Privacy and Personal Data Protection Policy

This Privacy Policy explains how ROBY® Technologies collects, uses, retains, protects and shares the personal data of Users of its website, mobile applications and related services.

It applies in particular to Passengers, Taxi Drivers, Tourist Transport Drivers, holders of approvals or operating authorisations, vehicle owners and operators, representatives of transport companies, professional partners and any person communicating with ROBY.

This Policy supplements the Platform’s General Terms of Use. It must be read together with the specific information presented when using a feature, payment method or service subject to particular rules.

ROBY undertakes to collect only the data necessary for the operation of the Platform, User safety, connecting Passengers and Drivers, compliance with regulations and improvement of its services.

ROBY does not sell, rent or transfer its Users’ personal data for commercial purposes.

A long-standing commitment to data protection and data sovereignty

ROBY has made data protection and data sovereignty founding principles of its activity.

As early as 2018, well before mobility applications became widespread in Morocco, ROBY Technologies began compliance procedures with the National Commission for the Control of Personal Data Protection (CNDP) concerning the processing of data through its application.

This process resulted in the issue, on 4 February 2019, of CNDP declaration receipt No. D-GC-551/2018, corresponding to declaration No. D-551/2018 filed on 15 October 2018, for processing entitled “Data processing by application” for the purpose of “Customer management”.

This pioneering approach reflects ROBY Technologies’ intention to develop a Moroccan mobility solution founded, from the outset, on compliance, trust, security and the protection of personal data.

Under ROBY’s current architecture, the principal databases, mobility data under ROBY’s control and their backups are hosted in Morocco in a sovereign cloud based on a sovereign data centre located in Moroccan territory.

This architecture is an essential component of the ROBY model. It keeps the hosting, control, governance and strategic value of data generated by Moroccan mobility in Morocco.

Data sovereignty does not consist solely of hosting data in Morocco. It also means controlling its use, preventing its commercial appropriation by foreign platforms and ensuring that it benefits Drivers, Passengers, institutions and the Moroccan ecosystem.

This Policy is drawn up in accordance, in particular, with:

• Moroccan Law No. 09-08 on the protection of individuals with regard to the processing of personal data;
• Decree No. 2-09-165 implementing Law No. 09-08;
• the decisions, recommendations and formalities of the CNDP;
• Law No. 31-08 laying down consumer-protection measures;
• EU Regulation 2016/679, known as the General Data Protection Regulation or “GDPR”, where applicable;
• national rules on data protection, electronic communications and direct marketing applicable in the countries where ROBY offers its services.

Article 1. Data controller and scope

1.1 Identity of the Data Controller

The controller responsible for processing carried out for the operation of the Platform is:

ROBY® Technologies, a limited liability company with share capital of 50,000 dirhams

Registered office: 474, Office 13, Sidi Ghanem Industrial District, 40000 Marrakech, Morocco

Commercial Register of the Marrakech Court: 89879

Tax identification number: 26058229

Business tax number: 64000465

Contact: contact form on roby.taxi

For any question relating to personal data protection, the User may write via the contact form with the subject line: “Personal data protection”.

1.2 CNDP Reference

The initial data processing carried out through the ROBY application was covered by CNDP receipt No. D-GC-551/2018, issued on 4 February 2019 following declaration No. D-551/2018 filed on 15 October 2018.

The name of the processing declared to the CNDP is: “Data processing by application”.

The purpose initially declared is: “Customer management”.

This declaration forms the historical foundation of ROBY Technologies’ compliance approach. It does not exempt ROBY from complying with all provisions of Law No. 09-08 and its implementing legislation. The receipt covers the declared processing within the limits of its stated purpose and scope. Any new category of data, new purpose, interconnection of files or material change is subject to the necessary formalities. Additional processing relating in particular to Driver verification, CIN numbers, trust permits, approvals, operating authorisations, geolocation data, fraud prevention, payments, security incidents and any sensitive data is declared, authorised or updated with the CNDP where required by law.

View the CNDP declaration receipt

1.3 Territorial Application

This Policy forms ROBY’s common data-protection framework.

