Effective Date: 9th October 2024

This Privacy Policy and its Addendum(s) (“Privacy Policy”) describe how Umney Company Limited, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (“Umney”, “we”, “us” or “our”) gather, utilize, handle and reveal your personal Information through the utilize of Umney’s mobile applications and websites (respectively “Apps” and “Websites”), as well as products, features and other services globally, operated by Umney (“Services”).

This Policy applies to our consumers, agents, vendors, suppliers, partners (such as driver, delivery and merchant partners), contractors and service providers (“you”, “your” or “yours”).

“Personal Information” is any information which can be utilized to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information.

We typically gather, utilize, reveal or otherwise handle your personal Information in accordance with this Privacy Policy with your consent, or in compliance with applicable laws, such as where:

• It is required for us to comply with legal requirements.
• It is required for us to enter into or perform a contract with you; and/or
• For our legitimate interests or the legitimate interests of any other persons, including but not limited to for the purposes set forth in this Privacy Policy.

I. COLLECTION OF PERSONAL DATA
We gather personal Information about you in the ways listed below. We may also combine personal Information gathered via these various channels:

You provide your Personal Information to us.

We gather your Personal Information when you provide it to us. For example, when you:

• Complete a user profile or registration forms (such as your name, contact information and other identification information where needed).
• Provide information to assess your eligibility to provide services as a Umney driver partner or delivery partner (such as your driver’s license information, vehicle information and background check results).
• Interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data).
• Participate in contests or events organized by us (such as the pictures, audio, or videos you may submit, which may include images of yourself).
• Verify your identity through various means (such as social media logins, submission of selfie images or independently verified payment card information).  
• Fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation and income information); and
• Agree to take a ride with in-vehicle audio and/or video recording features.

When our services are utilized
Personal Information may be gathered through the normal operation or utilize of our Apps, Websites and Services. Some examples are:

• Your location information.

           We collect the precise or approximate locations of users, drivers, delivery personnel, or service providers to enable different services, enable tracking and safety features, prevent and detect fraud, and comply with legal requirements. We collect this information when the app is running in the foreground or background of the user's mobile device.

          We collect location data, such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the mobile application. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. Note, however, that if you choose to opt out, you may not be able to use certain aspects of the services.

• Feedback, ratings and compliments.
• Transaction information (such as payment method).
• Information about how you interacted with our Apps, Website or Services (such as features utilized, and content viewed).
• Device information (such as hardware model and serial number, IP addresses), file and app names and versions, GPS location, IMEI number, and advertising identifiers or any information that may indicate device or app modification). 
• Telematics data (such as your speed, acceleration and braking data).

• To guarantee that vehicles are maintained appropriately and serviced in a timely fashion.
• To help maintain the safety, security and integrity of our products and Services.
• To improve and enhance our products and Services; and
• For internal tracking of the vehicle, analysis and administrative purposes.

These partners own and share such telematics data with us:

• our partners are also contractually obliged to safeguard this data.
• Personal information you enter in messages when you utilize our in-app communication features; and
• Personal information that may be captured through your interaction with us, our agents, in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).
• our in-vehicle applications or devices
• we may install in-vehicle audio and/or video recording applications or devices to promote the safety and security of our driver partners, delivery partners and consumers. 
• your Personal Information may be captured in these audios and/or video recordings. Where in-vehicle audio and/or video recordings are made, such recordings are gathered, handled, utilized and stored in a manner in accordance with this Privacy Policy and applicable laws.
• personal in-vehicle applications or devices
• some Umney partners may install personal in-vehicle applications or devices in their vehicles for their own purposes. This practice is not endorsed nor prohibited by Umney.
• the gathering, utilize and disclosure of Personal Information obtained from personal in-vehicle applications or devices is the responsibility of the relevant partner. Please check with the relevant partner if you have any queries about their utilize of personal in-vehicle cameras.

