ROVO E-HAILING LIMITED

DRIVER APP PRIVACY POLICY

Effective Date: 15 October 2026

Last Updated: 15 October 2026

Application: ROVO Driver App

Country of Operation: Kenya

1. INTRODUCTION

ROVO E-Hailing Limited (“ROVO”, “we”, “our” or “us”) is committed to respecting and protecting the privacy and personal information of drivers who register, apply to work or provide transportation services through the ROVO Driver App.

This Privacy Policy explains how ROVO collects, uses, stores, shares and protects personal information relating to driver applicants, registered drivers and individuals who provide transportation services through our platform.

It applies when you register as a driver, submit verification documents, use the ROVO Driver App, accept or complete trips, receive payments, contact support or otherwise interact with ROVO in your capacity as a driver.

ROVO processes personal information in accordance with applicable Kenyan law, including the Data Protection Act, 2019, and relevant regulations.

By registering or using the ROVO Driver App, you acknowledge that you have been given access to this Privacy Policy. Where consent is legally required, ROVO will request it separately. Your use of the App does not constitute blanket consent to all forms of data processing.

2. WHO WE ARE

Company: ROVO E-Hailing Limited

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

Country of Operation: Kenya

Business Location: Nairobi, Kenya

ROVO determines the purposes and means of processing personal information for its platform operations, subject to applicable law.

Depending on the contractual and operational arrangement, a fleet partner or other organisation may independently determine how certain driver information is processed. In such cases, the relevant party should provide appropriate privacy information about its own processing activities.

3. PERSONAL INFORMATION WE COLLECT

The information we collect depends on your role, the services you use and the verification requirements applicable to your account.

3.1 Identity and Contact Information

We may collect:

Full legal name.
Date of birth, where required for eligibility verification.
Telephone number and email address.
Residential or contact address.
Profile photograph.
Nationality or other eligibility information where lawfully required.
Emergency contact details, where provided and appropriately justified.
Driver account identification and verification information.

3.2 Identity and Verification Documents

To verify your identity and eligibility to provide transportation services, we may request relevant documents, including:

National identity card, passport or another accepted identity document.
Valid driving licence and relevant licence information.
Driver profile photograph.
Applicable driver or transport authorisations.
Police clearance or background verification documents, where lawful and necessary.
Work authorisation or immigration documentation, where applicable.
Other documents reasonably required for regulatory compliance, safety or platform eligibility.

We will collect only the information reasonably necessary for the relevant purpose and handle documents containing sensitive information with appropriate safeguards.

3.3 Vehicle and Insurance Information

Where you use a vehicle to provide services through ROVO, we may collect:

Vehicle registration number.
Vehicle make, model, year and colour.
Vehicle photographs.
Logbook or proof of ownership, where applicable.
Vehicle inspection and roadworthiness information.
Insurance policy details and validity.
Applicable transport licences and permits.
Fleet ownership or authorisation documents.
Vehicle maintenance or compliance information where necessary.

If you operate a vehicle owned by a fleet partner, we may verify your authorisation to use that vehicle.

3.4 Live Location and Trip Information

The ROVO Driver App may collect precise GPS location information to support driver operations, including:

Your current location while using relevant driver features.
Location during an active trip.
Your movement along the trip route.
Pickup and destination locations.
Trip acceptance, arrival, start and completion times.
Distance travelled and trip duration.
Location information associated with safety incidents, disputes or suspected fraud.

Background location: Where ROVO requires location access while the App is running in the background, we will explain the relevant purpose and request the necessary device permission. Background location may be used while you are online and available for bookings or performing an active trip, where supported and justified by the service.

We do not intend to track your location continuously when you are offline and not using a feature that requires it, except where another lawful and clearly disclosed purpose applies.

You can manage location permissions in your device settings. However, disabling required location access may prevent you from going online, receiving bookings or completing certain trips.

3.5 Trip Performance and Activity Information

We may collect information about your use of the platform, including:

Ride requests offered, accepted, declined or cancelled.
Trip completion records.
Pickup arrival times and estimated arrival times.
Customer ratings and feedback.
Complaints and incident reports.
Compliance with applicable platform requirements.
Relevant service quality and performance indicators.
Account status and eligibility records.

We use these records to administer the platform, support fair service delivery, investigate complaints and improve safety and reliability.

