Privacy Policy
Effective Date: 01 January, 2026
1. WHO WE ARE
Drive and Earn App is a technology platform developed and operated by Vision 2020 Group.
The Platform connects vehicle owners, drivers, fleet operators and other vehicle partners with advertising opportunities and Campaigns.
Depending on the circumstances, Drive and Earn may process personal information as a controller, business, processor, service provider, joint controller or in another legally recognised capacity. The applicable role will depend on the specific processing activity, relationship and applicable law.
1.1 Controller and Processor Roles
In general, Drive and Earn acts as the controller (or "business," under US state law terminology) in respect of personal information it collects directly from Vehicle Partners, Drivers and other Users to operate accounts, verify eligibility, administer Campaigns and process payments. Where an Advertiser supplies Campaign creative, targeting instructions or its own customer data for use in a Campaign, the Advertiser is generally the controller of that data and Drive and Earn acts as a processor or service provider acting on the Advertiser’s instructions for that specific data, unless otherwise stated in the applicable Campaign Opt-In Agreement or advertiser contract.
1.2 Data Protection Officer / Privacy Lead
Where applicable law requires the appointment of a Data Protection Officer or equivalent privacy lead (including under the EU GDPR, UK GDPR, or the Nigeria Data Protection Act 2023), Drive and Earn will appoint one and publish their contact details through the official Drive and Earn website. Until such an appointment is required or made, privacy enquiries should be directed to the contact channels in Section 70.
1.3 EU and UK Representative
Where Drive and Earn processes personal information of individuals located in the European Economic Area or the United Kingdom and is required under Article 27 of the EU GDPR or the UK GDPR to appoint a local representative, Drive and Earn will appoint an appropriate representative in the EEA and/or UK and publish their contact details through the official Drive and Earn website once the Platform’s activity in those regions reaches a level that triggers this requirement.
2. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to personal information collected or processed through:
• the Drive and Earn website
• mobile applications
• driver and vehicle registration systems
• vehicle partner portals
• advertiser and Campaign systems
• Campaign management systems
• payment systems
• customer support systems
• communications and marketing activities
• vehicle verification systems
• location and route systems
• advertising measurement systems
• analytics systems
• fraud prevention systems
• cookies and similar technologies
• social media or third-party platforms where we interact with you
• events, demonstrations and business communications
• other services, products, technologies or systems operated by or on behalf of Drive and Earn
This Privacy Policy also applies to information obtained from third parties where that information is used in connection with our services.
3. INFORMATION WE COLLECT
Depending on how you interact with Drive and Earn, we may collect different categories of personal information. This may include the following.
3.1 Identity Information
We may collect:
• full name
• date of birth
• age
• gender where required or voluntarily provided
• nationality where required
• profile photograph
• identification information
• identity verification information
• government-issued identification information
• driver licence information
• account identifiers
• verification records
• other information required to verify your identity or eligibility
4. CONTACT INFORMATION
We may collect:
• email address
• telephone number
• mobile number
• residential or mailing address
• business address
• emergency contact information where applicable
• communication preferences
• other contact information you voluntarily provide
5. VEHICLE INFORMATION
If you register or operate a vehicle through Drive and Earn, we may collect:
• vehicle make
• vehicle model
• vehicle year
• vehicle type
• vehicle category
• vehicle registration information
• licence plate information
• vehicle identification information
• vehicle ownership information
• vehicle photographs
• vehicle condition information
• vehicle colour
• vehicle size
• vehicle advertising surface area
• advertising coverage information
• wrap configuration
• vehicle documents
• insurance-related information
• inspection information
• maintenance or verification information where relevant
• fleet information
• other information required to determine whether a vehicle is suitable for a Campaign
6. DRIVER AND VEHICLE PARTNER INFORMATION
Where you participate as a driver, vehicle owner, fleet operator or vehicle partner, we may collect:
• driving information
• vehicle usage information
• registration information
• campaign participation information
• Campaign acceptance information
• Campaign completion information
• Campaign performance information
• route information
• driving activity
• mileage information
• location information
• vehicle availability
• Campaign preferences
• payment information
• banking information
• tax information where required
• communications with Drive and Earn
• support requests
• verification information
• information relating to compliance with Campaign requirements
7. LOCATION AND ROUTE INFORMATION
Location information may be an important part of the Drive and Earn service.
Depending on the service, device permissions and Campaign requirements, we may collect or process:
• GPS location
• approximate location
• precise location
• route information
• route history
• travel patterns
• vehicle movement
• driving distance
• timestamps
• location of Campaign activity
• geographic areas visited
• geofencing information
• route density
• traffic-related information
• location-based Campaign information
• information used to calculate or estimate advertising exposure
Location information may be collected directly from a device, vehicle system, application, integration, service provider or other authorised source. Where operationally sufficient, Drive and Earn collects location at intervals (rather than continuously) to reduce data collected, conserve device battery and lower processing costs, consistent with the data minimisation principle described in Section 62.