From other sources
We may gather Personal Information, including but not limited to your name, contact information and other identification information where needed from other sources. Such sources include:

• Referral program
• Our business partners, such as fleet partners, payment providers, ride-hailing partners and transport partners
• Insurance and financial providers
• Credit bureaus, alternative credit scoring agencies and any other credit reporting organizations.   
• Publicly available or governmental sources of data.
• When our utilizers add you as an emergency contact.
• When our utilizers add you as a recipient or beneficiary of any utilize of our services.
• When you utilize our in-app chat; and
• Marketing services providers or partners.
• When we need to validate/verify validity of the information provided 

Sensitive Personal Information
Some of the Personal Information that we gather may be sensitive in nature. This may include Personal Information pertaining to your race, national ID information, religious beliefs, background information (including financial and criminal records, where legally permissible), health data, disability, marital status and biometric data, as applicable. We gather sensitive Personal Information only with your consent and/or in strict compliance with applicable laws. In the event that you are required to furnish any documentation or information to us for any Purpose which may contain such sensitive Personal Information (which is not required that Purpose), you agree to provide such sensitive Personal Information before providing such documentation or information to us.

When you provide Personal Information of other individuals to us
In some situations, you may provide Personal Information of other individuals (such as your spouse family members or friends) to us. For example, you may add them as your emergency contact, when you utilize the in-app chat or when you add them as recipients or beneficiaries of any utilize of our Services. If you provide us with their Personal Information, you represent and warrant that you have obtained their consent for their Personal Information to be gathered, utilized and revealed as set out in this Privacy Policy.

Personal Information of minors
As a parent or legal guardian, please do not allow minors under your care to submit Personal Information to Umney. In the event that such Personal Information of a minor is revealed to Umney, you hereby consent to the handling of the minor’s Personal Information and accept and agree to be bound by this Notice and take responsibility for his or her actions.   

II. USE OF PERSONAL DATA
Umney may utilize your Personal Information for the following purposes set out in the list below. (“Purposes”). Additionally, if you utilize Umney in various capacities (for example, if you utilize multiple Umney Services, or if you are both a driver partner/delivery partner and a consumer), we may link your Personal Information gathered across your various capacities to facilitate your utilize of our Services and for the Purposes described below:    

Delete user data. 
We retain user data for as long as necessary for the purposes described above, including to provide its services and comply with legal obligations. The user has the right to delete all personal data collected by the app. Please follow the below process to request data deletion. 

Steps to Request Data Deletion: Users may request deletion of their account via application only. Follow the path "Login into the application >> Go to Profile Section >> Find "Account Settings" >> Tap on "Manage Accounts" >> Look for the option "Delete Account" to request data deletion. You will be prompted to select the reason for your decision. Once you choose the reason and submit your request, your account deletion process will begin to take effect

Providing services and features
Your Personal Information will be utilized to provide, personalize, maintain and improve our Apps, Websites and Services. This includes using your Personal Information to:

• Engage you to provide you with services across our various business verticals.
• Create, administer and update your account.
• Handle, manage or verify your eligibility for or application of products, Services, promotions, rewards and subscriptions with Umney.
• Conduct due diligence checks and risk assessments / analysis.
• Verify your identity and age (where necessary).
• Validate your ride and handle payments.
• Offer, obtain, provide, facilitate or maintain insurance or financing solutions.
• Track the progress of your trip and detect abnormal trip variations.
• Allow you to participate in the loyalty programmed or marketing activities organized by our merchant-partners and/or in collaboration with Umney.
• Personalize your App experience (such as to recommend products and services relevant to you, identify your preferences or otherwise personalize your experience with Umney.
• Make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys.
• Perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analyzing usage and activity trends.
• Protect the security or integrity of the Services and any facilities or equipment utilized to make the Services available.
• Enable communications between our users.
• Invite you to participate in our surveys and studies.
• Enable our partners to manage and allocate fleet resources and
• Fulfil the services to you as a data handler, where you have provided consent to the data controller (i.e. The organization you had purchased goods or services from, and for whom Umney is providing services on behalf of) for such services to be rendered.

