Privacy Policy — EmpowerDriver App
Effective Date: March 5, 2026
Last Updated: March 5, 2026
1. Introduction
The EmpowerDriver mobile application ("the App") is developed and operated by InCharge Technologies B.V. ("InCharge", "we", "us", or "our") as part of the EMobility Power consortium (emobilitypower.org), a Dutch-Kenyan initiative transforming Kenya's taxi industry through electric vehicle adoption.
This Privacy Policy explains how we collect, use, store, and protect your personal data when you use the App. We are committed to protecting your privacy in compliance with the Kenya Data Protection Act, 2019 ("KDPA") and other applicable data protection laws.
Contact: privacy@incharge.ai
2. Data We Collect
2.1 Information You Provide
- National ID number — used for identity verification and account creation
- Phone number — used for one-time password (OTP) authentication
- Vehicle information — make, model, license plate, fuel type, and year (when you add a vehicle)
2.2 Information Collected With Your Consent
The following data is only collected if you explicitly opt in during onboarding. You can enable or disable each category at any time in Settings > My Data & Privacy.
- Location data — GPS coordinates, including when the App is running in the background. Used to track trips, analyze driving patterns, and assess creditworthiness.
- Device information — device brand, model, operating system, OS version, app version, and a unique device identifier. Used for technical support, diagnostics, and security.
- Activity recognition — motion and activity data (e.g., driving, walking, stationary) from device sensors. Used to optimize location tracking and detect trip start/end.
- SMS messages (Android only) — SMS messages from financial service providers (e.g., M-PESA, ride-hailing platforms) to analyze income patterns. We only read messages from senders you explicitly approve. We do not read personal messages.
- Battery and Bluetooth data — if you connect to a battery monitoring device, battery telemetry (state of charge, voltage, current, temperature) via Bluetooth Low Energy (BLE).
2.3 Information Derived from Your Data
- Trip analytics — trip frequency, distances, timing, routes, and driving patterns
3. How We Use Your Data
- Account creation and authentication — National ID, phone number (legal basis: performance of contract)
- Trip tracking and driving analysis — location, activity recognition (legal basis: consent)
- Loan eligibility assessment — location, SMS, trip analytics (legal basis: consent and legitimate interest)
- App performance and diagnostics — device information, activity data (legal basis: consent)
- Customer support — device information (legal basis: consent)
- Battery monitoring — BLE telemetry (legal basis: consent)
- Financial pattern analysis — SMS messages (legal basis: explicit consent)
4. Automated Decision-Making
We use automated algorithms to process your data and assess loan eligibility. This may be used to determine loan terms, interest rates, and personalized offers.
Your rights regarding automated decisions (KDPA Section 35):
- Request human review of any automated decision
- Receive an explanation of how a decision was reached
- Dispute decisions and provide additional information
The App explains how automated decision-making works during onboarding before you begin using the service.
5. Data Sharing
We do not sell your personal data.
We may share your data with:
- EMobility Power consortium partners — specifically Platcorp (EV financing) when you apply for a loan, and only the data necessary to process your application
- Service providers — trusted third parties who help us operate the App (e.g., cloud hosting), bound by data processing agreements
- Legal authorities — when required by law or court order
6. Data Storage and Security
- Data is encrypted in transit (HTTPS/TLS) and at rest
- Authentication tokens are stored using platform-native secure storage (iOS Keychain, Android Keystore)
- Consent records are maintained locally on your device and on our servers for audit purposes
- Our servers are hosted in secure cloud infrastructure in the European Union with access controls
7. Data Retention
- Account data — retained for the duration of your account, plus any period required by law
- Location and trip data — retained for as long as needed to provide the service
- SMS data — retained for as long as needed for financial analysis; deleted upon request
- Device information — retained for the duration of your account
When you delete your account, we will delete or anonymize your personal data within 30 days, unless retention is required by law.
8. Your Rights
Under the Kenya Data Protection Act, you have the right to:
1. Access — request a copy of all personal data we hold about you
2. Rectification — request correction of inaccurate data
3. Erasure — request deletion of your data
4. Data portability — request your data in a machine-readable format
5. Withdraw consent — withdraw consent for any data collection at any time
6. Restrict processing — request that we limit how we use your data
7. Object to automated decisions — request human review of automated decisions
8. Lodge a complaint — file a complaint with the Office of the Data Protection Commissioner of Kenya
You can exercise these rights through the App (Settings > My Data & Privacy) or by contacting us at privacy@incharge.ai.
9. Consent Management
- During onboarding, you choose which data types to share (location, device info, SMS)
- You can change your consent preferences at any time in Settings > My Data & Privacy
- Withdrawing consent for location data will limit the App's ability to track trips and assess creditworthiness
- Withdrawing consent for SMS will stop financial pattern analysis
10. Children's Privacy
The App is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at privacy@incharge.ai.
11. Changes to This Policy
We may update this Privacy Policy from time to time. When we make significant changes, we will notify you through the App. Continued use of the App after changes constitutes acceptance of the updated policy.
12. Contact Us
InCharge Technologies B.V.
Email: privacy@incharge.ai
Website: https://www.emobilitypower.org
For complaints, you may also contact:
Office of the Data Protection Commissioner
Republic of Kenya