ROVO E-HAILING LIMITED

CUSTOMER PRIVACY POLICY

Effective Date: 15 October 2026

Last Updated: 15 October 2026

1. INTRODUCTION

ROVO E-Hailing Limited (“ROVO”, “we”, “our” or “us”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you visit www.rovo.co.ke, use the ROVO customer application, book a ride, communicate with our support team or otherwise interact with our services.

ROVO is a mobility technology platform designed to connect customers with drivers and other eligible service providers for convenient transportation and related mobility services.

We process personal information in accordance with applicable Kenyan data protection laws, including the Data Protection Act, 2019, and applicable regulations.

By using our website or services, you acknowledge that you have been given access to this Privacy Policy. Where consent is required by law, we will request it separately. Using ROVO does not constitute blanket consent to every form of data processing.

2. WHO WE ARE

Data Controller: ROVO E-Hailing Limited

Website: www.rovo.co.ke

Country of Operation: Kenya

Business Location: Nairobi, Kenya

ROVO determines the purposes and means of processing personal information for its own platform operations, subject to applicable law. Certain third-party service providers may process personal information on our behalf under appropriate arrangements.

For privacy-related enquiries, please use the official contact details published on our website. ROVO will publish or confirm its designated privacy contact or Data Protection Officer details where applicable.

3. PERSONAL INFORMATION WE COLLECT

Depending on how you use ROVO, we may collect the following categories of personal information.

3.1 Personal and Account Information

When you create an account or register to use our services, we may collect:

Full name.
Mobile telephone number.
Email address, where provided.
Account username and authentication information.
Profile photograph, where provided or required for a specific feature.
Preferred communication language and account preferences.

3.2 Location Information

To provide ride-hailing services, we may collect:

Your pickup and destination locations.
Your device’s approximate or precise location, depending on your permissions.
Your trip route and location during an active journey.
Trip start and end times.
Location information associated with booking, safety, customer support or dispute resolution.

Location access may be required for certain app functions. You can manage your device’s location permissions through your phone settings, but disabling them may limit some ROVO services.

We will process location information only for specified and lawful purposes, subject to the applicable legal requirements.

3.3 Ride and Transaction Information

We may collect information relating to your use of our services, including:

Ride requests and booking history.
Ride category selected, such as Economy, Comfort or Premium, where available.
Driver and vehicle details associated with your trip.
Fare estimates, final fares and applicable charges.
Payment status, transaction references and refunds.
Promotional codes, discounts and referral activity.
Cancellations, complaints and service feedback.

Where payments are handled by third-party payment providers, we may receive transaction confirmations and relevant payment references. We do not intend to collect or store complete payment card details unless a specific authorised arrangement requires it and appropriate safeguards are in place.

3.4 Communications and Customer Support

When you contact ROVO, we may process:

Messages, emails and support requests.
Complaints, compliments and feedback.
Lost-property reports.
Information you provide during safety investigations or fare disputes.
Relevant call recordings or chat records, where used and appropriately disclosed.

Please avoid sending unnecessary sensitive personal information through ordinary customer support channels.

3.5 Device and Technical Information

When you access our website or application, we may collect technical information such as:

Device type and operating system.
Application version.
IP address and technical identifiers.
Login timestamps and session information.
Error reports, diagnostics and security logs.
Website usage information and cookie preferences.

We use this information to maintain platform security, troubleshoot technical problems and improve service performance.

3.6 Safety and Incident Information

Where necessary and lawful, we may process information relating to reported accidents, security incidents, alleged misconduct, fraudulent activity, complaints or other safety concerns.

Such information may be used to investigate incidents, protect users and drivers, comply with legal obligations and cooperate with competent authorities where legally justified.

4. HOW WE USE YOUR PERSONAL INFORMATION

ROVO may use personal information for the following purposes:

Account management: Creating, verifying and maintaining your customer account.
Ride coordination: Matching you with an available driver or eligible service provider.
Trip management: Processing bookings, providing pickup information and managing trip status.
Pricing and payments: Calculating fares, recording payments, managing refunds and resolving billing disputes.
Customer assistance: Responding to enquiries, complaints, lost-property reports and feedback.
Safety and security: Investigating incidents, detecting suspicious activity and helping protect customers and drivers.
Fraud prevention: Identifying unauthorised account access, false bookings, payment abuse and other suspected fraudulent activity.
Service improvement: Understanding platform performance, identifying technical issues and improving customer experience.
Communications: Sending booking confirmations, trip updates, service announcements, security alerts and policy changes.
Marketing: Sending promotional offers, rewards and marketing communications where permitted by law and subject to applicable consent or opt-out requirements.
Legal compliance: Responding to lawful requests, meeting regulatory obligations and establishing, exercising or defending legal claims.