Safety and security
We utilize your data to guarantee the safety and security of our Services and all utilizers. This includes.

• Screening driver and delivery partners before enabling their utilize of our Services.
• Identifying unsafe driving behavior such as speeding, harsh braking and acceleration, and providing personalized feedback to driver partners.
• Verifying your identity when you log in to Umney.
• Using device, location, profile, usage and other Personal Information to prevent, detect and combat fraud or unsafe activities.
• Sharing drivers and passengers of driver partners’ location and details when the emergency button or the “Share My Ride” feature is activated; and
• Monitoring compliance with our terms and conditions and policies.

User support
We utilize Personal Information to resolve utilizer support issues. For example, we may:

• Investigate and address concerns.
• Monitor and improve our utilizer support responses.
• Respond to questions, comments and feedback; and
• Inform you about steps taken to resolve utilizer support issues.

Research and development and security.
We may utilize the Personal Information we gather for testing, research, analysis and product development. This allows us to understand and analyses your needs and preferences, protect your Personal Information, improve and enhance the safety and security of our Services, develop new features, products and services, and facilitate development of insurance and finance solutions.

Legal purposes
We may utilize the Personal Information we gather for legal purposes, such as to investigate and resolve claims or disputes, detect/prevent/prosecute crime, or as allowed or required by applicable law. 
We may also utilize your Personal Information when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.
For example, we may utilize your Personal Information to:

• Comply with court orders or other legal, governmental or regulatory requirements.
• Enforce our Terms of Service or other agreements; and
• Protect our rights or property in the event of a claim or dispute.

Marketing and promotions
We may utilize your Personal Data to send you marketing communications relating to customized products or services (that may be of interest or relevance based on your profile), or Umney’s partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:

• Send you special offers that may be of interest or relevance to you across all of Umney’s service offerings.
• Send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
• Notify, invite and manage your participation in our events or activities.

We may communicate such marketing to you by various means, where applicable (including by SMS, chat applications (e.g. WhatsApp, push notification, call, and by email)

If you wish to unsubscribe to the receiving of such marketing communications, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings. Please note that while you may opt out of marketing or promotion communications, Umney may still send you account and / or service-related messages (such as two-factor authentication, information on your transactions, rewards, etc.). 

User Published Content
If you publish content (such as a review or comment) on Umney’s platform, it will be shown publicly along with your personal information (such as profile name, uploaded photo(s)), and other information you choose to include in your content. For more information, see ours.

III. DISCLOSURE OF PERSONAL DATA
We need to share Personal Information with various parties for the Purposes. These parties include:
Other utilizers 
For example: 

• if you are a passenger of driver partners, we may share your username, pick-up and drop-off locations with our driver partner fulfilling your service request.
• if you are a driver partner, we may share your Personal Information with your passenger including your name and photo; your vehicle makes, model, number plate, location and average rating.
• if you are using our Umney store service, we may share your Personal Information with our delivery partner and selected merchant-partner, including your order details and drop off location.
• if you are participating in loyalty programs or marketing activities organized by our merchant-partners, we may share your Personal Information with them, including your name and contact details.
• if you are a delivery partner, we may share your Personal Information with your selected merchant-partner and utilizer, including your name and photo; your vehicle makes, model, location and average rating.
• if you are using our Umney delivery genie or delivery runner services, we may share your Personal Information with the recipient of your parcel, and vice versa, as well as the delivery partner in charge of fulfilling your service request; and
• if you utilize our in-app chat service, we may share your mobile number and Umney-registered name with the other parties to your chat.

With third parties
With third parties related to the use of Umney Services 
For example:

• if you are a passenger of driver partners, we may share a vehicle’s location and driver’s and/or your name with third parties when you utilize the “Share My Ride” feature or activate the Emergency Button.
• if you are a driver-partner, we may reveal your vehicle plate number or other personal information to the insurance company and/or to your passenger for the purpose of submission of insurance claims.
• if you utilize our payment services, we may share your Personal Information with another individual should you authorize and enable connection of his or her third party service payment method to our payment service for the purposes of enabling your payment on Umney.

