wacaOwners

Privacy policy

Draft. This text is being reviewed by a lawyer and may change before we launch. Parts in [square brackets] are still to be filled in.

Who we are

[COMPANY LEGAL NAME], registered in Nigeria ([RC NUMBER]), of [ADDRESS] ("we", "us"), runs this website and the car rental and car sales service. We decide how your personal data is used, which makes us the "data controller". You can reach our data protection contact at [DATA PROTECTION EMAIL].

What we collect, and why

  • Renters: your name, email, phone number, driver's licence number and expiry date, and the details of your booking. We use them to confirm your booking, check that you may drive, hand over the car and contact you about it. At hand-over our staff may check your licence with the official records through VerifyMe, with your agreement (see "Identity checks" below).
  • Car buyers: your name, email, phone number and, if you give it, your NIN or passport number. We use them to reserve the car, arrange the inspection and the transfer of ownership, and handle the payment.
  • Trip updates: we email you about your booking. If you tick the box when booking (or switch it on later), we also send updates about your trip to your phone number on WhatsApp: reminders before pick-up, each evening of the trip and before you return the car. We use Meta's WhatsApp Business service for this, which processes your phone number and the messages. You can stop at any time by replying STOP, on your booking page or in your account.
  • Customers with an account: if you create an account on our website we keep your name, email, phone number, a password (stored only in scrambled form) and, if you choose to save them, your driver's licence number and expiry date, so we can fill in the booking form for you next time. We link your bookings and purchases to the account so you can see them. You can ask us to correct or delete the account and what is saved in it (see "Your rights"). Booking without an account still works; a booking made as a guest is kept as described above.
  • Car owners: your name, email, phone number, city, a photo of your ID or the result of an identity check (see below), your bank account details (we ask your bank who owns the account and keep the account name the bank gives us), and your car's photos and papers (registration, insurance, customs, proof of ownership). We use them to verify you, list your car, pay you safely and keep the car's records.
  • Businesses using our API: the business and contact details you give us, and a record of the bookings and sales made through your keys.
  • Everyone: messages we send you (confirmations, reminders, updates) and, for staff safety and fraud prevention, a record of who changed what in our systems.

Identity checks

To prevent fraud and theft we may check your identity with the official records, only after you agree. Owners can use a one-time "virtual NIN" created in the NIMC app, so we never see their real National Identification Number. At hand-over staff may check a renter's driver's licence. For a check we send your name, date of birth and ID number to our verification provider, VerifyMe, which checks them with the official records (NIMC, or the road-safety authority for licences). We keep only the RESULT: whether your name and date of birth matched, the last four digits of a licence number, the provider's reference and the record of your agreement. We do not keep your ID number, your date of birth, or the photograph held in the official record. We keep the result for [12] months, then delete it; you can ask us to delete it sooner. A person at our company always looks at a result before it affects you: we do not refuse anyone solely because of an automated check.

Payments

Card payments are handled by Paystack. We never see or store your card number. We keep the payment reference, the amount and whether it succeeded. Bank transfers into our escrow account for car sales are recorded by the transfer reference.

Who we share it with

We share only what is needed with: Paystack (payments, and checking the name on a bank account); VerifyMe (identity checks, see above); Termii (text messages); [EMAIL PROVIDER] (email); [HOSTING PROVIDERS] (where our systems run); [INSURER] and [AIRPORT OPERATOR] where a rental or hand-over requires it; and the buyer or seller of a car where needed to complete a sale (for example the buyer's name, so the seller's papers can be prepared). We may disclose data to the police, courts or other authorities where the law requires it. We do not sell your data.

Why we may use it (our legal basis)

To carry out the contract with you (your rental, purchase, listing or API account); to meet legal duties (records, tax, anti-fraud); for our legitimate interests in running a safe service (preventing fraud and theft, resolving disputes), which we balance against your rights; and, where we ask, with your consent.

How long we keep it

[RETENTION PERIODS — for example: booking and payment records for [X] years for accounting and legal reasons; ID documents and licence details for [X] months after the last rental; owner verification documents while the account is active and [X] years after]. When the time is up we delete or anonymise it.

Where it is stored

On servers of [HOSTING PROVIDERS] located in [COUNTRIES]. Where data is stored outside Nigeria we make sure it is protected as the law requires.

How we protect it

Access to personal data is limited to staff who need it for their job, every change staff make is recorded, uploaded IDs and papers are kept private, and connections to our website are encrypted. No system is perfectly secure; if a breach affects you, we will tell you and the Commission as the law requires.

Your rights

You may ask us to: tell you what data we hold about you and give you a copy; correct it; delete it (where we have no legal reason to keep it); restrict or object to some uses; and move it to another service. You may withdraw consent at any time where we rely on it. Write to [DATA PROTECTION EMAIL]; we will answer within [30] days. If you are unhappy with our answer you can complain to the Nigeria Data Protection Commission.

Cookies

We use only the cookies the site needs to keep you signed in (customers, owners, businesses and staff) and to keep the booking process secure. We do not use advertising or tracking cookies.

Children

Our service is for adults. We do not knowingly collect data about children.

Changes

We will post any change to this page and, for important changes, tell you by email. This policy was last updated on [DATE].