Where ROBY offers its services in another country, this Policy may be supplemented by local provisions specifying, in particular, the responsible entity, the local representative’s contact details, the competent supervisory authorities, the applicable legal bases and the specific rights granted to Users.

Where ROBY offers services to persons located in the European Union or monitors their behaviour in connection with those services, the GDPR and the national rules applicable in the country concerned are observed.

The mandatory provisions of the country in which the Service is offered prevail over any incompatible provision of this Policy.

Article 2. Roles of the different parties

2.1 ROBY Technologies

ROBY determines the purposes and means of processing necessary for:

• creating and managing accounts;
• verifying Drivers, vehicles and authorisations;
• connecting Passengers and Drivers;
• managing Rides;
• securing the Platform;
• preventing fraud;
• assisting Users;
• managing payments and Driver Credits;
• managing complaints and incidents;
• improving services;
• complying with its legal obligations.

2.2 Drivers, Approval Holders and Operators

The Driver, approval holder, owner, tourist transport company or authorised operator may be responsible for processing carried out for their own professional needs, in particular to perform the transport service, meet accounting, tax, social security, insurance or regulatory obligations, and handle their own complaints.

These persons may use data obtained through ROBY only to perform the Ride, ensure safety, manage an incident, return a forgotten item or comply with a legal obligation.

They are not authorised to reuse the Passenger’s contact details to solicit or contact the Passenger personally, create their own marketing database or offer services outside the Platform without an appropriate lawful basis.

2.3 Payment Service Providers

Banks, payment institutions, electronic money institutions, mobile-wallet operators and other authorised financial service providers may act as independent controllers for processing required for customer identification, fraud prevention, anti-money laundering, payment processing, refunds and their own regulatory obligations.

Their privacy policies and special terms are provided when their services are used.

Article 3. Personal data collected

3.1 Identity and Contact Data

ROBY may collect:

• first name and surname;
• telephone number;
• email address;
• postal address;
• date of birth;
• nationality where necessary for a regulatory check;
• profile photograph;
• preferred language;
• information provided to customer support.

3.2 Account and Authentication Data

ROBY may collect:

• the account’s internal identifier;
• account creation, login and last-activity dates;
• verification codes and authentication information;
• account preferences and settings;
• the history of acceptances of the Terms and Privacy Policy;
• authorised devices and security events;
• login and account-recovery attempts.

ROBY does not retain passwords in plain text.

3.3 Data Relating to Drivers and Transport Professionals

To verify that a Driver is operating lawfully, ROBY may collect:

• a copy of the national identity card, passport or equivalent document;
• the identity-document number;
• the driving licence and its validity dates;
• the trust permit, professional card or any equivalent authorisation;
• the taxi approval, licence or operating authorisation;
• the identity and contact details of the approval holder;
• documents establishing the relationship between the Driver, approval holder, owner and vehicle operator;
• authorisations specific to tourist transport;
• the name of the company or operator with which the Driver is affiliated;
• necessary professional, tax, social security or accounting information;
• insurance certificates;
• vehicle and roadworthiness inspection documents;
• information concerning the validity, suspension or withdrawal of authorisations;
• bank details or payment identifiers required for remittances;
• information relating to the Driver account, its Credits and transactions.

The CIN number, data relating to offences or other categories subject to authorisation may be collected only after completion of the required formalities with the CNDP.

3.4 Vehicle Data

ROBY may collect:

• the vehicle’s make, model, year, colour and category;
• registration number;
• registration certificate;
• chassis number where required for verification;
• number of seats;
• photographs of the vehicle;
• insurance and roadworthiness inspection information;
• accessibility equipment;
• authorised transport category;
• identity of the owner or operator;
• changes of vehicle and replacement vehicles.

3.5 Ride Data

ROBY may collect:

• the pickup location;
• the destination;
• the date and time of the request;
• the route, distance and duration;
• the identity of the Driver and Passenger concerned;
• the assigned vehicle;
• acceptance, arrival, departure and Ride-completion times;
• changes of destination and intermediate stops;
• the price, its estimate or calculation method;
• surcharges, tolls, waiting fees and cancellation fees;
• the payment method;
• the Ride status;
• cancellations and no-shows;
• ratings and comments;
• forgotten items;
• related complaints, incidents and supporting documents.

