Privacy Policy

Pair Mobility is a technology-enabled shared commuter service operating in Lagos, Nigeria. Our platform connects passengers travelling along fixed high-demand corridors via a mobile or web app that enables seat booking, identity verification, and cashless payment.

For all data-related enquiries, you may contact us at: privacy@pairmobility.com

We collect the following categories of personal information:

• Account Information: Full name, phone number, email address, and date of birth provided during registration.
• Biometric Data: A selfie or headshot photograph used exclusively for identity verification at the point of boarding. This is processed to confirm that the person boarding matches the registered account holder.
• Payment Information: Payment is processed securely through Paystack. Pair does not store your card details. Paystack retains payment data in accordance with its own PCI-DSS-compliant privacy policy.
• Location Data: We collect your location only when the app is actively in use, specifically during booking to identify nearby pickup clusters and during live trips for safety tracking. We do not collect location data in the background when the app is closed.
• Trip & Usage Data: Records of your bookings, routes, travel history, and in-app behaviour used to improve the service.
• Device Information: Device type, operating system, and app version to ensure technical compatibility and security.

We collect and process your data for the following purposes:

• To create and manage your Pair account
• To verify your identity at the point of boarding using facial recognition technology
• To process your bookings and payments
• To communicate with you about your trips, updates, and service changes
• To ensure the safety of all passengers and drivers on the platform
• To comply with applicable Nigerian law and regulatory requirements
• To improve the Pair app and overall user experience through anonymised analytics

We will not use your personal data for any purpose not listed above without first obtaining your explicit consent.

The Pair platform is intended for users who are 18 years of age or older. By registering, you confirm that you meet this age requirement. If we discover that a user is under 18, we will promptly suspend the account and delete associated personal data.

Your data is stored on encrypted cloud servers hosted by reputable third-party cloud infrastructure providers (such as Amazon Web Services or Google Cloud). The following storage principles apply:

• All data in transit and at rest is encrypted using industry-standard protocols
• Biometric data (selfie and facial recognition data) is stored separately from general profile information, in a higher-security environment with stricter access controls
• Payment data is not stored by Pair; it is held by Paystack under its own security framework
• Trip and booking records are retained for up to 24 months from the date of each trip, after which they are anonymised or deleted
• Biometric data is retained only for the duration of an active account and deleted within 30 days of account closure

Access to your personal data is strictly controlled. The following parties may have access:

• Pair's internal team - for operations, customer support, safety investigations, and dispute resolution. Access is role-based; not all staff can view all data categories.
• Drivers - limited access only. Drivers see your name, pickup cluster, and the result of the facial verification check (match or no match). Drivers do not have access to your full profile, payment details, or contact information.
• Paystack - our payment processing partner, for handling and verifying transactions.
• Cloud infrastructure providers - for data hosting and storage. These providers operate under data processing agreements with Pair.
• Facial recognition / AI verification vendors - third-party technology providers who process biometric data on our behalf for identity matching at boarding. These vendors are bound by strict data processing agreements and may not use your data for any other purpose.
• Regulatory and law enforcement authorities - only when we are legally required or compelled to disclose information, and only to the extent required by law.

Pair may share data with the following types of partners, subject to the conditions described:

• Commercial partners (e.g. pickup point venues): We may share anonymised, aggregated data, such as passenger volume at specific locations, with venue partners for operational planning. No personally identifiable information is shared in this context.
• Urban planning and research partners: At scale, Pair intends to share anonymised and aggregated mobility intelligence with urban planners, government agencies, or research institutions. This data will never include personal identifiers.
• Future commercial partners: If Pair enters into partnerships that require sharing personal data, we will notify users and obtain appropriate consent before doing so.

Pair does not sell your personal data. Ever.

Pair takes the security of your personal information seriously. Our security measures include:

• End-to-end encryption for all data in transit and at rest
• Role-based access controls limiting which staff can access which data categories
• Multi-factor authentication for all internal systems
• Regular security audits and penetration testing
• Biometric data stored in an isolated, higher-security environment
• A formal incident response plan. In the event of a data breach, affected users will be notified within 72 hours of discovery, in accordance with NDPR requirements

Despite our best efforts, no system is entirely immune to risk. We encourage you to use a strong password and to report any suspicious activity to us immediately at security@pairmobility.com.

Pair accesses your device location only when the app is actively open and in use. We do not track your location in the background when the app is closed or not in active use.

Location access is used solely to:

• Help you identify the nearest pickup cluster during booking
• Monitor trip progress for safety purposes during a live journey

You may revoke location permissions at any time via your device settings. Note that revoking location access may limit certain features of the app.

As a data subject under the Nigeria Data Protection Regulation (NDPR), you have the following rights:

• The right to access the personal data Pair holds about you
• The right to correct inaccurate or incomplete data
• The right to request deletion of your data ("right to be forgotten"), subject to legal obligations
• The right to object to how your data is being used
• The right to data portability - receiving a copy of your data in a structured, machine-readable format
• The right to withdraw consent at any time, where processing is based on consent

To exercise any of these rights, contact us at privacy@pairmobility.com. We will respond within 30 days of receiving your request.

We may update this Privacy Policy from time to time as our service evolves or as required by law. When we make material changes, we will notify you via the app and update the effective date at the top of this document. Continued use of the Pair app after such changes constitutes your acceptance of the revised policy.

If you have questions, concerns, or requests relating to this Privacy Policy, please contact:

• Email: privacy@pairmobility.com
• Address: Pair Mobility, Lagos, Nigeria