Tsamai Ltd (“Tsamai”, “we”, “us”, or “our”) is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, disclose, transfer, and safeguard personal data when you use our mobile applications, websites, and related services available at https://www.tsamai.com (collectively, the “Platform” or “Service”), or when you contact us.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Platform.

1. Who This Policy Applies To

Tsamai is a city-to-city seat-sharing platform. Users include:

  • Drivers: independent individuals who publish trips and provide transportation using their own vehicles
  • Passengers: individuals who book seats on those trips

Drivers and passengers are collectively referred to as “users”, “you”.

2. Who We Are and Our Role

2.1 Data Controller

Unless stated otherwise, Tsamai Ltd is the data controller for personal data processed in connection with your use of the Platform (meaning we decide why and how your personal data is processed).

2.2 When Tsamai Acts as a Processor

In limited cases, Tsamai may process personal data as a processor on behalf of another controller (for example, where an organisation arranges travel for staff and supplies data to Tsamai). If that applies, you will be provided a project-specific notice.

3. Contact and Data Protection Requests

Questions, comments, and requests regarding this Privacy Policy are welcomed.

Privacy contact (Data Protection): support@tsamai.com (please use the subject line: “Privacy Request”).

4. Scope

This Privacy Policy applies when you use:

  • the Tsamai website (tsamai.com)
  • the Tsamai mobile apps
  • Tsamai support channels (email, in-app chat, and WhatsApp integrations where enabled)

This Privacy Policy does not cover how we process personal data relating to candidates, employees, or business-to-business contacts, except where required by law.

5. What Information We Collect

We collect three categories of information about you:

  1. Information you provide
  2. Information we collect automatically
  3. Information we obtain from other sources

We do not intentionally collect special category data (e.g., racial origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data used for identification, health data, or sexual orientation) unless required for legal, safety, or fraud-prevention reasons and permitted by law.

5.1 Information You Provide

A) Account and Profile Information

  • First name and surname
  • Phone number
  • Email address
  • Country and city
  • Profile photo (optional)
  • Account preferences and settings

B) Driver Verification and Vehicle Information (Drivers)

If you register as a driver, we may collect:

  • Proof of identity (e.g., ID number or document details)
  • Driver licence details (where required)
  • Vehicle details (make, model, colour, year, registration/plate details)
  • Vehicle images and relevant documents
  • Emergency contact details (optional but recommended)

Without required verification information, you may not be able to register or publish trips as a driver.

C) Trip, Booking, and Route Information

  • Origin and destination
  • Trip date/time
  • Seats offered/booked
  • Luggage and preferences
  • Trip notes (e.g., pickup guidance)
  • Trip status events (created/confirmed/cancelled/started/completed)

D) Wallet and Transaction Information

  • Wallet balance and ledger activity
  • Top-ups, deductions, refunds
  • Internal transfer records (where enabled)
  • Transaction references and receipt metadata

Important: Tsamai does not store full payment card details. Payment data is handled by payment processors under their own security standards.

E) Communications and Support

  • Messages sent through in-app chat
  • Messages sent via WhatsApp integrations (where enabled)
  • Emails and attachments
  • Support metadata (time/date and issue details)

F) User Generated Content

  • Ratings and reviews
  • Comments, reports, complaints
  • Uploaded photos/documents (e.g., verification)

5.2 Information We Collect Automatically

A) Location Information

We collect location data to enable trips, safety features (including trip sharing), fraud prevention, and customer support.

  • Passengers: precise location may be collected when the app is in use and during an active trip (subject to permissions). You can also enter pickup/drop-off manually in some cases.
  • Drivers: precise location may be collected when driver mode is active, while online, during an active trip, and for a limited time afterwards to support incident resolution and safety.

Location collection depends on your device settings and permissions.

B) Device and Network Information

  • Device model, manufacturer
  • Operating system and version
  • App version/build
  • IP address
  • Network type and carrier
  • Time zone and language
  • Identifiers used for fraud prevention and analytics (where permitted)

C) Usage and Diagnostics

  • App interaction events (screens viewed, feature usage)
  • Crashes, logs, and performance metrics
  • Timestamps and session activity
  • Security signals to detect abuse

D) Cookies (Website)

Our website may use cookies or similar technologies to keep you logged in (where applicable), remember preferences, and measure website performance and usage. You can manage cookies via your browser settings.

5.3 Information We Obtain From Other Sources

We may obtain information from:

  • Payment processors (transaction confirmation, chargeback status)
  • Identity verification vendors (verification result signals)
  • Fraud and risk services
  • Other users (reviews, incident reports)
  • Lawful requests from authorities where required

6. How We Use Your Information

We use personal information for the purposes below.

6.1 Providing and Operating the Platform

  • Creating and managing accounts
  • Enabling trip publishing, booking, and coordination
  • Enabling wallet payments and refunds
  • Enabling communications between users
  • Providing trusted contact and trip-sharing features (Warindi)

Legal basis: performance of contract; legitimate interests; legal obligation (where applicable).