For example:

• your employer may receive transaction data (tagged as business expenses) when you utilize your employer’s Umney for Business account.
• the administrator of any community group to which you link your Umney account may receive transaction data when you carry out a transaction.

With subsidiaries and affiliates
We share Personal Information with our subsidiaries, associated companies, jointly controlled entities and affiliates. The companies in the Umney group share resources, such as infrastructure and technology with each other to provide you with a consistent, relevant and secure experience when you utilize our products or Services, and for the Purposes set out in this Privacy Policy. 

For example, we do this to make your experience more seamless, such as by automatically completing your registration information from your use of one Umney Product or Service when you sign up for a new Umney Product or Service.

With Umney’s service providers and business partners
We may provide Personal Information to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:

• Payment handlers and facilitators.
• Debt collectors    
• Credit bureaus, alternative credit scoring agencies and any other credit reporting organizations.
• Background check and anti-money laundering service providers.
• Cloud storage providers.
• Document storage and management providers.
• Advertising and marketing partners and platform providers.
• Data analytics providers.
• Research partners, including those performing surveys or research projects in partnership with Umney or on Umney’s behalf.
• Educational and training institute partners.
• Fleet and merchant partners.
• Insurance and financing partners.    
• Third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians.
• Service providers who perform identity verification services; and
• Vehicle solutions partners, vendors or third-party vehicle suppliers.

For example:

• If you requested a service through a Umney partner or utilized a promotion provided by a Umney partner, Umney may share your Personal Information with that Umney partner. 
• If you have rented a vehicle from our recommended fleet partners to drive with Umney, we may share relevant information (e.g. the status of your account, applicable incentives/promotions, your ride statistics) for collaborative efforts (e.g. create new incentives and benefits for you or improving supply of driver partners).

With our legal advisors and governmental authorities
We may share your Personal Information with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:

• Where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or    
• Where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).

Business transfers
We may share your Personal Information with other parties, in connection with any acquisitions, sales, mergers, joint ventures, consolidation, restructuring, financing or any other type of business transactions. Your Personal Information will however remain subject to our obligations made in any pre-existing Privacy Policy that you have agreed to.

IV. RETENTION OF PERSONAL DATA
We retain your Personal Information for the period necessary to fulfill the Purposes outlined in this Notice unless a longer retention period is required or allowed by law. Once your Personal Information is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Information, we take steps to erase, destroy, anonymize or prevent access or utilize of such Personal Information for any purpose other than compliance with this Notice, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws. 

V. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Your Personal Information may be transferred from the country, state and city (“Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”).

When we transfer your Personal Information from your Home Country(Kenya) to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Information, including having a lawful basis for transferring Personal Information and putting appropriate safeguards in place to guarantee an adequate level of protection for the Personal Information. 
We will also guarantee that the recipient in Alternate Country is obliged to protect your Personal Information at a standard of protection comparable to the protection under applicable laws.

Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Information from your Home Country to the Alternate Country at the time you provide your Personal Information) or one of the safeguards permissible by laws.

VI. COOKIES, RELATED TECHNOLOGIES, AND ADVERTISING ON THIRD PARTY PLATFORMS
Cookies
Umney, and third parties with whom we partner, may utilize cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (such as software development kits (SDKs), which have similar functions to cookies and which may be installed in the Umney App to allow partners to gather certain information about your interaction with the Umney App) in connection with your utilize of the Websites and Apps, which may be persistent or stored only during an individual session on your browsers or devices. 

Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may be utilized for various purposes such as to:

• Provide the essential, basic functions of the utilize of our Websites, Services or Apps.
• Authenticate you or remember your utilizer preferences and settings.
• Delivering and measuring the effectiveness of advertising campaigns, such as by measuring number of views or clickthrough’s
• Analyze site traffic and trends. 
• Serve you relevant advertisements across other apps and websites owned by other companies (whether by us or by other advertisers); and
• Enhance utilizer interface and experience by generally understanding the online behaviors and interests of utilizers who interact with our Website, Services or Apps.