Where a person books a Ride for a third party, that person must ensure that they are authorised to provide the necessary information about the third party and must inform the third party of the use of their data.

3.6 Geolocation Data

ROBY may process the precise or approximate location of the telephone:

• of the Passenger when using the search function, specifying a pickup location, tracking the Driver’s arrival, taking a Ride or using a safety feature;
• of the Driver when online, available, approaching, waiting or on a Ride;
• where the Platform needs to detect an inconsistency, secure a Ride, handle a complaint or prevent fraud.

When the Driver is online or performing a Ride, geolocation may continue to operate in the background, including when the application is not displayed on screen, to the extent necessary for matching, Ride tracking and safety.

ROBY is not intended to track a User continuously when the User is not using the Service or, in the case of a Driver, when the Driver is offline from the Platform.

The User can manage geolocation permissions in the telephone settings. Refusing or disabling geolocation may prevent certain features from operating or prevent the receipt of Rides.

3.7 Payment and Financial Data

ROBY may collect:

• the selected payment method;
• the amount and currency;
• the date, time and reference of the transaction;
• payment status;
• refunds, cancellations and chargebacks;
• top-ups and withdrawals;
• Driver Credit entries;
• commissions and fees due;
• bank details required for remittances;
• identifiers or technical tokens provided by the payment service provider.

Full payment-card details are, in principle, collected and processed directly by the authorised payment service provider. ROBY is not intended to retain the complete card number or its security code.

3.8 Communications and Support

ROBY may collect:

• the content of messages exchanged within the Platform;
• exchanges with customer support;
• emails and attachments;
• call metadata, such as date, time and duration;
• reports, complaints, statements and responses;
• photographs, videos or documents submitted voluntarily.

A call may be recorded only if the participants are informed in advance and the recording is based on an appropriate lawful basis.

ROBY does not activate the telephone’s microphone to listen to or continuously record conversations inside the vehicle.

3.9 Technical Data

ROBY may collect:

• the IP address;
• the device type and model;
• the operating system;
• the application version;
• language and time zone;
• technical or advertising identifiers where their use is authorised;
• connection logs;
• error and crash reports;
• application performance data;
• security events;
• data necessary to detect compromised devices or fraudulent use.

3.10 Safety, Incident and Fraud Data

ROBY may process:

• reports of accidents, assaults, threats, harassment or discrimination;
• photographs or videos provided as evidence;
• information relating to police or authority intervention;
• damage caused to the vehicle;
• User reports;
• unusual behaviour detected on the Platform;
• location or payment inconsistencies;
• attempted identity theft;
• falsified documents;
• internal-check results;
• suspension decisions and challenges.

Where this information reveals data relating to health, an offence, a conviction or a security measure, ROBY applies enhanced safeguards and completes the specific formalities required.

3.11 Sensitive Data and Special Needs

A Passenger may choose to report a special need, such as reduced mobility, the need for an adapted vehicle or the presence of an assistance animal.

ROBY collects this information only where necessary to provide the Service, with the person’s explicit consent where required and after completing the applicable legal formalities.

ROBY does not request a detailed medical diagnosis where it is unnecessary.

Profile photographs and identity documents are not used for biometric or facial recognition unless a separate feature is subsequently offered after specific information has been provided to the persons concerned, the required authorisations have been obtained and appropriate safeguards have been implemented.

3.12 Sources of Data

Data may come from:

• the User directly;
• the telephone or device used;
• a Passenger booking for a third party;
• the Driver or transport company;
• the approval holder, owner or vehicle operator;
• payment service providers;
• technical service providers;
• competent authorities or bodies where disclosure is legally authorised;
• fraud-detection and security systems;
• other Users in connection with a rating, complaint or incident.

Article 4. Purposes and lawful bases of processing

4.1 Account Creation and Management

Data are processed to:

• create the account;
• verify the telephone number or email address;
• authenticate the User;
• manage the User’s preferences;
• enable account recovery;
• retain evidence of acceptance of the Terms.

This processing is necessary to establish and perform the contractual relationship, secure the Platform and comply with applicable legal obligations.

