Privacy Policy

1. Introduction

Welcome to Fleex Driver ("we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Fleex Driver mobile application (the "App"). This policy applies to drivers who use our platform to provide ride-hailing and delivery services in Mauritania.

By using the Fleex Driver app, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

2. Information We Collect

We collect several types of information to provide and improve our services to you.

2.1 Personal Information

When you register as a driver with Fleex, we collect:

Identity Information:

• Full name
• Email address
• Phone number
• National ID number
• Driver's license number and expiration date
• Date of birth
• Profile photo

Vehicle Information:

• Vehicle type (car, motorcycle, toktok)
• Vehicle make and model
• License plate number
• Vehicle color
• Vehicle registration documents
• Vehicle insurance information
• Vehicle photos (exterior and interior)

Financial Information:

• Bank account information (for earnings deposits)
• Ride earnings and transaction history
• Commission payments
• Balance and payout records

Document Verification:

• Scanned copies of driver's license
• Scanned copies of vehicle registration
• Scanned copies of insurance documents
• Scanned copies of national ID
• Professional photos for identity verification

2.2 Location Data (CRITICAL - ALWAYS ACTIVE)

We continuously track your precise location (GPS coordinates) when:

• You are online and available for rides
• You have an active ride in progress
• You are navigating to a pickup location
• You are completing a delivery
• The app is running in the background
• The app is closed but you remain online
• Your device screen is locked

Location data is used for:

• Real-time driver positioning: Passengers see your live location during rides
• Accurate fare calculation: Metered rides calculate fare based on actual distance traveled
• Route tracking: GPS checkpoints are logged for ride verification
• Fraud detection: We detect GPS spoofing, teleportation, and mock locations
• Service quality: Ensuring drivers follow optimal routes
• Proximity matching: Assigning rides to nearby drivers

Location data retention:

• Active ride data: Stored in Firebase Cloud Firestore during the ride
• GPS checkpoints: Retained for 90 days after ride completion for billing, support, and fraud investigation
• Historical location: Aggregated data may be retained for analytics (anonymized after 90 days)

Location data sharing:

• Passengers: Can see your real-time location during active rides
• Fleex Admin: Has access to location data for support, verification, and fraud detection
• Google Maps: Location coordinates are sent to Google Maps API for navigation and geocoding services

2.3 Device Information

We automatically collect information about your device:

• Device model and manufacturer
• Operating system version (Android version)
• Unique device identifiers (Android ID, FCM token)
• Mobile network information
• Device settings (language, timezone)
• Battery status (to optimize background tracking)
• Screen state (on/off) for power management

2.4 Usage Data

We collect information about how you use the App:

Ride History:

• Pickup and dropoff locations
• Ride duration and distance
• Fare amounts and pricing details
• Ride status updates (requested, accepted, in progress, completed)
• Timestamps for all ride events

Driver Activity:

• Online/offline status and duration
• Acceptance rate (rides accepted vs. declined)
• Cancellation rate and reasons
• Average rating from passengers
• Total rides completed
• Total earnings

App Interactions:

• Features used
• Screen views and navigation patterns
• Error messages and crashes
• Performance metrics (app load time, GPS accuracy)

2.5 Photos and Media

We collect photos when you:

• Register as a driver (profile photo, vehicle photos)
• Upload verification documents (license, registration, insurance)
• Report issues or accidents (optional incident photos)

Storage: All photos are stored in Firebase Cloud Storage and are encrypted in transit and at rest.

2.6 Communication Data

We may collect:

• Messages sent to Fleex support
• Phone call logs (when you call passengers using in-app calling)
• Push notification interactions
• In-app feedback and ratings

3. How We Use Your Information

We use your information for the following purposes:

3.1 Service Delivery

• Account Management: Creating and maintaining your driver account
• Ride Matching: Assigning ride requests based on proximity and availability
• Navigation: Providing turn-by-turn directions to pickup and dropoff locations
• Fare Calculation: Computing fares based on multiple factors including distance, time, and demand
• Payment Processing: Calculating earnings and processing payouts
• Communication: Facilitating communication between drivers and passengers

3.2 Safety and Security

• Identity Verification: Confirming you are who you claim to be
• Fraud Detection: Identifying GPS spoofing, mock locations, and suspicious activity
• Account Security: Detecting unauthorized access or account compromise
• Incident Investigation: Reviewing ride history in case of disputes or safety incidents
• Insurance Claims: Providing data for accident investigations when necessary

