Privacy Policy

1. Introduction

Twagiye ("we," "us," or "our") is Rwanda's first eco-friendly ride-hailing platform, headquartered in Kigali, Rwanda. We connect riders with verified drivers who operate electric and hybrid vehicles, providing cleaner, smarter transportation across the country.

This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you use the Twagiye mobile application, website, and related services (collectively, the "Platform"). It applies to all users of our Platform, including riders, drivers, and visitors to our website.

By accessing or using the Twagiye Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this policy, please do not use our services.

2. Information We Collect

We collect various types of information to provide and improve our services. The information we collect depends on how you interact with our Platform and whether you register as a rider or a driver.

2.1 Personal Information

When you create an account or use our services, we may collect the following personal information:

• Identity Information: Full name, date of birth, national identification number or passport number, and profile photograph.
• Contact Information: Email address, phone number, and residential address.
• Account Credentials: Username, password, and security questions used to access your account.

2.2 Driver-Specific Information

If you apply to become a driver on the Twagiye Platform, we additionally collect:

• Driving License: A valid Rwandan driving license or equivalent recognized license, including license number and expiry date.
• Vehicle Information: Vehicle make, model, year of manufacture, registration number, insurance documentation, vehicle inspection certificates, and proof that the vehicle is electric or hybrid.
• Background Check Information: Criminal background check results and driving history, as permitted by applicable law.
• Banking or Mobile Money Details: Information necessary to process your earnings payouts, including Mobile Money account details or bank account information.

2.3 Payment Information

To process ride payments and other transactions, we collect:

• Mobile Money account details (MTN Mobile Money, Airtel Money).
• Credit or debit card information (Visa, Mastercard), including card number, expiration date, and billing address. Note: full card details are processed and stored by our certified payment processors, not directly by Twagiye.
• In-app wallet balance and transaction history.

2.4 Location Data

With your permission, we collect precise location data from your mobile device. For riders, this includes your pickup location, drop-off location, and route taken during each ride. For drivers, this includes real-time GPS location while you are online and available for rides, as well as during active rides. Location data is essential for matching riders with nearby drivers, calculating fares, providing navigation, and ensuring safety during rides.

2.5 Usage Data

We automatically collect information about how you interact with our Platform, including:

• Ride history, including dates, times, routes, and fares.
• App usage patterns, including features accessed, screens viewed, and time spent on the Platform.
• Ratings and reviews you provide or receive.
• Communication records between riders and drivers through the in-app messaging or calling features.

2.6 Device Information

We collect information about the device you use to access our Platform, including:

• Device type, model, operating system, and version.
• Unique device identifiers and mobile network information.
• IP address, browser type, and language preferences.
• Push notification tokens for delivering ride updates and alerts.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Providing and Operating Our Services

• To create and manage your Twagiye account.
• To match riders with available drivers based on proximity, vehicle type, and other relevant factors.
• To facilitate ride bookings, provide real-time tracking, and deliver navigation assistance to drivers.
• To calculate and process ride fares and payments.
• To maintain your ride history and transaction records.

3.2 Payment Processing

• To process ride payments through Mobile Money (MTN, Airtel), Visa, Mastercard, or your in-app wallet.
• To manage driver earnings, calculate service fees, and facilitate weekly payouts.
• To detect and prevent payment fraud.

3.3 Driver Verification

• To verify driver identities, driving licenses, and vehicle documentation.
• To conduct background checks in compliance with applicable Rwandan law.
• To confirm that vehicles meet our electric/hybrid and safety requirements.

3.4 Platform Improvement

• To analyze usage patterns and improve the functionality, performance, and user experience of our Platform.
• To develop new features, products, and services.
• To conduct research and analytics on ride patterns, demand forecasting, and environmental impact measurement (including CO2 emissions saved).

3.5 Communication

• To send you ride confirmations, receipts, and status updates.
• To notify you of changes to our services, policies, or terms.
• To send promotional communications about Twagiye features, offers, and events (you may opt out at any time).
• To respond to your inquiries, feedback, and support requests.

3.6 Safety and Security

• To verify user identities and prevent unauthorized access to accounts.
• To monitor rides in real time for safety purposes, including route deviation detection and emergency response.
• To investigate and resolve disputes, accidents, or incidents reported by riders or drivers.
• To enforce our Terms of Service and community guidelines.

3.7 Legal Compliance

• To comply with applicable laws, regulations, and legal processes in Rwanda, including the Law Relating to the Protection of Personal Data and Privacy (Law No. 058/2021 of 13/10/2021).
• To respond to lawful requests from government authorities, regulators, and law enforcement agencies.
• To establish, exercise, or defend legal claims.

4. Information Sharing

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your information only in the following circumstances:

4.1 Between Riders and Drivers

When a ride is booked, we share limited information between the rider and the assigned driver to facilitate the ride. This includes the rider's first name, pickup and drop-off locations, and the driver's first name, profile photo, vehicle details, license plate number, and real-time location. After a ride is completed, both parties can rate and review each other.

4.2 Payment Processors

We share necessary payment information with our trusted third-party payment processors, including MTN Mobile Money, Airtel Money, and card payment networks (Visa, Mastercard), to process transactions securely. These processors handle your payment data in accordance with their own privacy policies and applicable payment card industry standards.

4.3 Service Providers

We may share information with trusted third-party service providers who assist us in operating our Platform, including cloud hosting providers, mapping and navigation services, analytics providers, customer support tools, and background check agencies. These providers are contractually obligated to protect your information and use it only for the purposes we specify.