4.2 Verification of Drivers, Vehicles and Authorisations

Data are processed to:

• verify the Driver’s identity;
• verify the Driver’s driving licence and trust permit;
• verify the approval, licence or operating authorisation;
• identify the approval holder;
• verify the relationship between the Driver, vehicle, owner and operator;
• verify tourist transport authorisations;
• verify insurance and roadworthiness inspection;
• prevent the use of false documents;
• suspend accounts whose documents have expired or are invalid.

This processing is necessary for safety, the lawful operation of the Platform, performance of the contract, fraud prevention and compliance with regulatory obligations.

4.3 Connecting Users and Performing Rides

Data are processed to:

• identify available Drivers;
• calculate their proximity and estimated arrival time;
• transmit the Ride request;
• allow the Passenger to select a Driver;
• display information identifying the Driver and vehicle;
• organise pickup;
• provide navigation;
• track the Ride;
• calculate or verify the price;
• manage changes, cancellations and no-shows;
• create the Ride history;
• enable the return of a forgotten item.

This processing is necessary to provide the requested Service and perform contracts entered into through the Platform.

4.4 Geolocation

Geolocation is used to:

• suggest a pickup location;
• display available Drivers;
• calculate distance and approach time;
• assign or present Ride requests;
• allow the Passenger to track the Driver’s arrival;
• provide navigation;
• calculate distance and duration;
• ensure Ride tracking and safety;
• enable voluntary route sharing;
• handle complaints;
• detect inconsistencies and prevent fraud.

Where geolocation is not strictly necessary for the Service or safety, it is based on the User’s consent and the permissions selected in the User’s telephone.

4.5 Payments, Credits and Accounting

Data are processed to:

• initiate and confirm a payment;
• record a cash payment;
• manage licence fees and commissions;
• maintain the Driver Credit history;
• carry out top-ups, remittances or refunds;
• process cancellations and chargebacks;
• prevent fraud;
• prepare supporting documents and accounting entries;
• comply with tax and regulatory obligations.

This processing is necessary for performance of the contract, compliance with legal obligations and the defence of the financial rights of ROBY and Users.

4.6 Support, Safety and Incident Management

Data are processed to:

• respond to support requests;
• verify facts relating to a Ride;
• handle accidents, assaults, threats, discrimination or forgotten items;
• protect Users;
• investigate a breach of the Terms;
• retain necessary evidence;
• take security measures;
• cooperate with authorities where required by law.

Depending on the circumstances, this processing is based on performance of the contract, protection of persons, compliance with a legal obligation, consent or ROBY’s legitimate interest in securing the Platform and defending its rights.

4.7 Fraud Prevention and Information Security

Data are processed to:

• detect false accounts and false documents;
• prevent identity theft;
• detect fictitious Rides;
• identify manipulation of prices, locations or payments;
• protect accounts;
• detect unauthorised access;
• prevent cyberattacks;
• secure systems and transactions.

This processing is based on ROBY’s security obligations and its legitimate interest in protecting the Platform, its Users and its partners.

4.8 Ratings and Service Quality

Data are processed to:

• enable mutual ratings;
• verify the quality and safety of Services;
• identify serious or repeated conduct;
• improve Driver training and support;
• measure satisfaction;
• improve the application.

Ratings must not be used alone to make a final decision producing a significant effect without an opportunity for review and challenge.

4.9 Marketing Communications

With the User’s consent where required, ROBY may use the User’s email address, telephone number or application notifications to:

• present new features;
• send promotional offers;
• provide information about loyalty or referral programmes;
• offer partner services.

The User may withdraw consent or unsubscribe at any time.

Messages essential to account operation, security, Rides or payments are not marketing communications and may continue to be sent while the account remains active.

4.10 Statistics, Research and Improvement

ROBY may use aggregated or anonymised data to:

• produce mobility statistics;
• analyse Service quality;
• improve routes and arrival times;
• improve safety;
• develop new features;
• conduct economic or operational studies;
• help public authorities understand mobility needs where such sharing is legally authorised.

Once data have been effectively and irreversibly anonymised, they can no longer identify a User and are no longer personal data.

No data directly identifying a User are disclosed to an administration, local authority or partner for statistical purposes without a lawful basis, authorisation or appropriate information.