8. DEVICE AND TECHNICAL INFORMATION
When you use our website, application or technology, we may automatically collect certain technical information, including:
• IP address
• device type
• device model
• operating system
• browser type
• browser version
• application version
• device identifiers
• advertising identifiers where available and permitted
• mobile network information
• language
• time zone
• connection information
• crash information
• diagnostic information
• log information
• access dates and times
• pages or screens accessed
• application features used
• other technical information
9. APP USAGE AND BEHAVIOURAL INFORMATION
We may collect information about how you interact with Drive and Earn, including:
• pages viewed
• screens viewed
• buttons selected
• features used
• Campaigns viewed
• Campaigns accepted
• Campaign participation
• registration activity
• account activity
• communications
• preferences
• searches
• interactions with notifications
• support activity
• session information
• other usage information
We may use this information to improve the Platform, understand user behaviour, improve Campaign matching, prevent fraud and develop new services.
10. PAYMENT AND FINANCIAL INFORMATION
Where payments are made through or in connection with Drive and Earn, we may process:
• bank account information
• account holder name
• payment account information
• transaction information
• payment history
• payment status
• tax information
• invoices
• payment verification information
• payment-related correspondence
• information required to comply with financial, tax, anti-fraud or other legal obligations
Payment information may be processed by third-party payment providers and financial service providers. We do not necessarily store complete payment credentials where a third-party payment provider is responsible for securely processing them.
11. CAMPAIGN INFORMATION
We may collect and process information relating to advertising Campaigns, including:
• Campaign identification
• Campaign participation
• Campaign acceptance
• Campaign start and end dates
• Campaign requirements
• vehicle assignment
• route requirements
• geographic requirements
• advertising coverage
• wrap configuration
• Campaign activity
• Campaign performance
• estimated impressions
• reach
• frequency
• dwell time
• route density
• location data
• verification information
• Campaign photographs
• Campaign results
• advertiser information
• other information required to operate, measure or verify a Campaign
12. PHOTOGRAPHS, VIDEOS AND VISUAL CONTENT
We may collect photographs, videos and other visual material relating to:
• users
• vehicles
• vehicle advertising
• advertising installations
• Campaigns
• Campaign locations
• Campaign results
• vehicle condition
• verification
• advertising displays
• promotional activities
Visual content may be provided by you, collected by Drive and Earn, collected by approved Campaign partners, or generated through Campaign verification processes.
Where legally permitted, such content may also be used for operational, verification, marketing, promotional, advertising, investor, public relations, sales, case study and business development purposes in accordance with our Terms and applicable law.
13. COMMUNICATIONS
We may retain information from communications with you, including:
• emails
• messages
• telephone communications
• support requests
• chat communications
• enquiries
• complaints
• feedback
• surveys
• correspondence
• communications concerning Campaigns or payments
Where legally permitted, communications may be recorded or monitored for quality assurance, training, security, dispute resolution, fraud prevention or compliance purposes.
14. INFORMATION FROM THIRD PARTIES
We may receive personal information from third parties, including:
• advertisers
• Campaign partners
• fleet operators
• vehicle owners
• wrap installation partners
• verification providers
• payment providers
• identity verification providers
• fraud prevention providers
• analytics providers
• location and mapping providers
• advertising technology providers
• marketing providers
• publicly available sources
• social media platforms
• business partners
• service providers
• government or regulatory authorities
• other legally permitted sources
Where required by applicable law, we will provide appropriate notices regarding information obtained from third parties.
15. WHY WE COLLECT PERSONAL INFORMATION
We may process personal information for purposes including:
• creating and managing accounts
• verifying identity
• verifying vehicle ownership or authority to use a vehicle
• verifying eligibility
• registering vehicles
• matching vehicles with Campaigns
• administering Campaign participation
• managing advertising Campaigns
• monitoring Campaign requirements
• verifying Campaign completion
• calculating Campaign payments
• processing payments
• preventing fraud
• detecting manipulation
• protecting Platform integrity
• providing customer support
• communicating with users
• improving services
• developing new products
• providing analytics
• measuring advertising performance
• generating Campaign reports
• developing location intelligence
• improving route and Campaign matching
• conducting research
• performing business analytics
• maintaining records
• complying with legal obligations
• protecting rights and property
• enforcing agreements
• resolving disputes
• responding to legal requests
• conducting security operations
• conducting audits
• supporting business transactions
• other purposes permitted by applicable law
16. CAMPAIGN MATCHING AND LOCATION INTELLIGENCE
Drive and Earn may use information about vehicles, drivers, routes, geographic areas and Campaign requirements to determine whether a vehicle may be suitable for a Campaign.
This may include analysing:
• vehicle category
• vehicle advertising coverage
• location
• routes
• driving activity
• geographic Campaign requirements
• Campaign duration
• vehicle availability
• historical Campaign participation
• vehicle characteristics
• estimated advertising exposure
• other Campaign-related factors
This processing may be automated, manual or a combination of both.
17. ADVERTISING MEASUREMENT
Drive and Earn may process information to estimate, calculate, verify or report advertising performance.
Depending on the Campaign, this may include:
• estimated impressions
• reach
• frequency
• dwell time
• vehicle movement
• geographic exposure
• route density
• Campaign duration
• vehicle activity
• location-based exposure
• traffic-related information
• Campaign verification data
• other advertising performance indicators
Certain metrics may be estimates rather than direct measurements. Drive and Earn may use different technologies and methodologies to measure Campaign performance.
