We only process information that we need, to enable us to provide you with the best service on our platform. Below are some examples to help you better understand the data we collect:

• Contact details: such as name, phone number, and e-mail address. For some of our services, we might require a little more, like your home address.
• Profile information: such as your picture, addresses, language, and communication preferences. For some of our services, we might require a little more details.
• Geolocation: such as where you are when in need of legal representation, the location of nearby lawyers to you, the time, the journey progression, and the final destination whilst the service is active.
• Payment information like the amount charged and the payment card used.
• Communication and correspondence records such as when you engage with us via our in-app chat; or speak with our customer service agents.
• Limited identification data of the device, like the IP address, on which our app has been installed
• Data about the usage of the services: like data about times and data about your conduct as assessed by the lawyers you engage with and vice versa.

We process your personal data when you visit or use the aptResponse website, mobile applications, APIs, or related services (the “Services”). The data collected may be used for one or more of the following:

We connect you with a Lawyer: We collect and process personal data for the purpose of connecting users with lawyers so you can receive the necessary service sought.

We make sure the app is optimal: We use contact details to notify users and lawyers of updates to our app so you can keep using our services. We also gather limited data from the device that you can use to connect you with our internet, mobile, and telephone services, and to help keep your account safe through authentication and verification checks.

We collect your payment: We obtain payment details to process the user’s payment on behalf of lawyers for services to be provided.

We maintain and promote standards: We collect data about service statuses, times, and lawyer ratings from lawyer feedback to ensure users’ satisfaction, promote compliance with our terms and conditions, and make sure we’re providing good quality and enjoyable service to everyone. Customer support data and correspondence are collected for the purposes of feedback, resolving disputes, and service quality issues.

We keep you informed: Your name, phone number, and email address will be used to communicate with you regarding issues such as letting you know that your requested service has been completed, sending you service confirmation slips and receipts, and letting you know about important service updates such as when we receive a confirmation affecting the provision of the service.

We are allowed to use personal information in the ways described above if we have a proper reason to do so in line with the Nigerian Data Protection Regulation (NDPR) 2019. We make sure that we have reasons for doing anything with your data.

Personal data is generally processed in order to provide the services contracted through our app with you. This means that to give you the service we promised you, and to meet our terms and conditions, we will process your personal data to meet those obligations.

We process your personal data relying on legitimate interest grounds. Legitimate interests include our commercial interests in providing an innovative, personalised, safe, and profitable service to our users; unless those interests are overridden by other interests. Our legitimate interests also include things like investigating and detecting fraudulent payments and other malicious activities, maintaining the security of our network and systems, and responding to suspected or actual criminal acts.

We may from time to time rely on alternative legal bases when:

• it is necessary to comply with a legal obligation such as processing data when the law requires it, including, for example, if there is a valid legal request to disclose personal information to a third party such as a court or regulatory authority;
• we need to protect your vital interests, or those of others, for example in the event of an emergency or an imminent threat to life; or
• when you have given us clear consent to do so for another specific purpose in which you have been fully informed.

If you choose not to give us personal information it may prevent us from fulfilling our contract with you, or stop us from carrying out our obligations as expected of by the law. It may also mean that we cannot operate your account. We will not be able to fulfill our obligations to you in other circumstances, for example, should you refuse to undertake an identity verification check to ensure the integrity of your account, then the account may be suspended or blocked to prevent fraud.

We only work with trusted partners and authorities. We only share your personal information when there is a proper reason to do so. We limit sharing to only that which is required. We do not sell your personal information.

The personal data of the user will only be disclosed to the lawyer when they engage with the app; in such a case, the lawyer will be able to view the name, phone number, and email of the user for the purposes of engaging with the user.

Feedback given by users regarding the quality of the services received is anonymous.

Depending on the circumstances and the service requested by the User, the User’s personal data may be disclosed to affiliates and partners of aptResponse, this will occur under the same strict conditions as established in this privacy policy.