Article 5. Telephone permissions and mobile features

The application may request access to:

• location, to find a Driver, organise a Ride, provide navigation and ensure safety;
• the camera, to photograph a document, vehicle or supporting item;
• the photo library, to submit a document or evidence selected by the User;
• the microphone, only where a feature selected by the User requires recording a message or making a call;
• notifications, to provide information about the Driver’s arrival, the progress of a Ride, a payment or a safety message;
• the telephone, to enable a call to a Driver, Passenger, customer support or emergency service;
• contacts, only if the User selects a feature that requires choosing a trusted contact.

ROBY does not upload the entire address book where only the selection of one contact is necessary.

The User may change permissions in the telephone settings. Certain features may cease to operate if an essential permission is withdrawn.

Article 6. Recipients of data

Data are accessible only to persons and bodies that need to know them for a specified purpose.

6.1 ROBY Personnel and Group Companies

Data may be accessible to authorised employees responsible for:

• customer service;
• Driver verification;
• security;
• fraud prevention;
• payments;
• accounting;
• legal affairs;
• technical maintenance;
• management, within the limits of its responsibilities.

Access is restricted according to the functions performed and is subject to control measures.

6.2 Information Shared Between Passenger and Driver

When a match is made, the Driver may receive:

• the Passenger’s first name or pseudonym;
• the pickup location;
• the destination or information necessary for the Ride;
• the number of Passengers;
• any special needs communicated;
• a temporary or protected means of communication.

The Passenger may receive:

• the Driver’s name and photograph;
• the Driver’s professional category;
• information identifying the vehicle;
• the registration number;
• the estimated arrival time;
• certain reputation or quality information where this feature is offered.

ROBY limits this information to what is necessary for identification, safety and performance of the Ride.

6.3 Technical Service Providers

Data may be entrusted to service providers supplying:

• sovereign hosting and storage in Morocco;
• mapping and navigation;
• the sending of SMS messages, notifications and emails;
• protected telephone communications;
• customer support;
• analysis of performance and technical incidents;
• cybersecurity;
• document verification;
• fraud prevention;
• payment and financial services.

These providers access data only to the extent necessary for their assignment. They are bound by contractual obligations concerning confidentiality, security, purpose limitation and the deletion or return of data.

An up-to-date list of the main categories of providers and, where required, their identity and country of establishment may be obtained by writing via the contact form.

6.4 Competent Authorities and Bodies

ROBY may disclose data:

• where required by law or a court decision;
• in response to a lawful request from a competent authority;
• to report an offence or serious danger;
• to defend its rights in legal proceedings;
• to protect a person’s life, physical integrity or safety;
• to administrative authorities responsible for verifying taxis, tourist transport vehicles, approvals, trust permits and operating authorisations.

To the extent possible, ROBY verifies the lawful basis, competence and scope of any request before disclosing data.

6.5 Insurers, Advisers and Professional Partners

Strictly necessary data may be disclosed:

• to insurers;
• to lawyers, experts and statutory auditors;
• to approval holders;
• to owners or authorised operators;
• to tourist transport companies;
• to banks and financial service providers;
• to partners directly involved in handling a complaint or incident.

No partner may use these data for its own marketing campaigns without a lawful basis and appropriate information being provided to the persons concerned.

6.6 No Sale of Data

ROBY Technologies does not sell, rent or exchange its Users’ personal data for payment.

ROBY Technologies does not disclose Users’ individualised routes to advertisers.

Data generated by mobility may not be used by a partner to create its own commercial database or take control of the relationship between ROBY Technologies and its Users.

Article 7. Data sovereignty and hosting in Morocco

7.1 Principle of Sovereignty

Data sovereignty is a central commitment of ROBY Technologies.

The principal data processed by ROBY, including data relating to accounts, Drivers, Passengers, vehicles, approvals, Rides, routes, professional documents, transactions and incidents, together with their backups, are hosted in Morocco in a sovereign cloud based on a sovereign data centre located in Moroccan territory.

This architecture allows ROBY to retain control of its strategic data and limit their exposure to foreign infrastructures or jurisdictions.

Hosting in Morocco is an essential component of User protection, ROBY’s technological control and the digital sovereignty associated with mobility data.