18. FRAUD PREVENTION AND SECURITY
Drive and Earn may process information to detect, investigate and prevent:
• GPS spoofing
• fake routes
• false mileage
• false location information
• fraudulent photographs
• manipulated Campaign data
• manipulated impressions
• manipulated reach
• manipulated dwell time
• manipulated frequency
• account abuse
• identity fraud
• payment fraud
• duplicate accounts
• false vehicle information
• unauthorised Campaign participation
• unauthorised access
• circumvention of verification systems
• misuse of the Platform
• fraudulent Campaign completion
• attempts to obtain payments without completing Campaign requirements
• other fraudulent, deceptive, abusive or unlawful conduct
Drive and Earn may use any verification technology it determines appropriate and legally permitted for these purposes.
19. LEGAL BASES FOR PROCESSING
Where applicable law requires us to identify a legal basis for processing personal information, we may rely on one or more legally recognised bases, including:
• performance of a contract
• steps taken at your request before entering into a contract
• compliance with a legal or regulatory obligation
• legitimate interests
• consent
• protection of vital interests
• performance of a task carried out in the public interest where applicable
• establishment, exercise or defence of legal claims
• other lawful bases recognised under applicable law
The legal basis applicable to a particular processing activity may depend on the jurisdiction, the nature of the information, the relationship between the parties and the purpose of processing.
Where consent is the applicable legal basis, you may generally withdraw consent where permitted by law. Withdrawal of consent will not necessarily affect processing carried out before withdrawal.
20. LEGITIMATE INTERESTS
Where permitted by applicable law, Drive and Earn may process personal information based on legitimate interests.
These interests may include:
• operating and improving the Platform
• preventing fraud
• protecting users
• maintaining Platform security
• improving Campaign matching
• measuring advertising performance
• developing technology
• conducting business analytics
• communicating with customers and partners
• promoting our services
• protecting our business
• enforcing agreements
• managing legal claims
• supporting legitimate commercial activities
Where required by applicable law, we will consider the relevant rights and interests of individuals when relying on legitimate interests.
21. CONSENT
Where we rely on consent, we will seek consent in the manner required by applicable law.
You may withdraw consent where legally permitted.
Certain services may not function correctly if consent is withdrawn where the relevant processing is necessary for that service.
22. COOKIES AND SIMILAR TECHNOLOGIES
Drive and Earn may use cookies, SDKs, pixels, tags, local storage and similar technologies.
These technologies may be used for:
• essential Platform functionality
• authentication
• security
• preferences
• analytics
• performance monitoring
• advertising
• Campaign measurement
• personalisation
• fraud prevention
• marketing
Where applicable law requires consent for certain cookies or similar technologies, we will seek the required consent.
You may be able to control certain cookie preferences through your browser, device settings or our consent-management tools. Disabling certain technologies may affect Platform functionality.
23. MARKETING COMMUNICATIONS
We may send communications concerning:
• Campaigns
• account activity
• services
• product updates
• offers
• promotions
• events
• business opportunities
• surveys
• research
• other relevant information
Where required by applicable law, we will obtain the necessary consent before sending certain marketing communications.
You may unsubscribe from marketing communications by using the available unsubscribe mechanism or by contacting us.
You may continue to receive essential service, transactional, security or administrative communications even after opting out of marketing.
24. HOW WE SHARE PERSONAL INFORMATION
We may disclose personal information where permitted or required by applicable law.
Recipients may include:
• advertisers
• Campaign partners
• vehicle owners
• drivers
• fleet operators
• wrap installation partners
• payment providers
• banks and financial institutions
• identity verification providers
• fraud prevention providers
• analytics providers
• advertising technology providers
• location and mapping providers
• hosting providers
• cloud service providers
• communications providers
• customer support providers
• technology providers
• professional advisers
• accountants
• auditors
• insurers
• legal advisers
• regulators
• government authorities
• law enforcement authorities
• courts and tribunals
• prospective buyers or investors
• companies involved in a merger, acquisition, restructuring or financing
• other third parties where permitted by law
We seek to limit disclosure to information relevant to the applicable purpose, subject to legal and operational requirements.
25. ADVERTISERS AND CAMPAIGN PARTNERS
Depending on the Campaign, Drive and Earn may share certain information with advertisers or Campaign partners.
This may include:
• Campaign participation
• vehicle information
• vehicle category
• advertising coverage
• geographic information
• Campaign performance information
• photographs
• verification information
• estimated reach
• impressions
• dwell time
• frequency
• route-related information
• other Campaign information
We may limit or aggregate information where appropriate. We will not disclose information in a manner prohibited by applicable privacy law.
26. WRAP INSTALLATION AND CAMPAIGN SERVICE PARTNERS
Drive and Earn may work with independent third-party specialists for vehicle advertising installation, removal, inspection, verification and related services.
Information may be shared with those parties where necessary to arrange:
• installation
• removal
• inspection
• scheduling
• Campaign verification
• vehicle identification
• Campaign administration
• related services
Third parties receiving information are expected to process it only for legitimate and authorised purposes and in accordance with applicable legal requirements.