3.6 Earnings, Payments and Financial Information

Depending on the payment arrangements available, we may collect:

Trip earnings and fare breakdowns.
Applicable commissions, platform fees and adjustments.
Incentives, bonuses and promotional rewards.
Payment transaction references and payment status.
Mobile money account details or bank account information required for payouts.
Refund, reconciliation and payment dispute records.
Tax-related information where required by law.

Payment information will be used for authorised payment, reconciliation, accounting, tax compliance and related legitimate purposes.

Where a third-party payment provider processes your transactions, that provider may separately process information under its own terms and applicable law.

3.7 Device and Technical Information

We may collect:

Device model and operating system.
App version and device identifiers.
IP address and relevant technical logs.
Login and session records.
Crash reports and diagnostic information.
Security events and suspicious login attempts.
Information necessary to detect unauthorised access or manipulation of the App.

3.8 Communications and Support Records

When you contact ROVO, we may process your messages, emails, support tickets, complaints, feedback and relevant call or chat records where recording is used and appropriately disclosed.

This information helps us resolve operational issues, investigate disputes and improve support services.

3.9 Safety and Incident Information

Where necessary and lawful, we may collect information relating to accidents, suspected fraud, dangerous driving, complaints, harassment, security incidents or other matters affecting drivers, passengers or the public.

This information may include statements, photographs, trip records and supporting documents relevant to an investigation.

We will apply appropriate access controls and safeguards to this information.

4. WHY WE COLLECT AND USE DRIVER INFORMATION

ROVO may process your personal information for the following purposes:

Driver onboarding: To register applicants and establish driver accounts.
Identity verification: To verify your identity, driving eligibility and applicable authorisations.
Vehicle verification: To confirm relevant vehicle, insurance and compliance information.
Trip allocation: To identify available drivers and coordinate customer bookings.
Navigation and location: To support pickup coordination, trip tracking, route information and trip completion.
Earnings and payouts: To calculate earnings, reconcile fares and process payments.
Customer service: To respond to driver enquiries, complaints and operational issues.
Safety: To investigate accidents, safety incidents, complaints and suspected misconduct.
Fraud prevention: To identify suspicious transactions, account manipulation, impersonation and other misuse.
Performance management: To evaluate service quality and address legitimate operational concerns.
Platform improvement: To diagnose technical issues, improve App performance and develop relevant features.
Legal compliance: To meet applicable tax, transport, employment-related, regulatory or other legal obligations.
Communication: To send booking notifications, service updates, safety alerts, policy changes and relevant operational announcements.
Dispute resolution: To investigate fare disputes, payment complaints and other matters involving trips or account activity.

ROVO will not use personal information for incompatible purposes unless permitted by applicable law.

5. LAWFUL BASIS FOR PROCESSING

Depending on the specific activity, ROVO may process driver information on the following lawful bases:

Contractual necessity: To administer your driver account and perform applicable contractual obligations.
Legal obligations: To comply with applicable transport, tax, regulatory and other legal requirements.
Legitimate interests: To support platform security, prevent fraud, administer trips and improve service reliability where permitted by law and where your rights are appropriately considered.
Consent: Where you have freely consented to a specified activity and consent is the applicable lawful basis.
Other lawful grounds: Any additional basis permitted under applicable Kenyan law.

Where processing is based on consent, you may withdraw it. Withdrawal does not invalidate processing that occurred lawfully before withdrawal, nor does it prevent processing supported by another valid lawful basis.

Where a document or location permission is necessary for a particular service, refusing it may mean that ROVO cannot complete the relevant verification or provide that feature.

6. LOCATION TRACKING AND GPS PERMISSIONS

Location information is important to the operation of the ROVO Driver App.

6.1 When Location May Be Used

Depending on the feature and permissions granted, location information may be processed when:

You are online and available to receive ride requests.
The App identifies nearby booking opportunities.
You navigate to a passenger’s pickup location.
You are completing an accepted trip.
A trip is being reviewed following a complaint or safety incident.
You use an optional feature that requires location information.

6.2 Why Location Is Used

We use location information to:

Match customers with nearby available drivers.
Provide pickup directions and navigation.
Calculate trip distance and duration where applicable.
Support fare calculation and trip records.
Help customers identify the assigned driver and vehicle.
Investigate safety incidents and disputes.
Detect suspicious trip activity or potential fraud.