We will not use personal information for purposes that are incompatible with the original purpose of collection unless permitted by applicable law.

5. OUR LAWFUL BASES FOR PROCESSING

ROVO will process personal information only where a lawful basis applies under Kenyan law.

Depending on the circumstances, this may include:

Contractual necessity: To create your account, arrange a requested ride or perform obligations connected with the service you request.
Legal obligations: To comply with applicable tax, transport, regulatory, court or other legal requirements.
Consent: Where you have freely given consent for a specified purpose, such as certain optional marketing or non-essential tracking technologies.
Legitimate interests: Where permitted by law, for proportionate activities such as platform security, fraud prevention, service improvement and the defence of legal claims, while considering your rights and interests.
Other lawful grounds: Any other basis expressly permitted by applicable law.

Where processing depends on consent, you may withdraw that consent at any time. Withdrawal will not invalidate processing lawfully undertaken before withdrawal, and it will not affect processing supported by another valid legal basis.

6. WHEN WE SHARE YOUR INFORMATION

ROVO does not sell your personal information to third parties as a commercial data product.

We may share relevant information with the following categories of recipients where necessary, proportionate and lawful.

6.1 Drivers and Service Providers

To facilitate a booking, we may share information necessary for the trip, such as your name or appropriate account identifier, pickup and destination details, relevant contact information and trip instructions.

Drivers may receive your location and contact information as required to complete your booking.

6.2 Payment Service Providers

We may share transaction information with authorised payment providers, banks or other relevant financial service providers to process payments, verify transactions, prevent fraud and administer refunds.

Their handling of personal information may also be governed by their own privacy policies.

6.3 Technology and Hosting Providers

We may engage service providers for application hosting, cloud storage, mapping, communications, analytics, customer support, cybersecurity and software maintenance.

These providers must be subject to appropriate contractual, confidentiality and data protection safeguards where required.

6.4 Fleet Partners and Business Partners

Where necessary to deliver a requested service, we may share relevant trip or operational information with an authorised fleet owner, fleet manager or service partner.

We will limit disclosure to information necessary for the relevant purpose.

6.5 Authorities and Legal Recipients

We may disclose information to courts, law enforcement agencies, regulators or other competent authorities where required by law, pursuant to a valid legal process or where otherwise lawfully justified.

6.6 Corporate Transactions

If ROVO undergoes a merger, restructuring, acquisition or transfer of business assets, relevant information may be transferred subject to applicable law and appropriate safeguards.

6.7 With Your Direction or Consent

We may share information where you expressly request or authorise us to do so, provided the disclosure is lawful.

7. INTERNATIONAL DATA TRANSFERS

Some technology providers may store or process information outside Kenya.

Where personal information is transferred outside Kenya, ROVO will comply with applicable Kenyan data protection requirements, including any applicable requirements concerning transfer safeguards, adequate protection, consent and other lawful conditions.

We will take reasonable steps to ensure that relevant recipients protect personal information appropriately and use it only for authorised purposes.

8. HOW LONG WE KEEP YOUR INFORMATION

ROVO retains personal information only for as long as reasonably necessary for the purposes for which it was collected, subject to applicable legal obligations.

Retention periods may depend on:

Whether your customer account remains active.
The need to maintain ride and transaction records.
Applicable accounting, tax and regulatory requirements.
The resolution of complaints, refunds, disputes or legal claims.
Fraud prevention and platform security requirements.
Any lawful requirement to preserve evidence or records.

When personal information is no longer required, we will take appropriate steps to delete it, anonymise it or otherwise securely dispose of it, subject to lawful retention obligations.

Deleting your account may not immediately remove all information where retention is legally required or necessary for a permitted purpose.

9. HOW WE PROTECT YOUR INFORMATION

ROVO will implement appropriate technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, loss, misuse or destruction.

Depending on the nature of the information and risks involved, safeguards may include:

Access controls and staff authorisation procedures.
Authentication and account security measures.
Secure communications and appropriate encryption.
Confidentiality obligations for personnel and service providers.
Security monitoring, backups and incident response procedures.
Staff awareness and data protection training.
Periodic review of relevant security practices.

No online platform or electronic transmission can be guaranteed to be completely secure. We will take reasonable and legally required steps to address security risks and respond to incidents.

Where a personal data breach occurs, ROVO will assess the incident and make any notifications required by applicable law.

10. YOUR DATA PROTECTION RIGHTS

Subject to applicable law and any relevant limitations, you may have the right to:

10.1 Right to Be Informed

Receive information about how and why your personal information is processed.

10.2 Right of Access

Request access to personal information held about you.

10.3 Right to Correction

Request correction of inaccurate, incomplete or misleading information.