7.2 Databases and Backups in Morocco

ROBY’s principal databases and their backups are retained in Moroccan territory.

The hosting provider must provide sufficient guarantees regarding:

• location of infrastructure;
• access control;
• encryption;
• backups;
• business continuity;
• data restoration;
• logging of operations;
• incident management;
• confidentiality;
• compliance with Moroccan Law No. 09-08.

Technical access to infrastructure is restricted to authorised persons for whom it is necessary to operate, maintain and secure the Platform.

7.3 No Relocation of the ROBY Database

Under its normal hosting architecture, ROBY Technologies does not relocate its principal personal-data database or its backups outside Morocco.

Mobility data are not sold, rented or made available to a foreign company to allow it to create its own User database, commercially exploit routes or take control of data generated by Moroccan mobility.

The data remain under the responsibility of ROBY Technologies and subject to Moroccan law, without prejudice to requests lawfully made by the competent authorities.

7.4 Technical Service Providers and Access from Abroad

Sovereign hosting of the principal database does not exclude the possibility that certain technical features may require occasional intervention by a third-party provider, in particular for mapping, notifications, communications, incident detection, maintenance or payments.

Before using a provider likely to access data from abroad or receive data outside Morocco, ROBY:

• determines whether that access or transmission constitutes an international transfer;
• limits the data to what is strictly necessary;
• verifies the provider’s confidentiality and security safeguards;
• contractually governs the processing;
• completes the formalities required by the CNDP;
• informs Users where required by law.

No regular transfer of personal data abroad may be implemented without the required safeguards and authorisations.

7.5 Transfers Subject to Moroccan Law

Where an occasional or limited transfer of data abroad is necessary, ROBY applies Articles 43 and 44 of Law No. 09-08 and completes the formalities required by the CNDP.

Safeguards may include:

• recognition of an adequate level of protection;
• the person’s express consent where this lawful basis is legally appropriate;
• contractual clauses governing the transfer;
• binding internal rules for intra-group transfers;
• any other safeguard accepted or approved by the CNDP.

For data subject to the GDPR, transfers outside the European Economic Area are based on an adequacy decision, standard contractual clauses approved by the European Commission or another mechanism provided for by Articles 44 et seq. of the GDPR.

The User may request information about the safeguards applicable to a transfer by writing via the contact form.

7.6 Anonymised Data and Institutional Data

ROBY may produce anonymised and aggregated statistics relating to mobility, transport demand, pickup areas, waiting times, vehicle availability or Service quality.

This information may be used to improve mobility, support Moroccan authorities and contribute to public-policy planning.

No directly identifiable data concerning a Driver or Passenger are disclosed for this purpose without a lawful basis, appropriate information and compliance with applicable formalities.

Data sovereignty means retaining in Morocco the hosting, governance, control, economic value and use of data for the benefit of Drivers, Passengers and Moroccan institutions.

Article 8. Retention periods

ROBY retains data only for as long as necessary for the purpose for which they were collected, extended, where justified, by the periods required to comply with a legal obligation, establish evidence or defend a right.

8.1 Principal Retention Periods

Subject to a different period imposed by law or validated in the formalities completed with the CNDP:

• account data are retained for the period during which the account is active, then for five years from its closure or the last significant transaction;
• Driver-verification documents are retained for the period of account validation and activity, then for five years from the end of the relationship, unless a different obligation applies;
• rejected or incomplete Driver applications are retained for twelve months from the last interaction, unless fraud is suspected or a legal obligation applies;
• Ride history is retained for five years from the Ride;
• precise route and geolocation data associated with a Ride are retained for the period necessary for tracking and safety, and then with the Ride history where necessary for evidence, fraud handling or complaint management;
• geolocation data with no useful connection to a Ride are deleted or anonymised within a maximum of twelve months;
• payments, Driver Credits, invoices and accounting entries are retained for the period imposed by applicable tax, accounting, banking and anti-fraud rules;
• ordinary support requests are retained for three years after closure;
• accident, fraud, assault or litigation files are retained for the duration of the proceedings, then for the applicable statutory limitation period;
• call recordings, where authorised, are retained for ninety days, unless necessary for the examination of an incident or dispute;
• technical and security logs are retained for twelve months, unless an incident requires longer retention;
• direct-marketing data are retained until consent is withdrawn or for the maximum authorised period from the last active contact;
• evidence of the withdrawal of consent or objection is retained for as long as necessary to respect the person’s choice.

