1. Introduction

Welcome to SmartOps Fleet ("we," "us," or "our"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal data in compliance with the Protection of Personal Information Act (POPIA) and other relevant South African data protection laws.

By using our website, you consent to the practices described in this Privacy Policy. If you do not agree with the terms outlined herein, please do not use our website.

2. Information We Collect

2.1 Personal Information

We may collect the following categories of personal information:

• Contact Information: Names, email addresses, phone numbers, and postal addresses.
• User Account Information: If you create an account with us, we may collect usernames, passwords, and other account details.
• Payment Information: If you make purchases through our website, we may collect payment card information or other financial information.
• Communication Data: Information provided during correspondence with us, including emails and chat messages.
• Usage Information: Data about your interactions with our website, including IP addresses, browser type, and device identifiers.
• Cookies and Tracking Information: We use cookies and similar tracking technologies to collect information about your browsing behavior on our website.

2.2 Sensitive Personal Information

We do not knowingly collect or process sensitive personal information (e.g., racial or ethnic origin, political opinions, religious beliefs, health data) unless required by law and with your explicit consent.

2.3 Facial Recognition and Identity Verification

To protect the security of your account and prevent unauthorized access to financial and account-sensitive functions, we collect and process your facial image for identity verification.

During your initial identity enrollment, you provide a selfie through our identity verification service provider, Rank One Computing (ROC.ai). Before starting the enrollment process, the ROC.ai enrollment flow presents its Privacy Policy and consent information. You must acknowledge and accept the applicable Privacy Policy before proceeding with enrollment.

ROC.ai processes the enrolled facial image and performs facial verification by comparing subsequent selfies against the facial image originally enrolled for your account. The purpose of this verification is to confirm that the person accessing the account is the enrolled account holder.

Facial verification may be required for security-sensitive functions, including requesting fuel advances, requesting rider advances, accessing driver or investor bank details, driver payouts, investor withdrawals, and profile verification. Verification may be required when the existing verification is unavailable or expired, and certain functions require face verification each time they are accessed. If verification is unsuccessful, the applicable function or transaction will not proceed and the user may retry the verification.

The initial enrolled selfie and associated verification results are stored by SmartOps in backend infrastructure hosted on Microsoft Azure in the South Africa North region. SmartOps retains the enrolled selfie while the user's SmartOps account remains active. When the user's SmartOps account is deleted, the enrolled selfie and its associated database record are deleted from SmartOps's backend.

Subsequent selfies submitted for verification are used for the verification process but are not stored by SmartOps.

ROC.ai is a third-party identity verification service provider. ROC.ai processes facial images and biometric information as part of its identity verification services. ROC.ai's published Online Services Privacy Policy states that facial-recognition information is retained for the period requested by the customer/data controller. ROC.ai's processing and retention of facial information is therefore subject to its applicable privacy terms and the service arrangements between ROC.ai and SmartOps.

SmartOps does not share the enrolled selfie with other third parties for advertising or marketing purposes. The enrolled selfie is used by SmartOps for identity verification, account security, fraud prevention, and authorization of the security-sensitive functions described in this section.

Users may request deletion of their personal information in accordance with this Privacy Policy. When a SmartOps account is deleted, the enrolled selfie and associated database record held by SmartOps are deleted.

3. How We May Use Your Information

We use your personal information for the following purposes:

• Providing Services: To deliver the products and services you request.
• Customer Support: To respond to your inquiries and provide support.
• Marketing: To send you promotional materials, newsletters, and updates with your consent (which you can withdraw at any time).
• Analytics: To improve our website, products, and services through data analysis.
• Compliance: To comply with legal obligations and protect our rights and interests.

4. Sharing Your Information

We may share your personal information with:

• Service Providers: Third-party service providers who help us operate our website and deliver services.
• Legal Compliance: When required by law or to protect our rights, safety, and property.
• Consent: With your consent, we may share your information as described at the time of consent.

5. Your Rights

Under POPIA, you have the following rights regarding your personal information:

• Access: You have the right to request access to the personal information we hold about you.
• Correction: You may request that inaccurate or incomplete personal information be corrected.
• Deletion: You have the right to request the deletion of your personal information, subject to legal requirements.
• Objection: You can object to the processing of your personal information for direct marketing purposes.
• Data Portability: You have the right to receive your personal information in a structured, commonly used format.

To exercise these rights or for any inquiries about your personal data, please contact us using the information provided in Section 8.

6. Security

We employ appropriate security measures to protect your personal information. However, no data transmission over the internet can be guaranteed to be 100% secure. As such, we cannot warrant the security of information you transmit to us.

7. Data Retention

We retain your personal information only for as long as necessary for the purposes stated in this Privacy Policy or as required by law.

8. Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy or your personal information, please contact us: Fleet@SmartOps.solutions

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. Any updates will be posted on this page with the revised effective date.

10. Consent

By using our website, you consent to the terms outlined in this Privacy Policy.