3.3 Service Improvement

• Analytics: Understanding driver behavior and app usage patterns
• Performance Monitoring: Tracking app crashes, errors, and slow performance
• Feature Development: Building new features based on driver needs
• A/B Testing: Testing new features with select groups of drivers

3.4 Legal and Compliance

• Legal Obligations: Complying with Mauritanian laws and regulations
• Tax Reporting: Providing earnings data for tax purposes
• Regulatory Compliance: Meeting transportation and business licensing requirements
• Legal Disputes: Responding to legal requests, court orders, or government inquiries

3.5 Marketing and Communications

• Service Updates: Notifying you of app updates, new features, and policy changes
• Promotional Offers: Sending incentives, bonuses, and promotional campaigns (opt-out available)
• Driver Support: Providing tips, training materials, and best practices

4. How We Share Your Information

We share your information in the following circumstances:

4.1 With Passengers (Limited Data)

During an active ride, passengers can see:

• Your first name
• Your real-time GPS location
• Your vehicle type, color, and license plate
• Your driver rating
• Your photo

Passengers cannot see: Your phone number, national ID, driver's license, full address, earnings, or ride history.

4.2 With Fleex Admin and Support

Fleex administrators and support staff have access to:

• All personal information (for account verification)
• Complete ride history and earnings
• GPS location data and route history
• Document uploads and verification status
• Device information and app usage data

Purpose: Account management, customer support, fraud investigation, and quality assurance.

4.3 With Third-Party Service Providers

We share data with trusted service providers who help us operate the App:

Provider	Data Shared	Purpose
Firebase (Google)	All data types	Backend infrastructure, authentication, database, storage, push notifications, analytics, crash reporting
Google Maps	GPS coordinates, addresses	Navigation, route calculation, geocoding, reverse geocoding
Payment Processors	Bank account info, earnings data	Processing payouts and transfers
Cloud Hosting (Firebase Firestore)	All ride and driver data	Secure data storage and real-time synchronization

All third-party providers are bound by data protection agreements and process data only as instructed.

4.4 For Legal Reasons

We may disclose your information when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations, court orders, or government requests
• Enforce our Terms of Service or investigate violations
• Protect the rights, property, or safety of Fleex, drivers, passengers, or the public
• Detect, prevent, or address fraud, security, or technical issues
• Respond to claims that content violates third-party rights

4.5 Business Transfers

If Fleex is involved in a merger, acquisition, asset sale, or bankruptcy, your information may be transferred to the new owner. You will be notified of any such change via email or prominent notice in the App.

4.6 With Your Consent

We may share information for other purposes when you provide explicit consent, such as:

• Sharing testimonials or success stories (with your permission)
• Participating in research studies or surveys
• Referring other drivers to the platform

5. Data Security

We implement industry-standard security measures to protect your information:

5.1 Encryption

• In Transit: All data transmitted between your device and our servers uses HTTPS/TLS encryption
• At Rest: Data stored in Firebase Firestore and Firebase Cloud Storage is encrypted
• Sensitive Fields: National ID, driver's license, and bank account numbers are encrypted with additional layers

5.2 Access Controls

• Authentication: Firebase Authentication with email/password
• Authorization: Role-based access control (drivers can only access their own data)
• Admin Access: Logged and monitored for audit purposes
• Device Security: Single-device login enforcement (logging in on a new device logs out the old one)

5.3 Integrity Protection

• HMAC Verification: Metering data (distance, time, fare) uses HMAC signatures to prevent tampering
• GPS Validation: Unrealistic speeds, teleportation, and mock locations are detected and rejected
• Audit Logs: All data modifications are logged with timestamps and user IDs

5.4 Security Monitoring

• Firebase App Check: Ensures requests come from legitimate app instances
• Crashlytics: Monitors app crashes and errors for quick resolution
• Suspicious Activity Alerts: Automated detection of GPS spoofing, duplicate logins, and unusual patterns

6. Your Privacy Rights (GDPR Compliance)

You have the following rights regarding your personal data:

6.1 Right to Access

• What it means: You can request a copy of all personal data we hold about you
• How to exercise: Contact privacy@fleex.mr with subject "Data Access Request"
• Response time: Within 30 days
• Format: JSON export or PDF report

6.2 Right to Rectification

• What it means: You can correct inaccurate or incomplete information
• How to exercise: Update your profile in the App settings or contact support@fleex.mr
• Examples: Correcting your phone number, updating vehicle information, changing profile photo

