.

To ensure consistent data protection standards across all locations where we operate, Silver Fleet has implemented the following measures:

•   Policies and procedures to restrict access to and processing of personal data for specific purposes.

•   Specialised training for personnel responsible for managing personal data.

•   Strong data protection measures during data transmission between Silver Fleet apps and servers, as well as when data is processed on our servers..

For your convenience, you can exercise your data protection rights by contacting Silver Fleet at the address mentioned above. If you have any questions, comments, or complaints regarding Silver Fleet's data practices, you can submit them via electronic mail to info@silverfleetltd.com. You may also use electronic mail to reach out to Silver Fleet's IT Officer and request a copy of the Standard Contractual Clauses or other transfer mechanisms relevant to your specific data processing activities.

III.    Data collections and uses

A.  The data we collect

Silver Fleet collects the following data:

•   Data provided by users:

•   User profile information: When users create or update their Silver Fleet accounts, we collect data such as their name, email, phone number, address, profile picture, and payment information.

•   Background check information (drivers): This includes information submitted during the application process, such as driver history or criminal record, license status, aliases, prior addresses, and right to work.

•   Identity verification photos: Users may provide photos of themselves or their government- issued identification for identity verification purposes.

•   Demographic data: We may collect demographic data about users, such as age, gender, or occupation, when required for specific Silver Fleet services or programs.

•   User content: Data submitted by users when contacting Silver Fleet, providing ratings or feedback, or engaging in other forms of communication. This may include photographs, audio recordings, or video recordings.

•   Travel information: Information related to travel itineraries, such as flight, lodging, or car rental reservations, may be collected.

•   Data created during use of our services:

•   Location data: Silver Fleet collects precise or approximate location data from drivers during the use of our services.

•   Transaction information: Data related to service requests, trip or order details, and payment transactions.

•  Usage data: Data about user interactions with our services, including access dates and times, app features or pages viewed, browser type, and app crashes.

•   Device data: Data about the devices used to access our services, such as hardware models, device IP address, operating systems, preferred languages, and mobile network data.

•   Communications data: Data regarding phone calls, text messages, or in-app communications between users facilitated through the Silver Fleet app.

•   Data from other sources:

•   Referral program participants: Data of referred individuals provided by users who refer them to Silver Fleet.

•   Uber account owners: Data of users who request services on behalf of others or enable other users to access services through their business accounts.

•   Information provided in connection with claims or disputes.

•   Business partners, vendors, and service providers: Data obtained from partners through which users create or access their Silver Fleet accounts, such as payment providers, social media services, or apps and websites utilising Silver Fleet's APIs.

•   Insurance, vehicle, or financial services providers for drivers.

•   Partner transportation companies associated with Silver Fleet.

•   Publicly available sources.
•   Marketing service providers or data resellers.

•   Law enforcement officials, public health officials, and government authorities.

B.  How we use personal data

Silver Fleet uses data to facilitate reliable and convenient transportation, and other related products and services. Additionally, we utilise this data for the following purposes:

•   Enhancing the safety and security measures implemented within our platform and services.

•   Providing customer support to address inquiries, concerns, or issues raised by our users.

•   Conducting research and development activities to improve and innovate our offerings.

•   Enabling seamless communication within our platform.

•   Carrying out marketing and advertising initiatives to promote our services and inform users about relevant offers or updates.

•   Sending non-marketing communications to users that are necessary for service-related matters.

•   Utilising data in connection with legal proceedings when required.

We use the data we collect for the following purposes:

1.  Providing our services. Silver Fleet utilises data to offer, personalise, maintain, and improve our services. This involves using data to:

•   Manage user accounts, including account creation and updates.

•   Enable transportation and related features such as location data for navigation, tracking journeys, and sharing driver information.

•   Match drivers and delivery persons with users based on availability, location, preferences, and other factors.

•   Facilitate payment processing.

•   Personalise user accounts and provide tailored recommendations.

•   Support insurance, vehicle management, invoicing, and financing solutions.

•   Keep users informed about trip updates, policy changes, and service-related notifications.

•   Ensure smooth operations by addressing software bugs and operational issues.

We perform these activities based on the necessity to fulfil our agreements with users and our legitimate interests.