27. PAYMENT PROVIDERS
Payments may be processed through third-party payment providers, banks or other financial service providers.
Those providers may independently process information under their own privacy notices and legal obligations.
Drive and Earn may provide payment information necessary to:
• verify payment eligibility
• process payments
• prevent payment fraud
• comply with financial requirements
• maintain transaction records
• resolve payment issues
28. SERVICE PROVIDERS AND PROCESSORS
Drive and Earn may engage third-party service providers to operate parts of the Platform.
These may include providers of:
• cloud infrastructure
• hosting
• software
• analytics
• mapping
• GPS
• communications
• customer support
• cybersecurity
• identity verification
• fraud detection
• payment processing
• marketing
• advertising technology
• data storage
• technical support
• other business services
Where required by applicable law, appropriate contractual, technical and organisational safeguards will be used, including data processing agreements incorporating the obligations required under the EU/UK GDPR, the Nigeria Data Protection Act 2023, and equivalent local law.
29. BUSINESS TRANSFERS
If Drive and Earn or any part of its business is involved in a merger, acquisition, sale, financing, restructuring, reorganisation, joint venture, investment, transfer of assets or similar corporate transaction, personal information may be transferred as part of that transaction, subject to applicable law.
30. LEGAL AND REGULATORY DISCLOSURES
Drive and Earn may disclose personal information where required or permitted by law.
This may include responding to:
• court orders
• legal processes
• regulatory requests
• government requests
• law enforcement requests
• investigations
• audits
• legal claims
• fraud investigations
• security incidents
• other lawful requests
We may also disclose information where necessary to protect users, employees, partners, property, the Platform, our legal rights, or the rights of others.
31. INTERNATIONAL DATA TRANSFERS
Drive and Earn operates as a global platform and may process personal information in jurisdictions other than the jurisdiction in which the information was originally collected.
Personal information may therefore be transferred to, stored in, accessed from or processed in other countries or regions, including Nigeria, the United Arab Emirates, the United Kingdom, the United States, Canada, Australia, Saudi Arabia, Qatar, Singapore, New Zealand and other countries in which Drive and Earn operates or engages service providers.
Where applicable law restricts international transfers, Drive and Earn will use an applicable legally recognised mechanism or safeguard, which may include:
• an adequacy decision or equivalent mechanism
• approved contractual safeguards, such as the European Commission’s Standard Contractual Clauses (SCCs) or the UK International Data Transfer Agreement (IDTA)
• standard contractual clauses or equivalent mechanisms recognised under non-EU/UK frameworks
• binding corporate arrangements where applicable
• approved certification mechanisms
• approved codes or contractual protections
• recognised transfer safeguards under the Nigeria Data Protection Act 2023 or the UAE Personal Data Protection Law
• applicable statutory exceptions
• another mechanism permitted by applicable law
Where required, Drive and Earn may conduct transfer impact assessments or other legally required assessments before or in connection with certain transfers. International transfer requirements may vary depending on the jurisdiction, the parties involved, the type of information and the processing activity.
32. DATA SECURITY
Drive and Earn uses technical, organisational and administrative measures designed to protect personal information against unauthorised access, unauthorised disclosure, loss, misuse, alteration, destruction, accidental disclosure, fraud, and other unlawful or unauthorised processing.
Security measures may include:
• access controls
• authentication
• encryption where appropriate
• system monitoring
• logging
• security testing
• backups
• fraud detection
• employee or contractor controls
• service-provider controls
• other security measures appropriate to the nature of the information and processing
No online system can be guaranteed to be completely secure.
33. DATA BREACHES AND SECURITY INCIDENTS
If Drive and Earn becomes aware of a personal information breach or security incident, we may investigate, contain and remediate the incident.
Where applicable law requires notification to individuals, regulators, authorities or other parties, Drive and Earn will provide the required notifications within the applicable legal requirements — for example, without undue delay and, where feasible, within 72 hours of becoming aware of a qualifying breach under the EU/UK GDPR, within the timeframe required by the Nigeria Data Protection Commission (NDPC) under the Nigeria Data Protection Act 2023, or within the timeframe required by any other applicable supervisory authority listed in Section 60.
34. DATA RETENTION
Drive and Earn retains personal information for as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
Retention periods may depend on the type of information, the purpose for which it was collected, whether an account remains active, Campaign requirements, payment requirements, tax obligations, accounting requirements, fraud prevention requirements, legal claims, dispute resolution, regulatory requirements, security requirements, and other legitimate business needs.
As a general guide, and subject to longer retention where legally required or where a dispute, investigation or legal claim is ongoing, Drive and Earn generally applies the following indicative retention periods:
• Account and identity verification information: for the duration of the account, plus a limited period after closure to address disputes, fraud investigations and legal requirements
• Vehicle and Campaign participation records: for the duration of the relevant Campaign and a limited period afterward for verification, reporting and dispute purposes
• Location and route data collected for Campaign verification: for a limited period following the relevant Campaign sufficient to verify and finalise Campaign payment and address any dispute, after which it is deleted or anonymised unless needed for an active fraud investigation or legal claim
• Payment, invoicing and tax-related records: for the period required by applicable tax and financial record-keeping law in the relevant country (commonly several years after the relevant transaction)
• Fraud, security and verification logs: for as long as reasonably necessary to protect the Platform and its Users against repeated abuse, subject to applicable law
• Marketing preference and consent records: until consent is withdrawn or the applicable marketing purpose ends, plus a limited period to evidence compliance
When information is no longer required, we may delete, anonymise, de-identify or otherwise securely dispose of it in accordance with applicable law.