Umney may allow third parties to utilize Cookies on the Websites and Apps to gather the same type of Personal Information for the same purposes Umney does for itself. Third parties may be able to associate the Personal Information they gather with other Personal Information they have about you from other sources. We do not necessarily have access to or control over the Cookies they utilize.

Disabling the gathering of cookies on our websites 

You have the right to choose to disable, block or deactivate cookies. 

Please note that however refusal or removal of some cookies could affect the availability, functionality or utilize of our Website, Services or Apps.

You may adjust your internet browser settings to disable, block or deactivate cookies, delete your browsing history or clear the cache from your internet browser. The settings may be contained within the “History”, “Preferences”, “Settings” or “Privacy” section of your internet browsers, or you may otherwise consult the help section of your internet browser for more information. 

Disabling the display of Targeted Ads on other platforms  
We may facilitate the display of targeted advertising on other platforms, such as on other online platforms that you may be a utilizer of. 

You may be able to limit our utilize of your Personal Information to display targeted advertisements on behalf of our advertisers, by adjusting your preference through our Umney App. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our utilize of mobile identifiers (such as Apple’s IDFA or Google’s GAID) and the ability to track you across apps and websites owned by other companies by adjusting the settings available on your mobile devices. Through adjusting the settings on your device, you can typically reset, delete, limit and/or otherwise restrict the utilize of such mobile identifiers.

Although we will not utilize your Personal Information to show you such targeted advertisements on other platforms, you may still see generic ads that appear relevant to you. This may be because we have engaged third party advertisers / platforms to display ads to utilizers of specific attributes or demographic makeups who may find them relevant. You may be able to limit seeing these advertisements through managing your preferences on these platforms.

VII. PROTECTION OF PERSONAL DATA
We will take reasonable legal, organizational and technical measures to guarantee that your Personal Information is protected. This includes measures to prevent Personal Information from getting lost or utilized or accessed in an unauthorized way. We limit access to your Personal Information to our employees on a need-to-know basis. Those handling your Personal Information will only do so in an authorized manner and are required to treat your information with confidentiality.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through any online means, therefore, any transmission remains at your own risk.

VIII. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA    
In accordance with applicable laws and regulations, you may be entitled to:

• Inquire about the handling of your Personal Information and be provided with a copy of it.
• In some cases, request the correction and/or deletion of your Personal Information
• In some cases, request the restriction of or object to the handling of your Personal Information
• Withdraw your consent to the handling of your Personal Information within our possession or control (and where we are handling your Personal Information based on your consent)
• Request receipt or transmission to another organization, in a machine-readable form, of the Personal Information that you have provided to us where we are using your Personal Information based on consent or performance of a contract. 
• Complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment as a result of unlawful handling of your Personal Information.

Where you are given the option to share your Personal Information with us, you can always choose not to do so. If we have requested your consent to handling and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, choosing not to share your Personal Information with us, withdrawing your consent to our utilize of it or to your agreement with our Privacy Policy could mean that we are unable to perform the actions necessary to achieve the purposes of handling described in Section II (Use of Personal Information) or that you are unable to make utilize of App or the Services.
 
After you have chosen to withdraw your consent, we may be able to continue to handle your Personal Information to the extent required or otherwise permitted by applicable laws and regulations.

We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

IX. AMENDMENTS AND UPDATES
Umney may modify, update or amend the terms in this Privacy Policy at any time. Such amendments shall be notified to you through the Application and/ or other appropriate means at least three (3) business days before the effective date. The updated version will be posted on the website. It is your responsibility to review the Privacy Policy regularly. Your continued utilize of the Apps, Websites or Services, purchase products from Umney or continuing to communicate or engage with Umney following the modifications, updates or amendments to this Notice, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.