2.  Safety and security. We use data to maintain the safety, security, and integrity of our services and users. This includes:

•   Verifying user identities and eligibility for transportation or deliveries, including background checks for drivers.

•   Utilising various features to prevent unauthorised use of our services and ensure compliance with safety requirements.

•   Detecting and addressing unsafe driving behaviour and promoting safer practices.

•   Preventing and combating fraud, unauthorised access, and abusive use of our platform.

•   Applying user ratings and feedback to encourage compliance with community guidelines and take appropriate actions in cases of policy violations.

•   Sharing relevant information with third-party companies to manage and de-escalate interpersonal conflicts during and/or after trips.

These activities are conducted to fulfil our agreements with users and ensure the safety and security of our platform.

3.  Customer support. We utilise the information we collect, including call recordings, to provide effective customer support. This includes investigating and resolving user concerns, monitoring and improving our customer support processes, and enhancing user satisfaction. Our customer support activities are performed to fulfil our agreements with users and improve our services.

4.  Research and development. We use data for testing, research, analysis, product development, and machine learning to enhance the user experience, improve service convenience, and develop new features. This helps us offer innovative services and maintain a high standard of quality. We rely on our legitimate interests in improving and developing our services for these activities.

5.  Enabling communications between users. We facilitate communication between users to ensure seamless interactions during transportation, deliveries, or other services. This includes allowing drivers and users to contact each other for coordination and resolving issues related to the service.

6.  Marketing and advertising. We use data for marketing and advertising purposes, such as:

•   Sending promotional communications about our services, offers, promotions, news, and events through various channels.

•   Displaying Silver Fleet advertisements on third-party apps or websites based on user interests and characteristics.

•   Showing personalised third-party advertisements within the Silver Fleet app, including sponsored listings and recommendations based on user preferences, location, and order history.

•   Measuring the effectiveness of our ads and third-party ads displayed on our platform.

•   We rely on our legitimate interests in informing users about our services and those offered by our partners for these marketing and advertising activities.

•   Non-marketing communications. We may send surveys and other non-marketing communications to users. This can include informing users about elections, ballots, referenda, or political processes that relate to our services. We perform these activities to fulfil our agreements with users and provide them with relevant information.

•   Legal proceedings and requirements. We use data to investigate and address claims or disputes related to the use of our services, comply with applicable laws, regulations, licenses, agreements, or legal requests, including those from law enforcement agencies. These activities are necessary to fulfil our legitimate interests and meet legal obligations.

C.  Cookies and Third-Party Technologies

Silver Fleet and its partners utilise cookies and similar identification technologies across our applications, websites, emails, and online advertisements.

Silver Fleet employs cookies and similar technologies, which are small text files stored on browsers or devices, utilized by websites, applications, online media, and advertisements. These technologies serve various purposes including:

•   Authenticating users' identities

•   Remembering user preferences and customised settings

•   Determining the popularity and engagement levels of content

•   Delivering and evaluating the effectiveness of advertising campaigns

•   Analysing website traffic, trends, and gaining insights into the online behaviours and interests of individuals who interact with our services

We may also collaborate with third parties to provide audience measurement and analytics services, serve advertisements on our behalf across the internet, and track and report on the performance of such ads. These entities may employ cookies, web beacons, software development kits (SDKs), and other technologies to identify the devices used by visitors on our websites, as well as when they visit other online platforms and services.

D.  Data Sharing and Disclosure

Certain services and functionalities provided by Silver Fleet may necessitate the sharing of data with other users or upon a user's explicit request. Additionally, we may share such data with our affiliated companies, subsidiaries, and trusted partners. This sharing of data may occur due to legal requirements or in relation to the resolution of claims or disputes.

Silver Fleet may share data in the following ways:

1.  With other users:

•   Sharing drivers' first name, ratings, and pickup/drop-off locations with passengers.

•   Sharing drivers' data including names, photos, vehicle details, location, average ratings, contact information, and profile information.

2.  At the user's request:

•   Sharing data with Silver Fleet’s business partners, such as other services, platforms, or websites integrated with Silver Fleet's APIs and vehicle suppliers or services for promotions, contests, or specialised services.

•   Sharing data with emergency services in case of emergencies or incidents.

