Note to Tujyane: bracketed text marks facts that must be confirmed and inserted before this page is published, and this draft should be reviewed by a lawyer licensed in Rwanda — particularly for registration with Rwanda's National Cyber Security Authority (NCSA) as data protection authority — before it is relied upon.
This Privacy Policy explains how Tujyane Ltd, ("Tujyane," "we," "us," or "our") collects, uses, stores, shares, and protects personal information when you use the Tujyane mobile app, the Tujyane website, the Tujyane Rentals dashboard, and related services (together, the "Platform"). Tujyane is the data controller for the personal information described in this Policy.
This Policy is written to align with Rwanda's Law N° 058/2021 of 13/10/2021 relating to the protection of personal data and privacy, and reflects the personal information we actually collect through the Platform as of the date above.
1. Scope
This Policy applies to passengers, drivers, rental companies and their team members, renters, website visitors, support contacts, and other individuals whose personal information we process in connection with Tujyane. It covers our mobile app (available on iOS and Android), our public website, and the Tujyane Rentals and internal admin dashboards.
2. Information We Collect
We collect the following categories of personal information:
Account and Profile Information
- first and last name
- phone number (used for OTP sign-in and verification)
- email address, where provided or used to sign in
- gender, where provided
- profile photo
- preferred language (English, French, or Kinyarwanda)
- account role(s) — passenger, driver, renter, rental company owner or member, or staff
- if you sign in with Google or Apple, the name and email address those providers share with us to create or match your account
We never store your password in plain text, and one-time verification codes sent by SMS or email are not retained once used.
Identity and Verification Documents (Drivers, Renters, and Rental Companies)
To verify eligibility to drive, rent, or list a vehicle, and to meet our legal and safety obligations, we collect:
- national ID
- driving license (including its expiry date)
- passport, where applicable
- vehicle registration, technical inspection certificate, and vehicle insurance documents (including their expiry dates)
- photographs of the documents above, taken or uploaded by you
- the review status of each document (pending, approved, or rejected) and any reviewer comments
These documents are stored as private files and are only accessible to you, the staff who review them, and — for approved driver/vehicle status — the limited information other users need to trust who they are booking with (see Section 4).
Vehicle and Rental Organization Information
- vehicle plate number, make, model, brand, color, category, mileage, features, and daily/rental pricing
- vehicle photographs, including front, back, and side images for condition verification
- rental organization name, address, logo, and social/contact links
- rental organization membership and role (owner or member) and team-invite records
Trip, Booking, and Location Information
- pickup and drop-off addresses and coordinates
- scheduled departure time, trip start and end time, seats booked, and booking/cancellation history
- estimated and actual route, distance, and duration
- live location data while a trip is active: your device's precise GPS position is shared (as a driver, with passengers on that trip and with Tujyane; as a passenger, with your driver and with Tujyane) to enable real-time trip tracking, arrival notifications, and safety monitoring. Location sampling frequency adapts automatically (for example, more frequent updates near pickup/drop-off, less frequent at highway speed, paused while the device is stationary) using your device's motion sensor;
- background location while a trip you are actively part of is in progress — collection stops when the trip ends or is cancelled;
- driver online/offline availability status and, for rental vehicles, pickup/drop-off district and location; and
- for Ecofleet, aggregate public-transport location and schedule information, which is not linked to your personal account.
Payment and Wallet Information
- in-app wallet balances, top-ups, transfers, gifts, and withdrawal records
- the mobile money phone number or bank account details you provide to top up or withdraw funds
- transaction records, references, and status from our payment processing partners (we do not receive or store full card numbers, as card payments are not currently supported)
- fare, rental-charge, commission, fee, discount, refund, and adjustment records
- downloadable transaction receipts
Communications and Support Information
- messages you send to another user through in-app chat (which may be linked to a specific booking), including message drafts temporarily stored on your device before you send them
- messages you send to our support team
- ratings, reviews, complaints, incident, and safety reports
- attachments, screenshots, or other evidence you submit to us
Device, Technical, and Diagnostic Information
- IP address, device model, operating system, and app version
- device push-notification token, used to deliver booking, wallet, document, and trip notifications through Apple and Google's notification services
- crash and error diagnostic data (via our crash-reporting provider), including a screenshot of the screen at the time of a crash where technically captured, and performance traces. We configure this tool to remove your email address before diagnostic data leaves your device;
- administrative action logs recorded when staff access or change account data, including the staff member's IP address, user agent, and the action taken, for accountability and security purposes; and
- a single functional cookie on our rental/admin dashboards that remembers whether your sidebar is expanded or collapsed. We do not use advertising or cross-site tracking cookies on our web properties.
