Privacy Policy

29th March 2026

 

Kose
Legal

Privacy Policy

Effective Date: 29 March 2026  ·  Version: 1.0  ·  Jurisdiction: Zimbabwe · Zambia · South Africa

1. Introduction

Welcome to Kose. Kose Africa (Pvt) Ltd and its subsidiaries ("Kose", "we", "our", or "us") operate a ride-hailing, e-commerce, and payments super-app serving users across Zimbabwe, Zambia, and South Africa.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use the Kose mobile application, website, and related services (collectively, the "Platform"). By creating a Kose account or using any of our services, you agree to the terms of this Policy.

We are committed to complying with applicable data protection laws in each country we operate in, including Zimbabwe's Data Protection Act, Zambia's Data Protection Act 2021, and South Africa's Protection of Personal Information Act (POPIA).

2. Information We Collect

2.1 Information You Provide Directly

  • Full name, email address, and phone number when you register
  • Profile photo (optional)
  • Payment information, including mobile money account details (EcoCash, MTN Mobile Money, etc.) and card details
  • Delivery address and saved locations
  • Identity verification documents where required by law
  • Communications you send to our support team

2.2 Information Collected Automatically

  • Precise GPS location data when you use the app, including pickup and drop-off points
  • Device information: model, operating system, unique device identifiers, and mobile network information
  • App usage data: features accessed, time spent, search queries, and clicks
  • Transaction history: rides taken, orders placed, amounts paid, and timestamps
  • Log data: IP address, browser type, pages visited, and crash reports

2.3 Information from Third Parties

  • Payment processors and mobile money operators confirming transaction status
  • Identity verification partners for KYC compliance
  • Google Maps and mapping services for route calculations
  • Social login providers if you sign in with Google or Facebook

3. How We Use Your Information

3.1 Providing Our Services

  • Matching you with available drivers for ride requests
  • Processing payments and maintaining your transaction history
  • Facilitating e-commerce orders and deliveries
  • Sending real-time trip updates, ETAs, and order confirmations
  • Enabling in-app communication between riders and drivers

3.2 Safety and Security

  • Verifying user identity to prevent fraud and account misuse
  • Monitoring for suspicious transactions or abnormal account activity
  • Sharing location data with emergency services if you activate the SOS feature
  • Investigating complaints, accidents, or safety incidents

3.3 Improving Our Platform

  • Analysing usage patterns to improve features and performance
  • Conducting internal research and analytics
  • Testing new features and services

3.4 Marketing and Communications

  • Sending promotional offers, discounts, and service updates (with your consent)
  • Personalising content and recommendations based on your usage
  • Sending transactional messages such as receipts and booking confirmations

You may opt out of marketing communications at any time through the app settings or by contacting us.

4. Location Data

Kose requires access to your precise location to function. Location data is used to:

  • Identify your pickup point and suggest nearby drivers
  • Calculate route distances and estimated fares
  • Track trip progress in real time
  • Detect unusual trip deviations for safety purposes
You can disable location access in your device settings, but this will prevent you from using core features of the Platform. Background location is collected only during active trips or when you have the app open.

5. Sharing Your Information

We do not sell your personal information. We share your data only in the following circumstances:

5.1 With Drivers

When you book a ride, we share your first name, pickup location, destination, and profile photo with the assigned driver. Your full phone number is not shared; all calls and messages are routed through anonymised channels.

5.2 With Service Providers

We work with trusted third-party vendors for payment processing, cloud infrastructure, customer support, and analytics. These providers are contractually obligated to protect your data and may only use it to deliver services on our behalf.

5.3 For Legal and Regulatory Compliance

We may disclose your information to government authorities, law enforcement, or courts when required by law, in response to a valid legal process, or to protect the rights and safety of Kose, our users, or the public.

5.4 Business Transfers

If Kose undergoes a merger, acquisition, or sale of assets, your information may be transferred to the successor entity, subject to equivalent privacy protections.

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you with our services:

  • Account data: retained for the duration of your account, plus 5 years after closure
  • Trip and transaction records: retained for 7 years for accounting and regulatory compliance
  • Support communications: retained for 3 years
  • Location data from completed trips: retained for 2 years

After the applicable retention period, data is securely deleted or anonymised.

7. Your Rights

Depending on your country of residence, you may 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 that we correct inaccurate or incomplete data
  • Right to deletion: request erasure of your data, subject to legal retention requirements
  • Right to portability: receive your data in a structured, machine-readable format
  • Right to object: object to processing for direct marketing or profiling
  • Right to withdraw consent: where processing is based on consent, withdraw it at any time
To exercise any of these rights, contact us at privacy@kose.africa. We will respond within 30 days. We may require identity verification before processing your request.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal information. Our security practices include:

  • Encryption of data in transit using TLS 1.2 or higher
  • Encryption of sensitive data at rest
  • Role-based access controls limiting who can access your data
  • Regular security audits and vulnerability assessments
  • Incident response procedures for data breaches

Despite our measures, no system is completely secure. In the event of a data breach that poses a risk to your rights, we will notify you and relevant authorities as required by applicable law.

9. Children's Privacy

Kose services are intended for users aged 18 and older. We do not knowingly collect personal information from children under 18. If we become aware that we have collected data from a minor, we will delete it promptly. If you believe a minor has created a Kose account, please contact us immediately at privacy@kose.africa.

10. Cookies and Tracking

Our website and app use cookies and similar technologies to remember your preferences, maintain session security, and analyse usage. You can manage cookie preferences through your browser settings. Disabling cookies may affect some functionality of the Platform.

11. Cross-Border Data Transfers

Your data may be processed in countries outside your country of residence where our cloud infrastructure or service providers are located. We ensure that such transfers are protected by appropriate safeguards, including standard contractual clauses and data processing agreements aligned with applicable law.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the app or by email at least 14 days before the changes take effect. Your continued use of the Platform after the effective date constitutes acceptance of the updated Policy.

13. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Data Protection Officer:

Phone
+263 77 000 0000
Address
Kose Africa (Pvt) Ltd, Harare, Zimbabwe

If you are dissatisfied with our response, you have the right to lodge a complaint with the relevant data protection authority in your country.

1. Introduction

This Driver Privacy Policy ("Policy") explains how Kose Africa (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. Information We Collect About Drivers

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. How We Use Driver Information

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

4. Continuous Location Tracking

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
Location tracking stops when you go offline in the driver app. Kose does not track your location when you are not logged into the driver app.

5. Sharing Driver Information

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.

6. Driver Ratings and Feedback

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.

A consistently low rating may result in additional training requirements or, in severe cases, deactivation from the platform. We will always provide you with an opportunity to respond to complaints before taking significant action against your account.

7. Earnings and Financial Data

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.

8. Data Retention

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.

9. Your Rights as a Driver

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
To exercise any right, contact privacy@kose.africa. We will respond within 30 days and may require identity verification before proceeding.

10. Automated Decision-Making

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.

11. Data Security

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.

12. Changes to This Policy

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.

13. Contact and Complaints

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

Phone
+263 77 000 0000
Address
Kose Africa (Pvt) Ltd, Harare, Zimbabwe

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

Zimbabwe
Postal and Telecommunications Regulatory Authority of Zimbabwe (POTRAZ)
Zambia
Zambia Information and Communications Technology Authority (ZICTA)
South Africa
Information Regulator (South Africa)