6.2 Safety, Security, and Fraud Prevention

  • Verifying driver eligibility and authenticity
  • Preventing misuse, fraud, and harmful activity
  • Investigating incidents and complaints
  • Enforcing Platform rules and Terms of Use

Legal basis: legitimate interests; legal obligation; vital interests (where applicable).

6.3 Improving and Developing the Platform

  • Research and analytics
  • Service performance monitoring
  • Feature development and testing
  • Debugging and incident response

Legal basis: legitimate interests (and consent where required).

6.4 Communications

  • Service notices (bookings, cancellations, safety alerts)
  • Support responses and operational messages
  • Marketing communications (where permitted, and opt-out available)

Legal basis: performance of contract; legitimate interests; consent (where required).

6.5 Compliance and Legal Protection

  • Responding to lawful requests
  • Meeting tax and audit obligations
  • Protecting Tsamai’s legal rights and users’ safety

Legal basis: legal obligation; legitimate interests.

7. Automated Decision-Making

We may use automated systems to help detect fraud and unusual behaviour, recommend fares or route suggestions, match trip requests with available trips, and flag accounts or trips for review. Where required by law, decisions with significant effects (such as permanent deactivation) will be subject to appropriate safeguards, including review and/or a route to appeal.

8. How We Share Your Information

We share personal data only as needed for the Platform to function, for safety, or for legal reasons.

8.1 Sharing With Other Users (Drivers/Passengers)

To enable a trip:

  • Passengers may see driver name, vehicle details, ratings, and trip status; during an active trip, they may see live location where enabled.
  • Drivers may see passenger name, booking details, pickup/drop-off guidance, and contact details where required for coordination.

8.2 Trusted Contacts / Trip Sharing (Warindi)

If you enable trip sharing, we may share with the contacts you choose: trip route summary, trip status (e.g., started/completed), live location (where enabled), and driver and vehicle details relevant to the trip.

8.3 Vendors and Service Providers

We may share limited data with providers who support payment processing, cloud hosting, messaging (push notifications, email, WhatsApp delivery), identity verification, fraud prevention, analytics, monitoring, and professional services (legal, auditing, accounting). These vendors are required to protect data and act under contractual obligations.

8.4 Legal Disclosures

We may disclose information if required to comply with law, regulation, or court order, respond to lawful requests, protect rights and safety, or prevent fraud and credit risk.

8.5 Corporate Transactions

If Tsamai is involved in a merger, acquisition, or asset transfer, personal data may be transferred as part of that transaction, subject to appropriate safeguards.

8.6 Aggregated/Anonymised Data

We may share aggregated or anonymised data that no longer identifies you personally.

9. Cross-Border Data Transfers

Tsamai may process data in countries other than your country of residence to support global operations. Where required, we use appropriate safeguards to protect your personal data.

10. Data Retention

We keep personal data only as long as necessary for the purposes described in this policy.

  • Account data: while your account is active, and for a reasonable period afterwards for support, fraud prevention, and compliance.
  • Trip and transaction records: retained as required for financial and tax compliance and dispute handling.
  • Support communications: retained as needed to manage issues and demonstrate compliance.
  • Verification records: retained for safety, compliance, and fraud prevention purposes.

We may retain data longer where a legal obligation requires it, there is an ongoing dispute or investigation, or retention is necessary to prevent fraud and ensure safety.

11. Your Rights

Depending on your location and applicable law, you may have the right to request access to your personal data, request correction, request deletion (erasure) in certain circumstances, object to processing based on legitimate interests, request restriction, request data portability (where applicable), and withdraw consent (where processing is based on consent).

To exercise these rights, contact us at support@tsamai.com with the subject “Privacy Request”. We may need to verify your identity. Some requests may be limited where we must keep data to meet legal obligations or for safety and fraud prevention.

12. Managing Your Choices

  • Location permissions: You can control location access through your device settings. Some features may not function without location access.
  • Marketing: You can opt out of marketing communications using the unsubscribe mechanism (where provided) or by contacting support.
  • Push notifications: You can disable push notifications in device settings or in-app settings (where available).
  • Cookies: You can disable cookies in your browser settings, but parts of the website may not work properly.

13. Information Security

We take information security seriously and implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. However, no transmission over the internet is completely secure. While we take commercially reasonable steps to protect data, we cannot guarantee absolute security.

14. Children’s Privacy

The Platform is not directed to children as defined under applicable local laws. If we learn we have collected personal data from a child, we will take steps to delete it.

15. Third-Party Links

The Platform may contain links to third-party websites or services. We are not responsible for third-party privacy practices. Please review their policies separately.

16. Changes to This Policy

We may update this Privacy Policy from time to time. We will update the “Last updated” date and post the revised policy on the Platform. Continued use indicates acceptance of the latest version.

17. Contact Us

Email: support@tsamai.com