35. ANONYMISED AND AGGREGATED INFORMATION
Where permitted by law, Drive and Earn may create aggregated, anonymised or de-identified information from personal information.
Such information may be used for:
• analytics
• benchmarking
• advertising measurement
• location intelligence
• traffic analysis
• Campaign analysis
• product development
• artificial intelligence and machine learning
• business intelligence
• investor presentations
• research
• reporting
• marketing
• commercial analysis
• other legitimate purposes
Where information is treated as anonymised or de-identified under applicable law, we may use it for purposes permitted by that law.
36. ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING
Drive and Earn may use automated systems, algorithms, artificial intelligence and machine learning technologies for purposes including:
• Campaign matching
• route analysis
• advertising measurement
• fraud detection
• identity verification
• security
• customer support
• analytics
• prediction
• optimisation
• location intelligence
• service improvement
• product development
Automated processing may involve analysing multiple data points to determine eligibility, identify potential fraud, recommend Campaigns, assess Campaign activity or improve Platform performance.
Where applicable law provides rights relating to automated decision-making or profiling — including the right under the EU/UK GDPR not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects, and the right to request human review — those rights will apply.
37. PROFILING
Where permitted by applicable law, Drive and Earn may use personal information to create or analyse profiles for legitimate business and operational purposes.
This may include:
• vehicle profiles
• Campaign suitability profiles
• route profiles
• geographic profiles
• fraud risk indicators
• advertising exposure profiles
• user preferences
• operational profiles
Profiling will be conducted in accordance with applicable law.
38. PRECISE LOCATION AND SENSITIVE INFORMATION
Certain information processed by Drive and Earn may receive special protection under applicable law.
This may include:
• precise location
• government identification information
• biometric information where used
• financial information
• health-related information if incidentally provided or legally required
• information relating to criminal allegations or fraud investigations
• other information legally classified as sensitive or specially protected, including “sensitive personal data” under the EU/UK GDPR, “sensitive personal information” under the California CCPA/CPRA, and equivalent categories under the Nigeria Data Protection Act 2023 and the UAE Personal Data Protection Law
Drive and Earn will process such information only where there is a lawful basis and where applicable legal requirements are satisfied. We do not intentionally collect sensitive information unrelated to the operation of the Platform.
39. DRIVER AND VEHICLE ELIGIBILITY
Drive and Earn may process personal information to determine whether a person or vehicle is eligible to participate in the Platform or a Campaign.
This may include verifying:
• minimum age
• identity
• vehicle ownership or legal authority
• vehicle documentation
• driver documentation
• Campaign requirements
• insurance-related information
• vehicle condition
• vehicle type
• advertising suitability
• other eligibility requirements
40. CHILDREN AND MINORS
Drive and Earn’s driver, vehicle partner and Campaign participation services are intended for individuals who meet the applicable minimum age requirements.
For participation as a driver or vehicle partner, the minimum age is generally 18 years, unless applicable law requires a higher age.
We do not knowingly seek to collect personal information from children for driver or vehicle partner participation, and the Platform is not directed at children.
If we become aware that we have inadvertently collected personal information from a child below the applicable minimum age without the consent required by law, we will take reasonable steps to delete that information promptly, unless retention is required by applicable law.
If you believe a child has provided personal information to us improperly, please contact us through the Drive and Earn website.
41. YOUR PRIVACY RIGHTS
Depending on applicable law, you may have rights concerning your personal information.
These may include the right to:
• access personal information
• obtain information about how personal information is processed
• correct inaccurate information
• update information
• request deletion
• request erasure
• restrict processing
• object to processing
• withdraw consent
• request data portability
• object to direct marketing
• opt out of certain targeted advertising
• opt out of certain forms of sale or sharing where legally defined
• limit certain uses of sensitive information where applicable
• request human review of certain automated decisions where legally required
• challenge or appeal certain decisions where applicable
• request information about international transfers
• lodge a complaint with a relevant supervisory authority
• exercise other rights granted by applicable law
These rights are not absolute and may be subject to legal exceptions, limitations and verification requirements.
41.1 Do We Sell or Share Personal Information
Drive and Earn does not sell personal information to third parties in exchange for money. However, in the ordinary operation of the Platform, Drive and Earn shares certain information — such as Campaign performance, aggregated location and reach data, and device or advertising identifiers — with advertising technology providers, analytics providers and Advertisers as described in Sections 24 and 25. Under some laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), this kind of sharing for cross-context behavioural advertising purposes may be legally treated as a "sale" or "share" of personal information, even though no money changes hands. Where this applies to you, you have the right to opt out of that sale or sharing. You may exercise this right through the privacy request channels described in Section 43, or, where we make one available, through an in-app or website "Do Not Sell or Share My Personal Information" control. We do not knowingly sell or share the personal information of individuals we know to be under 16 years of age.