Information From Other Sources
- Google or Apple, if you choose to sign in using those services (name and email address only)
- other users, such as a rating, review, or safety report submitted about you
- our mobile money, banking, and payment-facilitation partners, to confirm the status of a top-up, transfer, or payout
- law enforcement, regulators, or insurers, where relevant to a safety, fraud, or legal matter
3. How We Use Information
We use personal information to:
- create, verify, and manage user accounts and roles;
- verify identity, driving eligibility, vehicle roadworthiness, and rental-company legitimacy;
- match passengers and drivers, and renters and rental vehicles;
- display routes, ETAs, live trip progress, and booking or rental details;
- calculate fares and rental charges, operate the in-app wallet, and process top-ups, transfers, gifts, and payouts;
- administer cancellation, no-show, and rental damage/return policies;
- send push, SMS, and email notifications about your bookings, wallet activity, and account (see Section 12);
- provide customer support and resolve disputes;
- investigate fraud, abuse, unsafe behavior, and policy violations, and keep the Platform and its users safe;
- diagnose crashes and improve platform reliability and features;
- comply with legal, tax, anti-money-laundering, and regulatory obligations applicable in Rwanda; and
- send transactional notices, safety alerts, and service updates.
Document review, driver approval, and vehicle-listing approval decisions are checked by trained staff; they are not made through fully automated decision-making without human review.
4. How We Share Information
We share personal information in the following situations:
Between Users
- with your driver or passenger for a given trip: name, profile photo, pickup/drop-off details, live location during the trip, vehicle information, and rating;
- with a rental company or renter for a given booking: name, contact details reasonably needed to coordinate handover/return, and booking details;
- approved driver/vehicle status and public ratings are visible to other users so they can decide whether to book with you — we do not show your identity documents, national ID number, or wallet information to other users; and
- a shared-trip link you generate may show limited trip information (start/destination, departure time, driver's first name and rating, and vehicle details) to anyone you send that link to.
With Service Providers
We share information with providers who help us run the Platform, under contracts that limit their use of your information to providing services to us:
- Google (Maps and Routes, for route/ETA calculation) and Mapbox (mapping and navigation)
- Google and Apple (sign-in, and push notification delivery)
- our crash and performance monitoring provider, for diagnosing app issues (with your email address removed before it is sent)
- mobile money operators (including MTN Mobile Money and Airtel Money) and partner banks, to process top-ups and payouts
- cloud hosting and infrastructure providers who store Platform data on our behalf
- customer support tooling providers
For Legal and Safety Reasons
We may share information where reasonably necessary to:
- comply with law, regulation, court order, or a lawful request from a Rwandan authority;
- protect the rights, safety, and property of users or Tujyane;
- investigate accidents, claims, fraud, abuse, or security incidents;
- work with insurers, auditors, or professional advisers.
Business Transfers
We may share information in connection with a merger, acquisition, financing, restructuring, or sale of all or part of our business, subject to the new owner continuing to protect it under a policy at least as protective as this one.
We do not sell personal information to third parties for their own marketing purposes.
5. Legal Bases for Processing
We process personal information on the following bases:
- Performance of a contract — to create your account and provide the ride, rental, and wallet services you request;
- Legal obligation — to meet identity-verification, tax, anti-money-laundering, and regulatory requirements applicable in Rwanda;
- Legitimate interests — to keep the Platform safe, prevent fraud, resolve disputes, and improve our services, balanced against your rights; and
- Consent — for location access, push notifications, camera/photo-library access, and other permissions your device asks you to grant, and for any optional marketing communications. You may withdraw consent at any time through your device settings or by contacting us, though this may limit or disable the related feature.