Circumstances where the Information may be shared include:

1. upon receipt of a court order mandating us to; or
2. where we cooperate with a data protection supervisory authority in handling complaints or investigations; or
3. where we are responding to requests, such as those from law enforcement agencies, when we have good-faith that the response is required by law in that jurisdiction or it furthers a public interest task, affects users in that jurisdiction, and is consistent with internationally recognised standards.

In any scenario, we will always satisfy ourselves that we have a legal basis on which to share the information, and we will make sure that we document our decision.

Any personal data collected in the course of providing our services is transferred to and stored in the data centres of Digital Ocean, LLC. and/or Amazon Web Services, Inc. Only authorised employees of the company and partners have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding provisions of the services).

For our research and scientific purposes, all data is anonymously classified to prevent users from being personally identified.

We want you to stay in control of your personal data. We provide you with controls through the app where you can view your personal information including your profile data and service history. We also offer in-app settings like marketing opt-ins, and transparent cookie consent controls on our website.

• You can access your personal data via our app. You have the right to ask us for copies of your personal information. There are some exemptions, such as when we have to balance the rights of others, which means you may not always receive all the information we process.
• You can access and update your personal data via our app. You have the right to ask us to rectify information you think is otherwise inaccurate. You also have the right to ask us to complete information you think is incomplete.
• You have the right to ask us to erase your personal information subject to law.
• You have the right to ask us to restrict the processing of your information subject to law. This means that your data can only be used for certain things, such as legal claims or to exercise legal rights.
• You may have the right to object to processing if we are processing your information on the basis of legitimate interests. You may submit an objection to any automated decision we have made and ask that a person reviews it.
• You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you.

• We retain user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the transportation service it relates to, and the purposes for which we collected the data.
• Your personal data will be stored as long as you have an active user account. If your account is closed, personal data will be deleted (according to our retention schedule and rules), unless such data is still required to meet any legal obligation, or for accounting, dispute resolution, or fraud prevention purposes.
• Financial data regarding the use of services provided to passengers will be stored for three years after the last usage. Data required for other accounting purposes will be stored for seven years after the last journey.
• In the event of a suspected criminal offence, fraudulent activity, or false information having been provided, data will be stored for up to 7 years.
• In case of payment disputes, data will be retained until the claim is satisfied or the expiry date of such claims.
• Service usage data will be stored for three years, after which the data will be anonymized.

Please note that the uninstallation of our app from your device does not mean the erasure of your personal data. If the app has not been used for three years, we’ll get in touch and ask you to confirm whether you wish to keep your account active for future use. If no reply is received within a period of one month (as will also be communicated to you via email), the account will be closed and personal data will be deleted unless such data is required for any purpose mentioned earlier in this privacy notice.

We may send direct marketing messages to your e-mail address and/or phone number when you have given us permission to do so, or on a soft opt-in basis. We may personalise direct marketing messages using information on how you use our services, such as how frequently you use our app and your preferences.

If you no longer wish to receive direct marketing messages, please click the "Unsubscribe" link in the footer of one of our emails, or opt out in the profile section of our app.

We use the help of automated decision-making in case of issuing warnings and implementing service usage suspension. Using automated decision-making is less error-prone, more efficient and safer than using our employees. Data about your usage of the legal services is considered when assessing the need for a warning or suspension. The mobile App suspension will stay in force for 6 months, after which access to the service will be restored.

You will always have the right to human review of the decision and to contest the decision, express your point of view and obtain an explanation by contacting our customer support in our app.

Disputes relating to the processing of personal data are resolved through customer support say-hello@aptresponse.io in the first instance. You have the right to contact our Data Protection Officer privacy@aptresponse.io. Any dispute arising out of or in connection with the interpretation or otherwise of this policy shall be finally resolved by the Nigerian courts.

Our supervisory authority is the National Information Technology Development. Agency.

This policy shall be exclusively construed in accordance with the laws of the Federal Republic of Nigeria.

Further information is available in the Terms and Conditions for Users contained on the website.