42. JURISDICTION-SPECIFIC RIGHTS
Privacy rights differ between jurisdictions.
Where a particular jurisdiction provides additional rights, Drive and Earn will provide those rights to individuals to the extent required by applicable law.
These may include rights relating to:
• sensitive information
• precise geolocation
• targeted advertising
• profiling
• automated decision-making
• data sales or sharing
• cross-context behavioural advertising
• international transfers
• objection
• restriction
• portability
• deletion
• correction
• appeal
• consent
• marketing communications
• other legally protected interests
Nothing in this Privacy Policy is intended to remove or restrict a privacy right that cannot legally be excluded.
43. HOW TO EXERCISE YOUR PRIVACY RIGHTS
You may submit a privacy request through the contact methods made available on the official Drive and Earn website.
Requests should provide enough information for us to identify the requester, the relevant account or relationship, the nature of the request, and any other information necessary to process the request.
We may request additional information to verify your identity where permitted or required by law.
44. IDENTITY VERIFICATION FOR PRIVACY REQUESTS
To protect personal information, Drive and Earn may take steps to verify the identity of a person making a privacy request.
The verification process may depend on the type of request, the sensitivity of the information, the account involved, applicable legal requirements, and the risk of unauthorised disclosure.
We will not request information for verification that is unnecessary for the applicable request where applicable law prohibits such collection.
45. RESPONSE TO PRIVACY REQUESTS
Drive and Earn will respond to valid privacy requests within the timeframe required by applicable law — for example, generally within one month under the EU/UK GDPR (extendable by a further two months for complex requests), or within 45 days under the CCPA/CPRA (extendable by a further 45 days where necessary), or within the timeframe specified under the Nigeria Data Protection Act 2023 or other applicable law.
Where legally permitted, we may extend a response period where a request is complex, repetitive or otherwise subject to an applicable extension, and will notify you of any such extension where required.
If we refuse a request, we may provide an explanation where required by law and information about any applicable appeal or complaint rights.
46. MARKETING OPT-OUT RIGHTS
You may opt out of promotional communications.
You may generally do this by selecting an unsubscribe option, changing your communication preferences, using available account settings, or contacting us.
Opting out of marketing does not necessarily stop operational or legally required communications.
47. THIRD-PARTY WEBSITES AND SERVICES
The Drive and Earn Platform may contain links, integrations or references to third-party websites, applications or services.
Third-party services may have their own privacy policies and practices.
Drive and Earn is not responsible for the privacy practices of third-party services that operate independently of Drive and Earn.
You should review the privacy policies of third-party services before providing personal information to them.
48. SOCIAL MEDIA
Drive and Earn may maintain social media accounts, pages or profiles.
If you interact with us through social media, the relevant social media provider may independently process information about you.
Your use of those services is governed by the applicable provider’s terms and privacy policies.
49. USER-GENERATED CONTENT
You may provide content to Drive and Earn, including photographs, videos, comments, reviews, testimonials, feedback, Campaign content, vehicle information, messages, and other materials.
You are responsible for ensuring that information or content you provide does not unlawfully disclose another person’s personal information.
By submitting content, you confirm that you have the rights and permissions necessary for Drive and Earn to process the content for the purposes for which it was submitted.
50. CAMPAIGN CONTENT AND PROMOTIONAL USE
Where permitted by applicable law and our Terms and Conditions, Drive and Earn may use Campaign-related content for advertising, marketing, case studies, Campaign portfolios, investor presentations, sales presentations, public relations, social media, website content, promotional materials, business development, media communications, demonstrations, and other legitimate commercial purposes.
This may include vehicle photographs, Campaign photographs, Campaign results, screenshots, testimonials and related materials.
Where consent is legally required for a particular use, we will obtain that consent.
51. DATA OWNERSHIP AND USER RESPONSIBILITIES
You are responsible for ensuring that information you provide to Drive and Earn is accurate, current and lawful.
You should promptly update information where necessary.
You should not provide:
• false identity information
• false vehicle information
• another person’s personal information without authority
• fraudulent documents
• manipulated location information
• false Campaign information
• other information intended to mislead Drive and Earn
52. DATA ACCURACY
Drive and Earn may rely on information provided by users, advertisers, partners and third parties.
We may take steps to maintain accurate information, but we cannot guarantee that information obtained from external sources will always be complete or accurate.
You should notify us if information associated with your account is incorrect.
53. ACCOUNT SECURITY
Users are responsible for maintaining the security of their account credentials.
You should protect your password, avoid sharing account credentials, use appropriate device security, notify us of suspected unauthorised access, and keep account information accurate.
Drive and Earn may suspend or secure an account where we suspect unauthorised access, fraud or security risks.
54. PRIVACY OF OTHER INDIVIDUALS
If you provide Drive and Earn with information about another individual, you should have appropriate authority or permission to provide that information where required by applicable law.
This may include information relating to drivers, employees, fleet operators, vehicle owners, representatives, passengers, contractors, or other individuals.