6. Retention
We retain personal information for as long as reasonably necessary for the purposes described in this Policy, and in any event:
- account and profile information, for as long as your account is active, and for a limited period afterward to handle disputes and legal claims;
- identity and vehicle documents, for as long as needed to verify eligibility, plus any period required by Rwandan road-transport or record-keeping law;
- transaction, wallet, and payout records, for the period required by Rwandan tax, anti-money-laundering, and financial record-keeping rules;
- trip, booking, and rental records (including cancelled or deleted bookings, which we retain in a "soft-deleted" state rather than erasing immediately), for as long as needed for support, dispute resolution, and legal compliance; and
- chat messages and safety reports, for as long as needed to resolve the related booking, dispute, or investigation.
When information is no longer needed for these purposes, we delete it or retain it only in a de-identified or aggregated form.
7. Security
We use technical, administrative, and organizational measures to protect personal information, including: storing your authentication tokens in your device's secure hardware-backed storage (Keychain on iOS, Keystore on Android) rather than in plain app storage; storing identity and vehicle documents as private files accessible only to you and authorized reviewing staff; encrypting data in transit; and logging staff access to user data for accountability. No system is completely secure, and we cannot guarantee absolute security.
8. Your Rights
Under Rwanda's Law N° 058/2021 relating to the protection of personal data and privacy, and depending on your location, you have the right to:
- access the personal information we hold about you;
- correct inaccurate or incomplete information;
- request deletion of your account and personal information, subject to information we are required or entitled to retain (Section 6);
- object to or request restriction of certain processing;
- withdraw consent where processing is based on consent;
- request a copy of certain information in a portable format; and
- lodge a complaint with Rwanda's National Cyber Security Authority (NCSA), the authority responsible for data protection in Rwanda, or another competent supervisory authority.
To exercise these rights, contact us at info@tujyaneltd.com. We may need to verify your identity before acting on a request, and will respond within a reasonable time and in any event within any period required by law. Account deletion is currently handled by our support team on request; a self-service option is planned.
9. Location, Camera, and Notification Permissions
The app requests the following device permissions, each used only for the purpose stated:
- Location (foreground and background): to match you with nearby drivers or vehicles, show live trip tracking, calculate routes and ETAs, and trigger arrival notifications. Background location is only collected while you are actively part of an ongoing trip.
- Camera and photo library: to capture or upload your profile picture, identity and vehicle documents, and vehicle photographs.
- Motion/activity: to detect when your device is stationary so we can reduce how often we sample your location and save battery.
- Notifications: to deliver booking, trip, wallet, document-status, and chat alerts. You can manage which notifications you receive in the app's notification settings, and can disable notifications entirely through your device settings.
You can withdraw any of these permissions at any time through your device settings; doing so may disable the related feature (for example, disabling location will prevent live trip tracking).
10. Cookies and Similar Technologies
Our public website does not use analytics, advertising, or cross-site tracking cookies. Our Rentals and admin dashboards set a single functional cookie that remembers your sidebar display preference; this cookie does not identify you or track you across sites. Authentication is handled separately through secure session tokens rather than tracking cookies.
11. Children's Privacy
Tujyane is not intended for and may not be used by anyone under 18 years old. We do not knowingly collect personal information from children. If you believe a child has created an account or provided personal information to us, contact us at info@tujyaneltd.com so we can investigate and, if appropriate, delete that information.
12. Marketing and Notification Choices
Most notifications we send (booking, trip, wallet, and document-status alerts) are transactional and necessary to operate your account; you cannot opt out of these while keeping your account active, though you can adjust delivery channels where the app offers that choice. Where we send optional marketing or promotional messages, you may opt out at any time using the unsubscribe/preference option provided or by contacting us.
13. International Data Transfers
We primarily store and process personal information on infrastructure used to operate the Platform. Some of our service providers (for example, mapping, sign-in, notification-delivery, and crash-reporting providers such as Google, Apple, and our monitoring vendor) may process data outside Rwanda. Where personal information is transferred outside Rwanda, we take steps required by Rwandan law to ensure it continues to receive an appropriate level of protection, including through contractual safeguards with those providers.
14. Automated Decision-Making
We do not make decisions producing legal or similarly significant effects about you (such as rejecting a driver, vehicle, or document application, or suspending an account) using fully automated processing without human review. Document and listing approvals are checked by trained staff.
15. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the app or by email before the changes take effect and will update the "Last updated" date above. We encourage you to review this Policy periodically.
16. Contact Us
If you have questions about this Privacy Policy or our data practices, or wish to exercise any of the rights in Section 8, contact us at info@tujyaneltd.com