6.3 Right to Deletion ("Right to be Forgotten")

• What it means: You can request deletion of your account and all associated data
• How to exercise:
  • In-app: Go to Settings > Account > Delete Account
  • Email: Send request to privacy@fleex.mr with subject "Account Deletion Request"
• Processing time: Within 7 days of request
• Data retention exceptions:
  • Financial records (retained for 7 years for tax/legal compliance)
  • Fraud investigation records (retained for 3 years)
  • Legal dispute records (retained until resolution)
• After deletion: All GPS checkpoints, ride history, photos, and personal information are permanently deleted after the retention period

6.4 Right to Data Portability

• What it means: You can receive your data in a machine-readable format and transfer it to another service
• How to exercise: Contact privacy@fleex.mr with subject "Data Portability Request"
• Format: JSON file containing all your data
• Included data: Profile, ride history, earnings, ratings, GPS logs

6.5 Right to Restrict Processing

• What it means: You can request that we limit how we use your data
• How to exercise: Contact privacy@fleex.mr
• Note: This may limit your ability to use the App (e.g., restricting location tracking prevents accepting rides)

6.6 Right to Object

• What it means: You can object to processing of your data for certain purposes
• How to exercise:
  • Marketing emails: Click "Unsubscribe" in any promotional email
  • Push notifications: Disable in App Settings or device settings
  • Analytics: Opt out by contacting privacy@fleex.mr
• Note: You cannot object to processing required for core app functionality (GPS tracking, ride matching)

6.7 Right to Withdraw Consent

• What it means: You can withdraw previously given consent at any time
• How to exercise: Disable permissions in device settings or delete your account
• Effect: We will stop processing data based on that consent (e.g., disabling location permission stops ride offers)

7. Data Retention

We retain your data for the following periods:

Data Type	Retention Period	Reason
Account Information	Until account deletion + 90 days	Grace period for account recovery
Ride History	7 years	Tax and legal compliance
GPS Checkpoints	90 days after ride completion	Fraud investigation, billing disputes
Earnings Data	7 years	Tax reporting requirements
Document Photos	Until account deletion + 1 year	Verification and compliance
Crash Logs	30 days	Bug fixing and app improvement
Analytics Data	Indefinitely (anonymized after 90 days)	Service improvement
Support Messages	3 years	Record keeping and quality assurance

After the retention period expires, data is permanently deleted and cannot be recovered.

8. Children's Privacy

The Fleex Driver app is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from children under 18.

To register as a driver, you must:

• Be at least 18 years old
• Hold a valid driver's license
• Provide proof of identity (national ID)

If we discover that we have collected information from someone under 18, we will delete it immediately. If you believe we have collected information from a minor, please contact us at privacy@fleex.mr.

9. International Data Transfers

Your information is primarily stored and processed in:

• Firebase Cloud Firestore: Google Cloud Platform servers (may be located outside Mauritania)
• Firebase Cloud Storage: Google Cloud Storage (may be located outside Mauritania)

Google Cloud complies with:

• GDPR (General Data Protection Regulation)
• Privacy Shield Framework (for EU-US data transfers)
• ISO 27001, SOC 2/3 certifications

When data is transferred outside Mauritania, we ensure that:

• Adequate safeguards are in place (standard contractual clauses)
• The destination country has adequate data protection laws
• You are informed of the transfer and can object

10. Third-Party Links

The App may contain links to third-party websites or services (e.g., Google Maps, social media). We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information.

Third-party services integrated in the app:

• Google Maps: Subject to Google Privacy Policy
• Firebase: Subject to Google Privacy Policy
• Android OS: Subject to device manufacturer's privacy policy

11. California Privacy Rights (CCPA) - If Applicable

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: Categories of data collected and how it's used
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt out of sale of personal information (we do not sell your data)
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

To exercise these rights, contact privacy@fleex.mr.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

We will notify you of material changes by:

• Sending a push notification through the App
• Displaying a prominent notice on the login screen
• Sending an email to your registered email address
• Updating the "Last Updated" date at the top of this policy

Your continued use of the App after the effective date constitutes acceptance of the updated Privacy Policy. If you do not agree with the changes, you must stop using the App and delete your account.

We encourage you to review this Privacy Policy periodically for the latest information on our privacy practices.

14. Data Protection Officer (DPO)

If you have concerns about how we handle your data, you may contact our Data Protection Officer at:

Email: fleexrim@gmail.com
Subject: Data Protection Inquiry

15. Regulatory Compliance

Fleex complies with:

• Mauritanian data protection laws
• GDPR (General Data Protection Regulation)
• Industry best practices for data security

If you believe we are not complying with applicable data protection laws, you have the right to lodge a complaint with your local data protection authority.