Privacy Policy

Privacy Notice for Operators

Tog……..is a company registered under the law of The term "us" or "we" refers to the owner of the TOG app, TOG, a private limited company, founded in the.

Personal data we process

  1. Name, e-mail, phone number, place of residence.
  2. Financial risk, bank information and professionalism.
  3. Geolocation of operators and operator assigned cluster routes.
  4. Information about vehicles (including registration number).
  5. Operator’s efficiency and ratings.
  6. Operator’s license, photo, profession and identity documents.
  7. Data about criminal convictions and offences. The financial data of providing transportation services is not considered as personal data, because operators provide services in the course of economic and professional activities.


Purposes of the processing

  1. We collect personal data for the purpose of access customers qualification to join, operate and benefit from the platform and it product and programs.
  2. We collect and process personal data for the purpose of connecting customers with mechanization service providers (operators).
  3. Financial, banking and product financial data requirements.
  4. Geolocation and operator assigned cluster routes are processed to analyze the geographical area and give suggestions to the operators. ​If you do not want to disclose your geolocation for customers, you must close the TOG app or indicate in the TOG app that you are offline and currently are not providing transportation services.
  5. Operator’s license, profession, identity documents and criminal convictions and offences are processed to determine the compliance with the legal requirements and the suitability of pursuing a profession as a operator.
  6. TOG app displays operator’s photo, name and vehicle details for the customers to identify operator and vehicle.
  7. You will receive summaries from the TOG Operator Portal, which will include your efficiency and ratings as a operator. Summary and ratings about operator are necessary to provide a reliable service for customers.


Legal Basis

  1. Personal data is processed for the performance of the contract concluded with the operator. The prerequisite for the use of the TOG services is the processing of operator's identification and geolocation data.
  2. Personal data may be processed on the ground of legitimate interest in investigating and detecting fraudulent payments.
  3. Data regarding the ​criminal convictions and offences is processed for compliance with a legal obligation.


Recipients

  1. Your personal data is only disclosed to customers, whose order has been accepted by you. Customers will see operator’s name, vehicle, phone number, photo and geolocation data. Customers also see operator’s personal data in the receipt.
  2. Depending on the location of the operator, the personal data may be disclosed to the ​TOG local ​subsidiaries, representatives, affiliates, agents etc.)​. Processing of personal data by will occur under the same conditions as established in this privacy notice.


Security and Access

  1. Any personal data collected in the course of providing services is transferred to and stored in the data centers of Zone Media LTD and/or Amazon Web Services, Inc., which are located in the territories of a Member States of the European Union. Only authorized employees of ​TOG group companies and partners ​have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding transportation services).
  2. TOG group companies and partners ​can access personal data to the extent necessary to provide customer support in the respective country, see more ​tog.ng


Processing Customers Personal Data

  1. You may not process the personal data of customers without the permission of us. You may not contact any passenger or collect, record, store, grant access, use or cross-use the personal data provided by the passenger or accessible to you via the TOG app for any reason other than for the purposes of fulfilling the transportation services.
  2. You must comply with the rules and conditions for processing of personal data of customers as set forth in the Privacy Notice for Customers tog.ng/legal If you violate the requirements for the processing of personal data of customers, we may terminate your operators account and claim damages from you.


Access, Correction, Retention, Deletion and Data Portability

  1. Personal data can be viewed and corrected in TOG Operator Portal.
  2. Your personal data will be stored as long as you have an active operator's account. If your account will be closed the personal data will be stored for additional 5-year period.
  3. Data necessary for accounting purposes shall be stored for 7 years.
  4. In the event of suspicions of administrational or criminal offence, fraud or false information, the data shall be stored for 10 years.
  5. In the event of disputes, the data shall be retained until the claim is satisfied or the expiry date of such claims.
  6. We respond to the request for deleting and transferring personal data submitted by an e-mail within a month and specify the period of data deletion and transfer.


Known disclosure, registration and exit



Dispute Resolution

  1. Disputes relating to the processing of personal data are resolved through customer support (info.tog.ng) ​or by contacting togs Data Protection Officer (tog.ng/protection).
Privacy Notice for Farmers

Tog……..is a company registered under the law of The term "us" or "we" refers to the owner of the TOG app, TOG, a private limited company, founded in the.

Personal data we process

  1. Name, e-mail, phone number, place of residence.
  2. Geolocation of the passenger, the time and the destination of a journey.
  3. Payment information.
  4. Information about disputes.
  5. Identification data of the device on which the Tog app has been installed.