10.4 Right to Deletion

Request deletion of personal information where the law permits, subject to lawful retention requirements.

10.5 Right to Object

Object to certain processing of your personal information where provided by law.

10.6 Right to Withdraw Consent

Withdraw consent where processing is based on consent.

10.7 Right to Complain

Raise a privacy complaint with ROVO and, where appropriate, lodge a complaint with Kenya’s Office of the Data Protection Commissioner (ODPC).

10.8 Other Applicable Rights

Exercise any additional rights available to you under applicable data protection legislation.

To exercise a right, contact ROVO through the official contact details published on www.rovo.co.ke. We may request reasonable information to verify your identity before responding.

We will handle requests within the timeframes and procedures prescribed by applicable law. Certain requests may be refused or limited where a lawful exception applies, and we will explain this where required.

11. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies to support essential website functions, maintain security, remember preferences and understand website performance.

Where applicable, non-essential analytics or advertising cookies will be used in accordance with relevant consent requirements.

You can manage cookies through your browser settings and any preference controls provided on our website. Disabling certain cookies may affect website functionality.

Please refer to our separate Cookie Policy on www.rovo.co.ke for additional details once published.

12. MARKETING AND PROMOTIONAL COMMUNICATIONS

ROVO may provide information about promotions, discounts, referral programmes, new services and other relevant offers where permitted by law.

Where consent or an opt-in is required, we will obtain it before sending the relevant communications.

You can unsubscribe from marketing emails using the unsubscribe option where available or request that promotional messages stop through our official support channels.

Even if you opt out of marketing, we may continue sending essential service messages, including booking confirmations, payment notifications, safety alerts and important account or policy updates.

13. CHILDREN’S PRIVACY

ROVO’s customer services are intended for individuals who are legally eligible to use the relevant service.

We do not knowingly collect children’s personal information without an appropriate lawful basis and any consent or authorisation required under applicable law.

Where children’s personal information is involved, ROVO will apply the additional safeguards required by Kenyan law. If you believe a child has provided personal information unlawfully, please contact us so that we can assess the matter and take appropriate action.

14. THIRD-PARTY WEBSITES AND SERVICES

Our website or application may contain links to third-party websites, payment services, maps or other external platforms.

ROVO does not control the privacy practices of independent third parties. Your use of those services may be subject to their separate terms and privacy policies.

We encourage you to review the applicable policies before providing personal information to a third party.

15. AUTOMATED SYSTEMS AND DECISION-MAKING

ROVO may use automated systems to support driver matching, fare calculations, fraud detection, account security and platform operations.

Where a decision based solely on automated processing produces legal effects or similarly significant effects on you, ROVO will comply with applicable legal requirements, including any relevant safeguards, information rights or review mechanisms.

Where applicable, you may request further information about a significant automated decision and raise a concern through our support channels.

16. YOUR RESPONSIBILITIES

To help protect your personal information, you should:

Keep your account credentials and verification codes confidential.
Use accurate information when registering and booking rides.
Notify ROVO promptly if you suspect unauthorised access to your account.
Avoid sharing another person’s personal information without lawful authority.
Use official ROVO communication channels for account and privacy enquiries.

ROVO will not ask you to disclose your password through ordinary customer support communications.

17. CHANGES TO THIS PRIVACY POLICY

ROVO may update this Privacy Policy from time to time to reflect changes in our services, technology, business practices or legal obligations.

The latest version will be published on www.rovo.co.ke with the applicable effective date.

Where required by law, we will provide additional notice or obtain consent before implementing material changes that require it.

We encourage you to review this page periodically.

18. CONTACT ROVO ABOUT PRIVACY

If you have a question, wish to exercise a data protection right or want to raise a privacy concern, please contact ROVO through the official contact details displayed on:

Website: https://www.rovo.co.ke

Please use the subject line “Privacy Request – ROVO Customer” and include enough information for us to understand your request. Do not include your password or unnecessary sensitive information.

If your concern is not resolved, you may contact the Office of the Data Protection Commissioner in Kenya through its official website:

https://www.odpc.go.ke/

19. GOVERNING LAW

This Privacy Policy is governed by the laws of Kenya, including the Data Protection Act, 2019, and applicable regulations.

Nothing in this Policy is intended to exclude, restrict or override any right or protection that cannot lawfully be excluded, restricted or overridden.

20. FINAL STATEMENT

At ROVO, we believe that convenient mobility must go hand in hand with privacy, transparency and trust.

We are committed to handling customer information responsibly and taking appropriate steps to protect the information entrusted to us as we work to deliver a safer and more reliable mobility experience.

ROVO E-Hailing Limited

ROVO — Ride. Connect. Go.