ROUTA PRIVACY POLICY

1.Who We Are (Data Controller)

1.1Routa Enterprise is the data controller responsible for your personal data processed through the Platform.

1.2For any privacy-related questions, requests, or complaints, you may contact us using the details provided in the "Contact Us" section of this Policy.

1.3Where Routa processes personal data on behalf of a service provider or partner, Routa may act as a data processor, and the relevant third party may act as an independent data controller.

2.Scope of This Policy

2.1This Policy covers personal data collected through the Platform, including our waitlist, account registration, booking workflows, customer support channels, and marketing communications.

2.2This Policy does not apply to the independent practices of third-party service providers, payment processors, or external websites that may have their own privacy policies.

2.3We encourage you to review the privacy policies of any third party whose services you access through or alongside the Platform.

3.Information We Collect

3.1Information you provide directly to us, which may include:

• Full name
• Email address
• Agency or business name and website URL (for service providers)
• How you heard about us (referral source)
• Booking, travel, and reservation details you submit
• Communications, enquiries, feedback, and reviews you send to us

3.2Information we collect automatically when you use the Platform, which may include:

• Device information (such as device type, operating system, and browser type)
• IP address and approximate location derived from it
• Usage data, such as pages visited, features used, and time spent on the Platform
• Cookies and similar tracking technologies
• Referring website or campaign source

3.3Information we may receive from third parties, which may include:

• Service providers and partners involved in fulfilling your bookings
• Payment processors confirming transaction status
• Analytics, advertising, and marketing platforms
• Social media platforms where you interact with our content

3.4We do not intentionally collect sensitive personal data unless it is necessary for a specific service and is processed with an appropriate lawful basis.

4.How We Use Your Information

4.1We use your personal data for purposes including:

• Adding you to and managing our waitlist
• Creating and administering your account
• Facilitating searches, comparisons, bookings, and payments
• Communicating with you about your account, bookings, or enquiries
• Sending product updates, launch announcements, and marketing communications where permitted
• Providing customer support and responding to your requests
• Improving, personalising, and developing the Platform and our services
• Detecting, preventing, and addressing fraud, abuse, and security issues
• Complying with legal, regulatory, and contractual obligations

4.2We will not use your personal data for purposes that are incompatible with those described in this Policy without notifying you or obtaining your consent where required.

5.Lawful Bases for Processing

5.1We process your personal data on one or more of the following lawful bases under the NDPA:

• Your consent, which you may withdraw at any time
• The performance of a contract with you, or to take steps at your request before entering into a contract
• Compliance with a legal or regulatory obligation
• Our legitimate interests, provided these are not overridden by your rights and freedoms
• The protection of your vital interests or those of another person

5.2Where we rely on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6.Marketing and Waitlist Communications

6.1If you join our waitlist or otherwise opt in, we may send you emails about Routa's launch, features, offers, and updates.

6.2You may unsubscribe from marketing communications at any time using the unsubscribe link in our emails or by contacting us directly.

6.3We may still send you non-promotional service messages relating to your account, bookings, or legal notices, even if you opt out of marketing.

7.Cookies and Tracking Technologies

7.1We use cookies and similar technologies to operate the Platform, remember your preferences, analyse usage, and support marketing.

7.2The types of cookies we may use include:

• Essential cookies required for the Platform to function
• Performance and analytics cookies that help us understand usage
• Functionality cookies that remember your preferences
• Advertising and marketing cookies that help measure campaigns

7.3You can manage or disable cookies through your browser settings, although doing so may affect the functionality of the Platform.

8.How We Share Your Information

8.1We may share your personal data with:

• Service providers whose services you book or enquire about through the Platform
• Payment processors and financial institutions to facilitate transactions
• Technology, hosting, analytics, and marketing vendors that support our operations
• Professional advisers such as lawyers, auditors, and consultants
• Regulators, law enforcement, or other authorities where required by law
• A successor entity in connection with a merger, acquisition, or sale of assets

8.2We require third parties that process personal data on our behalf to do so under appropriate contractual and security obligations.

8.3We do not sell your personal data to third parties.

9.International Data Transfers

9.1Your personal data may be processed, stored, or transferred to countries outside Nigeria where our service providers or infrastructure are located.

9.2Where we transfer personal data internationally, we take reasonable steps to ensure an adequate level of protection consistent with the NDPA, including the use of appropriate safeguards and contractual protections.

10.Data Retention

10.1We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including legal, accounting, regulatory, or reporting requirements.

10.2When personal data is no longer required, we will securely delete, anonymise, or otherwise dispose of it in accordance with applicable law.

10.3Waitlist data is retained until you unsubscribe or request deletion, or until it is no longer needed for the purpose for which it was collected.

11.Data Security

11.1We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure.

11.2Despite our efforts, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

11.3You are responsible for keeping your account credentials confidential and for notifying us promptly of any unauthorised use of your account.

12.Your Rights

12.1Subject to applicable law, you have the following rights in relation to your personal data:

• The right to be informed about how your data is processed
• The right to access the personal data we hold about you
• The right to request correction of inaccurate or incomplete data
• The right to request deletion of your data where applicable
• The right to object to or restrict certain processing
• The right to withdraw consent at any time
• The right to data portability where applicable
• The right to lodge a complaint with the Nigeria Data Protection Commission (NDPC)

12.2To exercise any of these rights, please contact us using the details in the "Contact Us" section. We may need to verify your identity before responding to your request.

12.3We will respond to valid requests within the timeframes required by applicable law.

13.Children's Privacy

13.1The Platform is intended for users who are at least 18 years old.

13.2We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without appropriate consent, we will take steps to delete it.

14.Third-Party Links and Services

14.1The Platform may contain links to third-party websites, service providers, or applications that are not operated by Routa.

14.2We are not responsible for the privacy practices or content of such third parties, and this Policy does not apply to them.

14.3We encourage you to read the privacy policies of any third party before providing them with your personal data.

15.Changes to This Policy

15.1We may update this Policy from time to time to reflect changes in our practices, technology, or legal requirements.

15.2When we make material changes, we will update the "Effective Date" and, where appropriate, provide additional notice.

15.3Your continued use of the Platform after any update constitutes acceptance of the revised Policy.

16.Contact Us

16.1If you have questions, requests, or complaints about this Policy or our data practices, please contact:

• Routa Enterprise
• Email: tryrouta@gmail.com
• Address: 19, WASIU SHOKUNBI, AGUNFOYE, IGOGBO, IKORODU, LAGOS STATE, NIGERIA

16.2You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been infringed.