55. EMPLOYEES, CONTRACTORS AND BUSINESS CONTACTS
Drive and Earn may also process personal information relating to employees, applicants, contractors, consultants, suppliers, business representatives, advertisers, investors, partners, and other professional contacts.
Such processing may be subject to additional notices or contractual arrangements where required.
56. LEGAL CLAIMS AND DISPUTES
Drive and Earn may retain and process information necessary to establish legal rights, exercise legal rights, defend claims, investigate disputes, enforce agreements, investigate fraud, respond to regulatory matters, comply with legal processes, and protect the Platform and its users.
Such information may be retained for as long as legally necessary.
57. CHANGES TO THIS PRIVACY POLICY
Drive and Earn may update this Privacy Policy from time to time.
Changes may be made to reflect new services, new technologies, new processing activities, changes to the Platform, changes in legal requirements, changes in business operations, changes to third-party providers, or other developments.
Where required by applicable law, we will provide additional notice or obtain consent before material changes take effect.
The effective date shown at the beginning of this Privacy Policy identifies the applicable version.
58. SEVERABILITY
If any provision of this Privacy Policy is found to be invalid, unlawful or unenforceable in a particular jurisdiction, that provision will be interpreted or modified to the extent necessary to comply with applicable law, while the remaining provisions will continue to apply.
59. NO WAIVER OF LEGAL RIGHTS
Nothing in this Privacy Policy is intended to waive, remove, restrict or limit any privacy, consumer, data protection or other legal right that cannot lawfully be waived or restricted.
Where applicable law provides a stronger protection than this Privacy Policy, the applicable law will prevail to the extent required.
60. GLOBAL REGULATORY FRAMEWORK AND SUPERVISORY AUTHORITIES
Drive and Earn will process personal information in accordance with applicable privacy, data protection, consumer protection, electronic communications, marketing, cybersecurity and related laws applicable to the relevant processing activity.
Because Drive and Earn is intended to operate globally, different legal requirements may apply depending on where the individual is located, where the information is collected, where the information is processed, where Drive and Earn operates, where a Campaign operates, the type of information involved, the type of service provided, the parties involved, and the specific processing activity. This Privacy Policy is intended to operate alongside those requirements rather than replace them, and is not limited to or written primarily for any single country.
Without limiting the general, worldwide application of this Privacy Policy, the following is a non-exhaustive guide to the principal data protection frameworks and supervisory authorities relevant to countries in which Drive and Earn currently operates or intends to operate. Where Drive and Earn expands into a country not listed below, this Privacy Policy will still apply, together with that country’s applicable law and any Regional Addendum published for that country.
60.1 Nigeria
The Nigeria Data Protection Act 2023 ("NDPA"), enforced by the Nigeria Data Protection Commission ("NDPC").
60.2 United Arab Emirates
The UAE Federal Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) ("UAE PDPL"), together with any applicable free-zone data protection regime (such as the DIFC Data Protection Law, overseen by the DIFC Commissioner of Data Protection, or the ADGM Data Protection Regulations, overseen by the ADGM Office of Data Protection, where applicable to the relevant processing).
60.3 United Kingdom
The UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018, enforced by the Information Commissioner’s Office ("ICO").
60.4 European Union / European Economic Area
The EU General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR"), enforced by the national supervisory (data protection) authority of the relevant EU/EEA member state, coordinated at EU level by the European Data Protection Board ("EDPB").
60.5 United States
There is no single federal data protection law of general application in the United States. Where applicable, Drive and Earn complies with relevant state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), enforced by the California Privacy Protection Agency ("CPPA"), and equivalent comprehensive state privacy laws in other US states in which Drive and Earn operates or has users, such as Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA) and Utah (UCPA), each enforced by the relevant state Attorney General or dedicated privacy regulator.
60.6 Canada
The Personal Information Protection and Electronic Documents Act ("PIPEDA"), enforced by the Office of the Privacy Commissioner of Canada ("OPC"), together with applicable provincial privacy legislation where relevant.
60.7 Australia
The Privacy Act 1988 (Cth), enforced by the Office of the Australian Information Commissioner ("OAIC").
60.8 New Zealand
The Privacy Act 2020, enforced by the Office of the Privacy Commissioner ("OPC NZ").
60.9 Saudi Arabia
The Personal Data Protection Law ("PDPL"), enforced by the Saudi Data and Artificial Intelligence Authority ("SDAIA").
60.10 Qatar
Law No. 13 of 2016 Concerning Personal Data Protection, enforced by the Compliance and Data Protection Department of the National Cyber Governance and Assurance Affairs ("NCGAA"), together with the separate QFC Data Protection Regulations where processing occurs within the Qatar Financial Centre.
60.11 Singapore
The Personal Data Protection Act 2012 ("PDPA"), enforced by the Personal Data Protection Commission ("PDPC").
60.12 Other Jurisdictions
Where Drive and Earn collects or processes personal information of individuals located in a country not listed above, Drive and Earn will comply with the applicable data protection or privacy law of that country to the extent it applies to the relevant processing, and individuals in that country retain any rights granted to them under that law, notwithstanding that the specific law and regulator are not named above.