4.4 Law Enforcement and Legal Requirements

We may disclose your information when required to do so by law, or when we believe in good faith that disclosure is necessary to comply with a legal obligation, respond to a court order or subpoena, cooperate with law enforcement investigations, protect the safety of our users or the public, or protect the rights and property of Twagiye.

4.5 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity. We will notify you of any such change and any choices you may have regarding your information.

5. Data Storage and Security

5.1 Data Storage

Your personal data is stored on secure servers located in Rwanda where possible, and in other jurisdictions where our cloud service providers maintain data centers. Where data is transferred outside of Rwanda, we ensure that appropriate safeguards are in place in accordance with Rwanda's data protection laws.

5.2 Security Measures

We implement industry-standard technical and organizational measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols and encryption of sensitive data at rest.
• Strict access controls ensuring that only authorized personnel can access personal data, on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Secure payment processing through PCI-DSS compliant payment providers.
• Multi-factor authentication options for user accounts.

While we strive to protect your information, no method of electronic storage or transmission over the internet is completely secure. We cannot guarantee absolute security, but we are committed to taking all reasonable steps to safeguard your data.

6. Your Rights

Under Rwanda's Law Relating to the Protection of Personal Data and Privacy (Law No. 058/2021), and other applicable regulations, you have the following rights regarding your personal information:

• Right of Access: You have the right to request a copy of the personal data we hold about you. You can access much of this information directly through your account settings in the Twagiye app.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most of your information through the app, or contact us for assistance.
• Right to Erasure: You have the right to request deletion of your personal data, subject to certain legal exceptions (for example, we may need to retain certain data for legal, regulatory, or safety reasons).
• Right to Data Portability: You have the right to request a copy of your personal data in a structured, commonly used, machine-readable format, and to have that data transmitted to another service provider where technically feasible.
• Right to Object: You have the right to object to certain processing of your personal data, including processing for direct marketing purposes.
• Right to Withdraw Consent: Where we rely on your consent to process your data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at info@twagiye.rw. We will respond to your request within 30 days. If you believe your data protection rights have been violated, you have the right to lodge a complaint with the relevant data protection authority in Rwanda.

7. Location Data

Location data is a critical component of our ride-hailing service. Here is how we handle it:

• When We Collect It: For riders, precise location data is collected when you open the app to book a ride and during an active ride. For drivers, location data is collected while you are logged in and available to accept rides, and during active rides.
• How We Use It: Location data is used to match you with the nearest available driver, calculate accurate fares based on distance and route, provide real-time ride tracking for safety, offer navigation assistance to drivers, and generate estimated arrival times.
• Background Location: Drivers may be asked to allow background location access so that ride requests can be received while the app is not in the foreground. This is optional and can be adjusted in your device settings.
• Opting Out: You can disable location services through your device settings at any time. However, please note that disabling location services will prevent you from booking or completing rides through the Platform.

8. Cookies and Tracking Technologies

Our website and Platform may use cookies and similar tracking technologies to enhance your experience. These include:

• Essential Cookies: These are strictly necessary for the operation of our website and Platform. They enable core functionality such as account authentication, session management, and security features. These cookies cannot be disabled.
• Analytics Cookies: We use analytics tools to understand how visitors interact with our website. This helps us improve our services, identify popular features, and optimize the user experience. Analytics data is aggregated and does not personally identify you.
• Functional Cookies: These cookies remember your preferences, such as language settings and display options, to provide a more personalized experience.

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

9. Children's Privacy

The Twagiye Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18 years of age. If you are under 18, you may not create a Twagiye account or use our services.

If we become aware that we have inadvertently collected personal data from a child under 18, we will take immediate steps to delete that information from our systems. If you are a parent or guardian and believe that your child has provided personal information to Twagiye, please contact us at info@twagiye.rw so that we can take appropriate action.

10. Third-Party Services

Our Platform integrates with and relies on certain third-party services to deliver our ride-hailing experience. These include:

• Payment Processors: MTN Mobile Money, Airtel Money, and card payment networks (Visa, Mastercard) process your transactions. These providers have their own privacy policies governing their handling of your payment data.
• Mapping and Navigation Services: We use third-party mapping providers to display maps, calculate routes, provide navigation to drivers, and estimate arrival times. These services may receive your location data to function properly.
• Cloud Infrastructure: We use third-party cloud hosting services to store and process data securely.
• Communication Services: We may use third-party services to facilitate SMS notifications, push notifications, and email communications.

We encourage you to review the privacy policies of these third-party services. Twagiye is not responsible for the privacy practices of third-party providers, though we select partners who demonstrate commitment to data protection.

11. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. Specific retention periods include:

• Active Accounts: Your personal data is retained for as long as your account remains active and you continue to use the Platform.
• After Account Deletion: Upon account deletion, we will delete or anonymize your personal data within 90 days, except where retention is required by law or necessary to resolve disputes, enforce our agreements, or protect our legal interests.
• Ride and Transaction Records: Ride history and financial transaction records are retained for a minimum of 5 years to comply with Rwandan tax and financial regulations.
• Safety and Incident Records: Records related to safety incidents, disputes, or violations may be retained for up to 7 years or longer if required for ongoing legal proceedings.
• Aggregated and Anonymized Data: We may retain aggregated or anonymized data that cannot identify you indefinitely for research, analytics, and environmental impact reporting purposes.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, legal requirements, or for other operational reasons. When we make material changes, we will:

• Post the updated Privacy Policy on our website and within the Twagiye app.
• Update the "Last Updated" date at the top of this page.
• Notify you through the app, via email, or by other appropriate means for significant changes.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of the Platform after changes are posted constitutes your acceptance of the revised policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We aim to respond to all privacy-related inquiries within 30 days of receipt.