About this notice
This notice explains how Routes by Remora collects, uses and shares personal data, and the rights you have over it. It applies to the Routes mobile app, the website at remoraroutes.com, and our related services.
Routes by Remora LTD, a company registered in Ghana with its registered office at 4th Floor, 1 Airport Square, Accra, Ghana, is the controller of that data.
Routes is a route-sharing platform. Passengers are matched with private drivers already making a similar journey. Operating that service safely and without cash means we handle certain sensitive information, including your location while you are travelling and information used to confirm your identity. This notice sets out what that involves.
Our processing is governed by the Ghana Data Protection Act, 2012 (Act 843), and we are registered as a data controller with the Data Protection Commission of Ghana. Where we offer the service to people in the European Economic Area or the United Kingdom, the EU and UK General Data Protection Regulation apply to that processing, and this notice is written to meet those standards.
Questions, requests and complaints: [email protected].
Information we collect
Information you give us. Your phone number, name, email address, date of birth, gender, profile photograph and country. If you drive, your driving licence details and information about your vehicle, such as its make, model, colour and registration.
Identity verification information. Before using Routes, every passenger and driver completes an identity check. This involves a photograph of a government-issued identity document, and a selfie which is compared against the photograph in that document to confirm you are the same person. For drivers, additional checks confirm that a live person is present. The comparison of your selfie against your document produces biometric data, which is treated as sensitive personal data under Ghanaian law and as a special category of personal data under the GDPR. We record the outcome of the check and supporting information from our verification provider.
We use this information solely to confirm identity and prevent impersonation and fraud on a service where people share vehicles with strangers. We do not use it for advertising, and we do not use it to identify you anywhere other than during verification.
Location information. When you are online as a driver, or searching for or taking a ride as a passenger, we collect your device's location continuously so that matching and navigation work. We also record the pickup and destination points of your journeys, along with places you save or use frequently. We do not collect your location when you are not using the service in one of those ways.
Trip and communication information. Your ride requests and their outcome, including cancellations; invitations exchanged between drivers and passengers; messages sent through in-app chat; and the ratings and reviews you give and receive.
Payment information. Records of credit purchases, your wallet balance and transaction history, withdrawal requests, and the payout account you nominate. Card details are entered into and handled by our payment processor. We do not receive or store your full card number.
Information collected automatically. Device and connection information such as IP address, device type and identifier, operating system, app version, and information about how you use the service, including session activity and notification tokens.
How we use your information, and our legal basis
| Purpose | Legal basis |
|---|---|
| Creating and operating your account, and providing the service | Performance of our contract with you |
| Confirming your identity and eligibility to drive | Performance of our contract; compliance with legal obligations |
| Comparing your selfie against your identity document, which produces biometric data | Your explicit consent, given when you choose to begin verification |
| Matching drivers and passengers, and providing navigation | Performance of our contract |
| Operating women-only matching | Your explicit consent, given by enabling the option |
| Processing payments, holding and releasing fares, and paying out earnings | Performance of our contract |
| Keeping tax, accounting and anti-money-laundering records | Compliance with legal obligations |
| Investigating safety reports, disputes, fraud and misuse, and enforcing our terms | Our legitimate interests in user safety and platform integrity |
| Improving and securing the service | Our legitimate interests in operating a reliable service |
| Sending service messages about your rides, payments and account | Performance of our contract |
| Sending marketing communications | Your consent, which you may withdraw at any time |
Where we rely on legitimate interests, we have weighed those interests against your rights and concluded the processing is necessary and proportionate. You may ask us about that assessment and you may object to the processing.
Automated decisions. The outcome of your identity check is applied to your account automatically, and a declined result prevents you from using Routes. Matches are generated automatically from journey overlap, permitted detour, available seats and ratings. Because these decisions affect you, you may request human review, express your view, and contest the outcome by contacting us. Decisions to suspend or remove an account are always taken by a person.
How we share your information
We do not sell your personal data, and we do not share it for cross-context behavioural advertising.
With other users. When you are matched, you and the other user see the information needed to complete the ride, including display name, profile photograph, rating, the relevant pickup or drop-off point, and in-app chat. Reviews are attributed to their author.
With people you share a trip with. If you choose to share a trip, anyone holding the link you generate can follow that journey in real time, including your location, without needing a Routes account. Share these links only with people you intend to have that visibility. Links expire, and you can stop sharing at any time.