6.3 Location Controls

You may manage location permissions through your phone’s settings.

When you are offline, ROVO should not continue collecting location merely for routine driver availability or trip allocation, unless a separate lawful and disclosed feature requires it.

You should use the App’s online/offline controls to indicate your availability accurately.

7. HOW WE SHARE DRIVER INFORMATION

ROVO does not sell driver personal information as a commercial data product.

We may share relevant information with the following recipients when necessary and lawful.

7.1 Customers

Before a booked trip begins, relevant driver information may be shown to the customer, including your name, profile photograph and vehicle details, as applicable.

During a trip, customers may receive trip-related information such as your location, estimated arrival time and vehicle details where necessary for the service.

7.2 Fleet Owners and Fleet Partners

Where you operate a vehicle supplied or managed by a fleet partner, relevant information may be shared for vehicle allocation, trip reconciliation, compliance, earnings administration and other legitimate fleet-management purposes.

The scope of sharing should reflect the applicable contractual arrangement and legal requirements.

7.3 Payment Providers

We may share necessary transaction information with authorised payment providers, banks or mobile money providers to process payouts, verify transactions and resolve payment disputes.

7.4 Technology and Hosting Providers

We may use authorised service providers for cloud hosting, mapping, navigation, communications, analytics, identity verification, cybersecurity and technical support.

Appropriate contractual and data protection safeguards should apply to these arrangements.

7.5 Authorities and Regulators

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

7.6 Professional Advisers and Legal Representatives

Where necessary, relevant information may be shared with lawyers, auditors, insurers or other professional advisers subject to appropriate confidentiality and legal safeguards.

7.7 Business Transfers

In connection with a lawful merger, acquisition, restructuring or transfer of business assets, relevant information may be transferred subject to applicable legal requirements.

7.8 Other Disclosures

We may share information where you have directed or authorised us to do so, provided the disclosure is lawful.

8. INTERNATIONAL DATA TRANSFERS

Some technology providers may store or process personal information outside Kenya.

Where information is transferred internationally, ROVO will comply with applicable Kenyan data protection requirements, including applicable safeguards and lawful transfer conditions.

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

9. RETENTION OF DRIVER INFORMATION

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

Retention periods may depend on:

Whether your driver account remains active.
Driver verification and eligibility requirements.
Trip records and earnings reconciliation.
Tax, accounting and regulatory obligations.
The investigation or resolution of complaints and disputes.
Safety, fraud prevention and legal claim requirements.
Any lawful obligation to preserve relevant records.

When information is no longer required, ROVO will take appropriate steps to delete it, anonymise it or securely dispose of it, subject to applicable retention requirements.

Closing your account does not automatically require immediate deletion of every record. Where information must be retained lawfully, it will be retained only for the relevant permitted purpose and handled with appropriate safeguards.

10. DATA SECURITY

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

Measures may include:

Access restrictions and role-based permissions.
Secure authentication and account controls.
Appropriate encryption and secure data transmission.
Confidentiality obligations for personnel and service providers.
Security monitoring and incident response procedures.
Backups and appropriate recovery arrangements.
Staff training and periodic review of security practices.

No digital system can be guaranteed to be completely secure. ROVO will take reasonable and legally required steps to manage security risks and respond to personal data breaches.

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

11. YOUR DATA PROTECTION RIGHTS

Subject to applicable law, you may have the right to:

11.1 Be informed about how your personal information is collected and used.

11.2 Access personal information held about you.

11.3 Request correction of inaccurate, incomplete or misleading personal information.

11.4 Request deletion of personal information where legally permitted, subject to lawful retention obligations.

11.5 Object to certain processing of your information where applicable law provides that right.

11.6 Withdraw consent where consent is the lawful basis for processing.

11.7 Raise a complaint with ROVO and, where appropriate, the Office of the Data Protection Commissioner in Kenya.

11.8 Exercise other applicable rights available under Kenyan data protection law.

To exercise a right, contact ROVO using the official contact details published on www.rovo.co.ke.

We may request reasonable information to verify your identity before processing your request. We will respond in accordance with applicable legal requirements and timeframes.

Certain requests may be limited or refused where a lawful exception applies.

12. AUTOMATED DECISION-MAKING AND DRIVER PERFORMANCE

ROVO may use automated systems to support driver matching, trip allocation, navigation, fraud detection, safety monitoring and platform operations.