X. HOW TO CONTACT US
If you have any queries about this Notice or would like to exercise your rights set out in this Notice

• Email; support@umney-ea.com 

I.INTERPRETATION
All capitalized terms but undefined terms utilized herein shall bear the same meaning as those defined in the Terms of Use and Umney’s Privacy Policy

This Addendum forms part of the Umney Privacy Policy. In the event of any inconsistency between the Umney Privacy Policy and this Addendum, this Addendum shall prevail.

II. UMNEY’S RELATIONSHIP WITH USERS AND CLIENTS

How Umney for Business works
Umney for Business is provided as an add-on feature for organizations (“Client”) to facilitate corporate billing for its authorized Users’ (e.g. employees) utilize of Umney’s Services in the course of work.

When a client chooses to utilize Umney for Business, the Authorized User is given the option of tagging his/her rides or other transactions to the Client or to tag it as a personal ride. As part of this feature, Umney will reveal detailed trip and booking information that Authorized Users have tagged as being for business purposes to the Client. Apart from this, Umney does not reveal other Personal Information of Authorized Users to the Client.

Alternatively, an individual utilizer may choose to set up a business profile within the App to facilitate the tagging of business-related rides and to generate consolidated trip reports to facilitate the submission of claims from his or her employer. When utilized in this mode, the claims handle is user-driven, and the utilizer’s employer need not be a Client.

For ease of reference, Authorized Users and individual utilizers will each be referred to as a “User” and inclusively as “Users” in this Addendum.

Umney is a data controller, so are our clients.
In respect of any User and the handling of their Personal Information, Umney acts as a data controller. For further information on how Umney gathers, utilizes and reveals Users’ Personal Information, please refer to the Umney Privacy Policy.

Due to the way Umney for Business works, Umney does not handle any Personal Information for and on behalf of the Client. Accordingly, Umney is not the data handler of the Client, but an independent data controller in respect of all Personal Information that it handles in the course of providing the Umney for Business feature. Likewise, the Client is an independent data controller of the Personal Information that it reveals to and/or receives from Umney.

As independent controllers, Umney and the Client individually determine the purposes and means of handling Personal Information, subject to the provisions set out in the Terms of Use and this Privacy Policy. Umney and the Client are also individually responsible to guarantee the protection of Personal Information under their charge.

III. WHAT PERSONAL DATA IS COLLECTED, PROCESSED AND DISCLOSED
What Umney gathers as part of Umney for Business
In order to provide the Umney for Business feature, the User or the Client will be required to provide the following information about the User to Umney:

• full name.
• business email address; and
• other identifying information about the User as reasonably requested by Umney.

• authenticating the User.
• where applicable, linking the Authorized User’s account with the Client’s Umney for Business account or tracking the Authorized User’s business profile bookings on the Apps, as the case may be.
• where applicable, verifying the Corporate Billing status of such Authorized User from time to time; and
• contacting the User in accordance with the purposes set out in the Umney Privacy Policy.

Upon onboarding a User to the App, Umney will handle the Personal Information of the User in accordance with the Umney Privacy Policy and this Addendum.

What Umney reveals to its clients

Umney will reveal relevant trip and booking information as determined by Umney from time to time to the Client to facilitate Corporate Billing.

What Umney reveals to its individual utilizer

Depending on the business profile settings selected by the individual utilizer, the utilizer may retrieve and generate reports containing his/her relevant trip and booking information.

IV. PARTIES’ OBLIGATIONS
The Client and Umney shall each:

• Individually inform their data subjects of how each handles Personal Information and allow their data subjects to exercise their rights under the local data protection/data privacy laws.
• Comply with the obligations applicable to each party under the applicable data protection/data privacy laws when handling any Personal Information of the Proposed or Authorized Users.
• Obtain the necessary consents (if applicable) for its disclosure of Personal Information to facilitate the provision of the Umney for Business feature; and
• Implement appropriate legal, technical and organizational measures to protect Personal Information against unauthorized or unlawful handling and against unauthorized loss, destruction, damage, alteration, or disclosure, as well as any breach or attempted breach of its security measures (“Information Security Incident”).