Purposes of the processing

  1. We collect and process personal data for the purpose of connecting farmers with operator to help them move around cities more efficiently.
  2. We display geolocation data and the phone number of farmers to operator to enable efficient pick-up. Geolocation data is collected only when the Tog app is activated. The collection of geolocation data stops after closing the Tog app. In some countries operator cannot see farmers’ phone numbers; the driver sees an altogether different number which temporarily diverts to the passenger’s phone number enabling the driver and passenger to communicate.
  3. We may use geolocation data to resolve quality issues related to mechanization services.
  4. We use contact details to notify farmers of updates to the Tog app.
  5. We collect data of the routes taken by operator and farmers to analyze the geographic coverage in order to provide recommendations to the operator about most efficient routes.
  6. Your name, phone number and e-mail will be used to communicate with you.
  7. We obtain payment details to process farmers' payment on behalf of operator for mechanization services.

Customer support data is collected on a case-by-case basis and stored for the purpose of resolving disputes and service quality issues.



Legal Basis

  1. Personal data is processed in order to provide the service contracted with farmers. We collect and processes the personal data submitted by the farmers in the course of installation and use of the Tog app. The prerequisite for the use of Tog services is farmers agreeing to the processing of identification and geolocation data.
  2. Personal data may be also processed on legitimate interest grounds, for example in investigating and detecting fraudulent payments.


Recipients

  1. The personal data of passenger is only disclosed to driver who has activated Tog app; in such case, driver will see the name, phone number (in some countries the number is masked) and geolocation data of the passenger.
  2. After providing the mechanization service, the name and the telephone number (in some countries the number is masked) of the passenger will remain visible to the driver for 24 hours. This is necessary for operator to resolve any issues associated with service provision, e.g., to contact the passenger if something was left behind in the vehicle.

Feedback given by farmers regarding the quality of the service is anonymous and operator do not receive names and telephone numbers of the passenger who provided rating and feedback.
Depending on the location of the passenger, the personal data may be disclosed to the Tog group companies and partners (local subsidiaries, representatives, affiliates, agents etc). Processing of personal data by Tog group companies and partners will occur under the same conditions as established in this privacy notice.



Security and Access

  1. Any personal data collected in the course of providing the services is transferred to and stored in the data center’s of Zone Media Ltd. and/or Amazon Web Services, Inc., which are located in the territories of a Member States of the European Union. Only authorized employees of Tog group companies and partners have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding mechanization services).
  2. TOG group companies and partners ​can access personal data to the extent necessary to provide customer support in the respective country, see more ​tog.ng

Geolocation data is processed in anonymized form and personalized only if the geographical location data is needed to be linked to a passenger for resolving disputes or fraud.

For research and scientific purposes, the data is used in unidentified form (anonymized)



Access and correction

  1. You can access and update your personal data via the Tog app.


Retention

  1. Your personal data will be stored as long as you have an active passenger account. If your account is closed, personal data will be deleted (according to the policies set out in this section) from the databases, unless such data is required to be retained for accounting, dispute resolution or fraud prevention purposes.

Financial data regarding mechanization services provided to farmers will be stored for 3 years after the last journey.

Data required for accounting purposes will be stored for 7 years [after the last journey].

In the event that there are suspicions of a criminal offence, fraud or false information having been provided, the data will be stored for 10 years.

In case of payment disputes, data will be retained until the claim is satisfied or the expiry date of such claims.

Journey history data will be stored for 3 years, after which the data will be anonymized.

Please note that the deinstallation of Tog app in your device does not cause the deletion of your personal data.

If the Tog app has not been used for 3 years, we will notify you and ask you to confirm whether account is still active. If no reply is received, the account will be closed and personal data will be deleted unless such data is required to be stored for accounting, dispute resolution or fraud prevention purposes.



Deletion

  1. You should also bear in mind that any request to delete your personal data is possible only if we delete your account. As a result of that you will not be able to use Tog app via an account which has been deleted.

We respond to any request for to delete personal data submitted by e-mail within a month and will specify the period of data deletion.



Portability

  1. We will respond to any request for transfer of personal data submitted by e-mail within a month and specify when the data transfer will take place. After we have verified the customer in question, we will provide you with you personal data, which includes: contact information, last 3 years’ journey history and payment information.


Direct Marketing

  1. We will only use your e-mail address and/ or phone number to send direct marketing messages if you have given us permission to do so via the tog.ng website or via the Tog app. We may personalize direct marketing messages using the information how you use Tog services (frequency of use, journeys, payments).

If you no longer wish to receive direct marketing messages, please click the “Unsubscribe” link in the footer of our e-mail or in profile section of the Tog app.



Dispute Resolution

  1. .Disputes relating to the processing of personal data are resolved through customer support (info@tog.ng) or by contacting Tog’s Data Protection Officer (privacy@tog.ng).
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