The App may also use trip records, customer feedback and other relevant information to support driver performance reviews or account eligibility decisions.

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 raise concerns about a significant decision through ROVO’s official support channels.

ROVO will not represent an automated score or system flag as conclusive proof of misconduct without appropriate consideration of the circumstances where such review is required.

13. DRIVER ACCOUNT SECURITY AND RESPONSIBILITIES

You are responsible for protecting your account and the information associated with it.

You must:

Keep your password and verification codes confidential.
Use accurate information when registering or updating your profile.
Notify ROVO promptly if you suspect unauthorised account access.
Avoid sharing your account with an unauthorised person.
Ensure that documents you submit are genuine and current.
Use only vehicles you are authorised to operate.
Avoid collecting, copying or disclosing customer information for unrelated purposes.
Report suspected data breaches or security incidents through official channels.

You must not use passenger information obtained through ROVO to contact, track, harass, market to or otherwise engage a passenger for unrelated purposes without a lawful basis or appropriate authorisation.

14. DRIVER COMMUNICATIONS

ROVO may send you communications relating to:

Booking requests and trip updates.
Account verification and document expiry.
Earnings, payments and reconciliation.
Safety alerts and emergency procedures.
App updates and service interruptions.
Operational announcements and policy changes.
Promotions or optional offers where legally permitted.

Essential operational messages may continue even if you opt out of promotional communications.

Where consent is required for marketing, ROVO will obtain it in accordance with applicable law.

15. COOKIES AND SIMILAR TECHNOLOGIES

The ROVO website may use cookies or similar technologies to support essential functions, security, preferences and website performance.

The Driver App may use device permissions, software identifiers, diagnostic tools or similar technologies to support its operation.

Any non-essential tracking technologies will be handled in accordance with applicable legal requirements, including relevant consent requirements.

16. THIRD-PARTY SERVICES

The ROVO Driver App may rely on third-party mapping, navigation, payment, identity verification, hosting or communication services.

Those providers may process information under their own applicable terms and privacy policies.

ROVO will take appropriate steps to manage the processing activities for which it is responsible and to use suitable safeguards where required.

You should review third-party privacy information where a service directs you to do so.

17. ACCOUNT DEACTIVATION AND CLOSURE

You may request account closure through the available account settings or official ROVO support channels.

ROVO may restrict, suspend or deactivate an account where reasonably necessary due to:

Expired or invalid driving or vehicle documents.
Suspected account impersonation or fraud.
Serious safety or security concerns.
Material breaches of applicable platform requirements.
Legal or regulatory obligations.
Other legitimate grounds consistent with applicable law.

Where reasonably practicable and legally permitted, ROVO will provide relevant information about the action and an appropriate channel to request a review.

Account closure does not automatically remove lawful record-retention obligations.

18. CHILDREN’S PERSONAL INFORMATION

The ROVO Driver App is intended for individuals legally eligible to register and provide the relevant driving services.

ROVO does not knowingly collect children’s personal information for driver onboarding without an appropriate lawful basis and any authorisation required under applicable law.

If you believe children’s personal information has been collected unlawfully, please contact ROVO through its official privacy channels.

19. CHANGES TO THIS PRIVACY POLICY

ROVO may update this Privacy Policy to reflect changes in its services, technology, operations or applicable law.

The latest version will be published on www.rovo.co.ke or made available through the Driver App.

Where required by law, ROVO will provide additional notice or obtain consent before implementing relevant changes.

The effective date will be updated to reflect the current version.

20. CONTACT AND PRIVACY REQUESTS

For questions about this Privacy Policy, requests to exercise data protection rights, or concerns about the handling of your information, contact ROVO through the official contact details published on:

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

Please use the subject line “Driver Privacy Request – ROVO” and provide sufficient information to identify your request.

Do not send your password, verification codes 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/

21. 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 or restrict any right or protection that cannot lawfully be excluded or restricted.

22. OUR COMMITMENT TO DRIVERS

ROVO recognises that drivers entrust the platform with important personal, professional, financial and location information.

We are committed to handling that information responsibly, limiting access to authorised purposes, providing appropriate transparency and taking reasonable steps to protect driver privacy as we develop a reliable mobility platform in Kenya.

ROVO E-Hailing Limited

ROVO — Ride. Connect. Go.

Your Destination. Your Choice.