With our service providers. We use carefully selected providers to deliver the service, including identity verification providers, payment processors, mapping and routing providers, communications providers who deliver our messages and notifications, and cloud hosting and security providers. They act on our instructions under contracts that restrict what they may do with your data and prevent them using it for their own purposes. Payments and payouts are processed by Paystack, whose own privacy notice governs the information you provide directly to them.
For legal and safety reasons. We may disclose information to law enforcement, regulators or other authorities where we are legally required to, or where disclosure is necessary to protect someone's safety, investigate fraud, or establish or defend legal claims. We may also share information with our professional advisers, and with a buyer or successor if our business is transferred, in which case we will tell you beforehand.
International transfers. Our providers operate outside Ghana, so your data may be transferred internationally, including to the European Economic Area, the United Kingdom and the United States. Where we transfer personal data protected by the GDPR, we rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or another mechanism recognised in law. You may request further information about these safeguards.
How long we keep your information
We keep personal data for as long as we need it for the purposes described in this notice, and then delete or anonymise it.
In practice this means we keep your account and profile information for as long as your account is open. Information about your journeys, including chat and ratings, is kept while your account is open and, in anonymised form afterwards, so that safety reports and disputes can still be investigated. Records relating to payments, earnings and identity verification are kept for the periods required by Ghanaian tax, accounting and anti-money-laundering law, which are generally longer than the periods above. Live location associated with an active session is short-lived and is removed once that session ends.
Where we need to prevent a removed user from returning to the platform, we retain limited information for that purpose only.
Your rights and choices
Subject to the conditions and exceptions in applicable law, you may:
- Ask for access to the personal data we hold about you, and for a copy of it
- Ask us to correct data that is inaccurate or incomplete
- Ask us to delete your data
- Ask us to restrict processing while a question about accuracy or lawfulness is resolved
- Object to processing based on our legitimate interests, and object at any time to direct marketing, which we will always act on
- Receive your data in a portable format and, where technically feasible, have it transmitted to another provider
- Withdraw consent where we rely on it, including your consent to identity verification and to women-only matching. Withdrawal does not affect processing already carried out, and withdrawing consent to verification means your account can no longer be maintained
- Request human review of the automated decisions described above
To exercise any of these, contact [email protected]. We will respond within the period the law allows, and will tell you if a request is complex and needs longer. We may need to confirm your identity before acting on a request.
Deleting your account. You can request deletion in the app or by contacting us. Before your account can close, any ride in progress must be completed and any outstanding balance or pending payout resolved. After a short grace period during which you may reverse the request, we remove the information that identifies you, including your contact details, profile, verification records and payout details. Records we are legally required to keep, and journey and ratings information needed for safety and dispute purposes, are retained without identifying you.
Complaints. If you are unhappy with how we have handled your data, please contact us first.
California residents. If you are a California resident, you have the right to know what personal information we collect and why, to obtain a copy, to correct it, to delete it, to opt out of the sale or sharing of personal information, to limit the use of sensitive personal information, and not to be discriminated against for exercising those rights. We do not sell or share personal information as the CCPA and CPRA define those terms, and we do not use or disclose sensitive personal information beyond the purposes those laws permit. To exercise these rights, contact us.
Cookies and our website
Our website uses cookies and similar technologies. Some are necessary for the site to function. Others support analytics, which help us understand how the site is used and improve it; these process information such as your IP address, the pages you view, and your device and browser.
You can control cookies through your browser settings, including blocking or deleting them, though some parts of the site may not work as intended if you do.
Children
Routes is for adults. You must be at least 18 years old to use the service, as a passenger or a driver. We do not knowingly collect personal data from anyone under 18 and we do not direct the service or our marketing at children. If we learn that someone under 18 has created an account, we will close it and delete their data. If you believe a child has provided us with personal data, contact us and we will act on it.
Security
We take appropriate technical and organisational measures to protect personal data, including encryption of data in transit, restricted and logged administrative access, revocable sign-in sessions, and handling of card details entirely by our payment processor so that they do not reach our systems.
Keep your device and your phone number secure, since the code we send to your number is what confirms your identity to us. Tell us immediately if you believe someone else has accessed your account.
Changes to this notice
We may update this notice as our service develops. The version number and effective date above identify the current version. Where a change is material we will notify you through the app or by email before it takes effect, and where a change requires your consent we will ask for it.
Contact us
Routes by Remora LTD
4th Floor, 1 Airport Square, Accra, Ghana