8.2 Suspension of Deletion

Data may be retained for longer where necessary for:

• an investigation;
• legal proceedings;
• a request from an authority;
• the defence of a right;
• the prevention of identified fraud;
• compliance with a legal obligation.

In such cases, access is restricted to the persons responsible for the matter.

8.3 Anonymisation

At the end of the retention periods, data are deleted or irreversibly anonymised.

Anonymised data may be retained for statistical, research, mobility-planning or service-improvement purposes, in compliance with the required formalities.

Article 9. Rights of individuals

9.1 Rights Under Moroccan Law

In accordance with Law No. 09-08, any person who provides proof of identity may exercise:

• the right to be informed of processing;
• the right of access to data concerning them;
• the right to rectify inaccurate or incomplete data;
• the right to object, on legitimate grounds, to certain processing;
• the right to object to the use of their data for direct-marketing purposes.

9.2 Additional Rights Applicable in the European Union

Where the GDPR applies, the person may also request, subject to the conditions laid down by law:

• erasure of their data;
• restriction of processing;
• portability of the data provided;
• withdrawal of consent;
• objection to processing based on legitimate interests;
• objection to direct marketing;
• human intervention concerning an automated individual decision;
• information about international transfers;
• lodging a complaint with the competent supervisory authority.

9.3 Exercising Rights

Requests may be sent:

• via the contact form, with the subject line “Exercise of my rights”;
• by post to the registered office of ROBY Technologies, for the attention of the Data Protection Contact.

The request must enable the account concerned to be identified and specify the right being exercised.

ROBY may request proof of identity where there is reasonable doubt about the requester’s identity. Only information strictly necessary for this verification will be requested.

It is recommended that information not required for verification be concealed on the copy of the identity document, subject to applicable legal requirements.

ROBY responds within the time limits laid down by applicable regulations. Where the GDPR applies, a response is provided, in principle, within one month, subject to an authorised extension due to the complexity or number of requests.

The exercise of a right is free of charge, except in the case of a manifestly unfounded or excessive request under the conditions provided for by law.

9.4 Limits on Rights

Certain data cannot be deleted immediately where their retention is necessary for:

• performance of a Ride or payment in progress;
• compliance with a legal obligation;
• accounting;
• fraud prevention;
• security;
• the establishment, exercise or defence of a legal claim.

To the extent permitted by law, ROBY explains the reasons for any refusal or restriction.

9.5 Complaint to an Authority

In Morocco, the User may refer a matter to the National Commission for the Control of Personal Data Protection:

CNDP

Avenue Al Arz, Sector 4, M1, Hay Riad, Rabat, Morocco

Website: www.cndp.ma

Where the User is located in the European Union, the User may also refer a matter to the competent data-protection authority in the country of residence, place of work or place of the alleged infringement.

Article 10. Data security and breaches

10.1 Security Measures

ROBY implements technical and organisational measures appropriate to the nature of the data and the risks, including:

• hosting principal data and backups in Morocco;
• encryption of communications;
• encryption or enhanced protection of sensitive data where appropriate;
• separation of technical environments;
• access-rights controls;
• enhanced authentication for sensitive and administrative accounts;
• logging of access and critical operations;
• data backup and restoration;
• incident monitoring;
• protection against malicious software;
• security updates;
• vulnerability testing;
• restriction of provider access;
• confidentiality commitments;
• employee training;
• incident-management procedures;
• deletion or anonymisation of data that have reached the end of their retention period.

Identity documents, driving licences, trust permits, approvals, operating authorisations and financial information are subject to enhanced access restrictions.

10.2 User Responsibility

The User must:

• protect their telephone and login details;
• use a lock code;
• not share verification codes;
• not lend their account;
• keep their operating system and application up to date;
• immediately inform ROBY in the event of loss, theft or unauthorised access.

As no information system can provide absolute security, ROBY cannot guarantee that no incident will occur despite the measures implemented.