3.  With the general public:

•   Publicly viewable questions or comments submitted by users on public forums, such as Silver Fleet blogs or social media pages.

4.  With the Silver Fleet account owner:

•   Sharing trip information, including location data, with the owner of an account used by another party, such as an employer's profile or an account associated with a partner transportation company.

5.  With Silver Fleet subsidiaries and affiliates:

•   Sharing data with subsidiaries and affiliates to facilitate service provision and data processing on behalf of Silver Fleet.

6.  With Silver Fleet service providers and business partners:

•   Sharing data with payment processors, background check providers, cloud storage providers, mapping service providers, social media companies, marketing partners, research partners, safety enhancement vendors, consultants, insurance and financing partners, airports, and third-party vehicle suppliers.

7.  For legal reasons or disputes:

•   Sharing users' data as required by applicable laws, regulations, operating licenses, legal processes, governmental requests, or safety concerns. This includes sharing data with law enforcement, public health officials, government authorities, airports, or third parties to enforce terms of service, protect rights or property, or resolve claims or disputes.

8.  With consent:

•   Sharing a user's data other than as described in this notice with the user's explicit consent

E.  Data retention and deletion

Silver Fleet retains user data for the duration necessary for the purposes outlined above. The retention period of user data is determined based on factors such as the type of data, user category, and the specific purposes for which the data was collected.

The length of time that Silver Fleet retains user data may also be influenced by legal and regulatory requirements, as well as considerations related to safety, security, and fraud prevention. Additionally, factors such as outstanding credits, unresolved claims or disputes, or other account-related issues may impact the retention period.

For instance, we retain data:

•   For the duration of users' accounts if it is necessary to provide our services, such as user profile information and credentials.

•   For a period of 10 years to comply with tax obligations.

•   For defined periods necessary for safety or fraud prevention purposes.

Even after an account deletion request, certain data may be retained if required by law, regulations, or for safety, security, fraud prevention, or compliance purposes, or due to account- related issues.

Users have the right to request the deletion of their accounts at any time. Silver Fleet will delete the user's account and associated data following a deletion request, unless retention is required by legal or regulatory obligations, for safety, security, fraud prevention, or due to unresolved account-related matters such as outstanding credits or disputes. Please note that drivers and delivery persons' accounts and data are generally retained for the statutory retention period after a deletion request, as required by legal and regulatory requirements. For riders and order recipients, their data is typically deleted within 90 days of a deletion request, except when retention is necessary for the aforementioned reasons.

Users can initiate an account deletion request by sharing an account deletion instruction with Silver Fleet via email to operations@silverfleetltd.com.

IV. Choice and transparency

Silver Fleet allows users to manage and oversee the data collected by Silver Fleet through various means, including:

1.  Privacy settings: Users have the ability to adjust their privacy settings to control the collection and usage of their data within the Silver Fleet platform.

2.  Device permissions: Users can manage the permissions granted to the Silver Fleet application on their devices, determining which data the app can access.

3.  In-app feedback and ratings: Silver Fleet provides users with the option to submit feedback and ratings within the app, allowing them to share their experiences and contribute to the improvement of our services.

4.  Marketing choices: Users have the option to make choices regarding the marketing communications they receive from Silver Fleet, enabling them to customise their preferences and manage their engagement with promotional content.

Additionally, Silver Fleet offers users the following rights regarding their data:

1.  Access and copies: Users can request access to or copies of their data held by Silver Fleet, providing them with transparency and insight into the information we have collected about them.

2.  Account changes and updates: Users have the ability to modify and update their account information, allowing them to keep their personal details accurate and up to date.

3.  Account deletion: Users can request the deletion of their accounts, ensuring that their personal data is permanently removed from Silver Fleet's systems, subject to the retention periods outlined in our data retention policy.

4.  Processing restrictions: Users have the right to request that Silver Fleet restricts the processing of their data, which means we will only store the data without using or processing it further, as permitted by applicable laws and regulations.

V.  Updates to this notice

We may periodically revise this notice. In the event of significant changes, we will inform users in advance through the Silver Fleet apps or alternative communication channels, such as email. We recommend that users regularly review this notice to stay informed about our privacy practices and any updates.

By continuing to use our services after an update, users give their consent to the revised notice to the extent permitted by applicable laws.