61. DATA PROTECTION BY DESIGN
Drive and Earn may consider privacy and data protection requirements when designing and developing applications, websites, Campaign systems, location intelligence systems, analytics systems, advertising technology, payment systems, verification systems, artificial intelligence systems, fraud prevention systems, and other Platform technologies.
Where required by applicable law, Drive and Earn may conduct privacy, security or data protection assessments (including Data Protection Impact Assessments under the EU/UK GDPR, or equivalent assessments under the Nigeria Data Protection Act 2023 or other applicable law) for particular processing activities, including large-scale or continuous location tracking.
62. DATA MINIMISATION
Drive and Earn seeks to collect and process information relevant to legitimate business, operational, legal, security and Campaign purposes.
We do not intend to collect personal information unrelated to the purposes for which it is processed. However, the information required may vary depending on the service, Campaign, jurisdiction and relationship with Drive and Earn.
63. ACCOUNT DELETION
Where available, you may request closure or deletion of your Drive and Earn account.
Account deletion does not necessarily require immediate deletion of every piece of information associated with the account.
Certain information may need to be retained for legal obligations, tax requirements, financial records, fraud prevention, security, dispute resolution, contractual enforcement, regulatory compliance, or other legally permitted purposes.
Where permitted by law, retained information will be securely stored and used only for the applicable purpose.
64. INFORMATION RETAINED AFTER ACCOUNT CLOSURE
Closing an account does not necessarily eliminate all information from Drive and Earn systems immediately.
For example, we may retain information relating to completed Campaigns, payments, financial transactions, tax records, legal claims, fraud investigations, security incidents, contractual obligations, regulatory requirements, and historical business records.
Where applicable, information will be deleted, anonymised or de-identified when the relevant retention requirement expires.
65. YOUR RESPONSIBILITY REGARDING DEVICE LOCATION PERMISSIONS
Certain Drive and Earn functions may require access to location information.
You may control certain location permissions through your device settings.
If you disable required location permissions, certain Campaign, verification, route or Platform functions may become unavailable or may not operate correctly.
66. VEHICLE TRACKING AND CAMPAIGN VERIFICATION
Where a Campaign requires route, location or activity verification, Drive and Earn may use available technology to verify Campaign participation.
This may include GPS, device location, application data, route data, timestamps, mileage information, vehicle information, photographs, verification technologies, third-party data, and other authorised technologies.
The specific technology used may vary by Campaign.
67. LOCATION DATA RETENTION
Location information may be retained for different periods depending on its purpose, as described further in Section 34.
For example, information may be retained to verify Campaign participation, calculate Campaign performance, investigate fraud, resolve disputes, maintain Campaign records, improve location intelligence, satisfy legal obligations, or perform legitimate business functions.
Where required by law, applicable retention limitations and deletion requirements will be followed.
68. FRAUD AND SECURITY DATA
Information generated through fraud detection, security monitoring and verification systems may be retained even after account closure where permitted by law.
This may include fraud indicators, verification outcomes, suspicious activity records, device information, location information, account information, Campaign activity, payment activity, investigation records, and security logs.
Such information may be used to prevent repeated abuse and protect Drive and Earn and its users.
69. NO GUARANTEE OF ABSOLUTE SECURITY
Although Drive and Earn takes security seriously, no technology, communication network, database, device or online service can be guaranteed to be completely secure.
Users acknowledge that internet transmission and electronic storage involve inherent risks.
Drive and Earn will maintain safeguards appropriate to applicable legal requirements and the nature of the information processed.
70. CONTACTING DRIVE AND EARN
For questions, privacy requests, data protection requests, complaints or other privacy-related matters, please contact Drive and Earn through the official website:
www.driveandearnapp.com
When contacting us regarding a privacy matter, please clearly identify the nature of your request so that it can be directed to the appropriate team.
71. COMPLAINTS
If you believe that Drive and Earn has processed your personal information unlawfully or improperly, you may contact us so that we can investigate the matter.
Where applicable law provides you with the right to complain to a supervisory authority, regulator, data protection authority or other competent body — such as those named in Section 60 — you may exercise that right at any time, including before or without first contacting Drive and Earn.
Nothing in this Privacy Policy prevents you from exercising a statutory complaint or regulatory right.
72. CONTACT AND PRIVACY REQUEST INFORMATION
When submitting a privacy request or complaint, you should provide sufficient information for us to understand and investigate the matter.
We may request additional information where necessary to verify identity, protect personal information or comply with applicable law.
73. LANGUAGE AND INTERPRETATION
This Privacy Policy may be translated into different languages for operational or legal purposes.
Where a translated version is provided, the applicable legal requirements of the relevant jurisdiction will determine how the notice is interpreted where required.
74. ENTIRE PRIVACY NOTICE
This Privacy Policy describes the principal ways in which Drive and Earn processes personal information.
Additional privacy notices, consent notices, cookie notices, Campaign notices, application disclosures, Regional Addenda or contractual provisions may apply to particular services, countries or processing activities.
Where a specific notice provides additional information for a particular service or country, that notice should be read together with this Privacy Policy.
75. EFFECTIVE DATE
This Global Privacy Policy and Data Protection Notice is effective from:
1 January 2026
Drive and Earn App
Developed and operated by Vision 2020 Group
www.driveandearn.ae