10.3 Breach Management

In the event of a breach likely to present a risk to persons, ROBY:

• takes the measures necessary to contain and remedy the incident;
• assesses the nature of the data and possible consequences;
• retains the information necessary for analysis;
• informs the CNDP or any other competent authority where required by law;
• informs the persons concerned where such information is legally required;
• documents the incident and corrective measures.

Where the GDPR applies, a breach presenting a risk to the rights and freedoms of persons is notified to the competent authority within the applicable legal time limit, in principle within seventy-two hours of its discovery.

Article 11. Automated decisions, ranking and fraud prevention

ROBY may use automated systems to:

• identify available Drivers;
• calculate their distance and arrival time;
• organise the display of requests;
• detect payment or location inconsistencies;
• assign a risk level to a transaction;
• detect conduct liable to constitute fraud;
• temporarily restrict a feature in the event of an immediate risk;
• improve the quality and safety of the Service.

The criteria used may include location, vehicle category, availability, approach time, document compliance, cancellations, safety incidents and preferences expressed by the Passenger.

An unfavourable rating or automated alert must not, by itself, result in permanent closure of the account producing a significant effect without appropriate review.

ROBY may take an automated and temporary precautionary measure where necessary to prevent fraud, protect an account or respond to an immediate danger.

The User may request human intervention, submit observations and challenge a decision that significantly affects the User’s account.

Article 12. Cookies, trackers and audience measurement

The website and application may use cookies, mobile identifiers, pixels, SDKs and similar technologies.

12.1 Strictly Necessary Trackers

These trackers may be used without prior consent where they are essential for:

• login;
• authentication;
• security;
• storing essential choices;
• operation of booking or payment;
• fraud prevention;
• technical load balancing of the service.

12.2 Audience Measurement and Improvement

Tools may measure:

• the number of visits;
• screens viewed;
• technical errors;
• performance;
• use of features;
• general journeys through the application.

Where required by law, these tools are activated only after the User has given consent.

12.3 Advertising and Personalisation

ROBY uses advertising trackers, advertising identifiers or commercial-personalisation technologies only after obtaining the required consent.

Where this rule applies, refusal must be capable of being expressed as easily as acceptance.

The User may change their choice at any time through the privacy settings or cookie-management tool.

A separate Cookie Policy specifies the tools actually used, their provider, purpose and duration.

Article 13. Minors and persons under protection

Creation of a ROBY account is reserved for persons who are at least eighteen years old and legally capable of entering into a contract.

ROBY does not seek knowingly to collect data from a minor holding an account.

A minor may be transported when accompanied by a responsible adult or where the Service, regulations and safety measures expressly permit the minor to be carried.

Where an adult provides information concerning a minor or a person under that adult’s responsibility, the adult warrants that they are authorised to do so and limits the information to what is necessary for the Service.

If ROBY learns that an account was created directly by a minor in breach of the Terms, it may suspend the account, request the necessary checks and delete data that must not be retained.

Article 14. Amendment of the policy

ROBY may amend this Policy to take account of:

• a legal or regulatory development;
• a change to the services;
• the addition of a feature;
• a change of service provider;
• new processing;
• a change in security measures.

The update date appears at the beginning of the Policy.

Any material amendment is brought to Users’ attention through the application, website, a notification or email.

Where consent is required for a new purpose, ROBY obtains that consent before implementing the processing concerned.

Earlier versions may be retained to demonstrate the information provided to Users at a given date.

Article 15. Languages and accessibility

This Policy must be made available to Users in clear and understandable language.

For Morocco, an Arabic-language version accompanies the French version in accordance with the requirements applicable to consumer information.

In other countries, ROBY provides the necessary translations and local information.

In the event of any discrepancy between versions, the mandatory rules of the country in which the Service is provided prevail.

Article 16. Contact

For any question, complaint or request relating to personal data protection:

Write to us via the contact form with the subject line “Personal data protection”.

To facilitate processing of the request, the User may specify:

• first name and surname;
• the telephone number or email address linked to the account;
• status as Passenger, Driver or partner;
• the precise subject of the request;
• the Ride or transaction concerned, where applicable.

ROBY never asks a User to disclose a password or one-time login code in order to exercise their rights.