Driver Privacy Policy

This Driver Privacy Policy explains how Kose Africa (Pvt) Ltd, a subsidiary of Zano Money (Pvt) Ltd ("Kose", "we", "our", or "us") collects, uses, stores, and shares personal information relating to individuals who register and operate as independent driver-partners on the Kose platform ("Drivers" or "you").

As a Driver, you are an independent contractor, not an employee of Kose. However, you entrust us with significant personal and professional data in order to use our platform. We take this responsibility seriously and are committed to handling your information in accordance with applicable data protection laws, including Zimbabwe's Data Protection Act, Zambia's Data Protection Act 2021, and South Africa's Protection of Personal Information Act (POPIA).

By registering as a Kose driver, you acknowledge that you have read and understood this Policy.

2.1 Registration and Onboarding Information

• Full legal name, date of birth, and national identity number
• Residential address and contact details (phone number and email)
• Passport-size photograph and profile photo
• Driver's licence details, including licence number, class, and expiry date
• Vehicle registration details: make, model, year, colour, and registration number
• Certificate of fitness or roadworthy certificate
• Vehicle insurance documentation
• Bank account or mobile money account details for earnings disbursement
• Criminal background check results (where required by law or platform policy)

2.2 Location and Trip Data

• Continuous GPS location data during active driver sessions
• Route data for every trip completed, including pickup and drop-off coordinates
• Time and duration of each trip
• Idle location data when you are online and awaiting trip requests
• Speed and driving behaviour data collected during trips

2.3 Performance and Behavioural Data

• Trip acceptance rate, cancellation rate, and completion rate
• Rider ratings and written reviews submitted about you
• In-app response times and activity patterns
• Complaints or safety reports made against or by you
• Earnings history and payment records

2.4 Device and Technical Data

• Device model, operating system, and unique device identifiers
• Driver app version and usage logs
• Network and connectivity information
• App crash reports and diagnostics

3.1 Onboarding and Verification

• Verifying your identity, licence, and vehicle credentials before activation
• Conducting background checks to ensure platform safety standards
• Ensuring your vehicle meets Kose's minimum requirements
• Complying with local transport authority regulations

3.2 Operating the Platform

• Matching you with nearby ride or delivery requests based on your location
• Calculating fares, commissions, and earnings for each completed trip
• Processing earnings disbursements to your registered account
• Providing navigation assistance and route optimisation
• Facilitating communication between you and riders via anonymised channels

3.3 Safety and Compliance

• Monitoring driving behaviour including speed and route deviations
• Investigating accidents, complaints, or safety incidents involving you
• Sharing your information with law enforcement or regulators when legally required
• Suspending or deactivating accounts that pose safety risks
• Enabling riders to activate the SOS feature, which shares trip data with emergency services

3.4 Performance Management

• Calculating your driver rating based on aggregated rider feedback
• Identifying patterns that affect service quality
• Providing performance insights and tips through the driver app
• Determining eligibility for incentive programmes and bonuses

3.5 Legal and Regulatory Obligations

• Maintaining records required by transport and tax authorities
• Complying with anti-money laundering (AML) and know-your-customer (KYC) requirements
• Responding to valid legal requests from courts or government agencies

Kose requires continuous access to your device's GPS location while you are active on the platform. This is fundamental to how the service works. Location data is used to:

• Show your availability to nearby riders
• Route trip requests to the closest available driver
• Enable real-time trip tracking for rider safety
• Verify that you are operating within your approved service zone
• Resolve disputes about trip routes or distances

5.1 With Riders

When you are matched with a rider, we share your first name, profile photo, vehicle details (make, model, colour, and registration number), and real-time location. Your full phone number is never shared directly with riders; communications are routed through Kose's anonymised calling system.

5.2 With Regulatory and Government Authorities

We may share your driver registration details, licence information, and trip records with transport authorities, the Zimbabwe Revenue Authority (ZIMRA), Zambia Revenue Authority (ZRA), South African Revenue Service (SARS), or law enforcement agencies as required by applicable law, tax obligations, or valid legal orders.

5.3 With Insurance Providers

Trip data including routes, speeds, and timestamps may be shared with vehicle insurance providers in connection with accident claims or coverage assessments.

5.4 With Service Providers

We engage third-party service providers for background checks, payment processing, cloud storage, analytics, and communications. These providers are bound by data processing agreements and may only use your data to perform services on our behalf.

5.5 Emergency Situations

In the event of an accident or emergency reported through the platform, we may share your location, trip details, and contact information with emergency services to ensure your safety and the safety of riders.

After every completed trip, riders are invited to rate their experience and optionally leave written feedback. These ratings are aggregated into your overall driver score, which is visible to riders when they are matched with you. Individual reviews are visible to Kose's internal teams for safety monitoring.

Kose collects and processes financial information to calculate and disburse your earnings. This includes:

• Per-trip earnings based on distance, time, and applicable surcharges
• Platform commission deductions
• Incentive and bonus payments
• Weekly or daily settlement records

We are required to maintain financial records for regulatory and tax compliance purposes and may share earnings summaries with tax authorities as required. You are responsible for declaring your income and paying applicable taxes. Kose may provide earnings statements to assist with this.

We retain driver data for the following periods:

• Account and identity data: duration of active partnership, plus 5 years after termination
• Trip and earnings records: 7 years for tax and regulatory compliance
• Location data: 2 years from the date of the trip
• Background check results: duration of active partnership
• Performance and rating data: duration of active partnership, plus 2 years

After these periods, data is securely deleted or irreversibly anonymised.

Subject to applicable law, you have the following rights regarding your personal data:

• Right to access: request a copy of the personal data we hold about you
• Right to correction: request correction of inaccurate or outdated information
• Right to deletion: request erasure where data is no longer necessary, subject to legal retention obligations
• Right to object: object to certain processing activities, including automated decision-making
• Right to data portability: receive your data in a portable format
• Right to human review: request human review of automated decisions that significantly affect you, such as account deactivation

Some decisions on the Kose platform are made using automated systems, including:

• Trip matching based on proximity, acceptance rate, and availability
• Fare calculation algorithms
• Fraud detection and account security flags
• Eligibility determinations for incentive programmes

Where an automated decision significantly affects your access to the platform or your earnings, you have the right to request a human review of that decision by contacting our Driver Support team.

We apply robust technical and organisational measures to protect your personal data, including:

• Encryption of data in transit (TLS 1.2+) and at rest
• Secure storage of identity documents with restricted access
• Role-based access controls for internal staff
• Regular security assessments and penetration testing
• Audit logs for access to sensitive driver data

In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and the relevant data protection authority within the timeframes required by applicable law.

We may update this Driver Privacy Policy periodically. When we make material changes, we will notify you through the Kose Driver app or by email at least 14 days before the changes take effect. Your continued use of the platform after the effective date constitutes your acceptance of the revised Policy.

For any questions or concerns about this Policy or how we handle your data, please contact our Data Protection Officer:

If you are not satisfied with our response, you have the right to lodge a complaint with your country's data protection authority: