Privacy and Personal Data Protection Policy

ClickBus Libya – ClickBus Driver Application

Preamble

This Privacy and Personal Data Protection Policy describes how ClickBus Libya collects, uses, stores and protects the personal data of users of the ClickBus Driver application.

This policy is established in accordance with international data protection principles, privacy best practices and the requirements of application distribution platforms, including Google Play.

By using the ClickBus Driver application, you acknowledge that you have read this policy and agree to the terms described herein.

Definition and nature of personal data

When using the website and/or the ClickBus Driver application, we may collect personal data about you. Personal data means any information that can directly or indirectly identify an individual, including but not limited to:

• Full name
• Phone number
• Email address
• Profile photo
• Professional information (carrier, route, vehicle)
• Login and app usage data
• Data related to transactions, tickets, trips and operations performed via the platform
• Any other information you voluntarily choose to provide

Purpose of this policy

This policy aims to inform you, in a transparent manner, about:

• The personal data collected
• The purposes for which it is collected
• Who may have access to it
• The measures in place to ensure its security
• Your rights as a user

Data controller

The data controller is:
ClickBus Libya
Operated by EZ-Pass
Registered office: Immeuble SCI, Rue du Lac Toba, Les Berges du Lac, Tunis – Tunisia
Contact email: sales@clickbus.tn

Purposes of data collection

Personal data is collected for the following purposes:

• Operation and use of the ClickBus Driver application
• Management of user accounts and access
• Management of trips, tickets, validations and transport-related operations
• Communication with users (notifications, SMS, emails, alerts)
• Customer support and technical assistance
• Improvement of services and user experience
• Production of internal statistics and performance analyses
• Prevention of fraud, incidents and abusive use
• Compliance with contractual and operational obligations

Some data are required for the proper functioning of the application. Failure to provide such data may prevent access to certain services.

Recipients of collected data

Collected data is accessible only to:
- ClickBus Libya and EZ-Pass internal teams
- Partner carriers strictly for the purpose of delivering the service
- Technical providers and subcontractors acting on behalf of ClickBus (hosting, maintenance, cloud services)

These recipients are bound by strict confidentiality obligations.

Data sharing and transfer

Personal data may be shared with third parties only when necessary for the operation of the service or for the purposes listed above. ClickBus undertakes not to sell users’ personal data to third parties for unauthorized commercial purposes.

Data security

ClickBus implements all reasonable technical and organizational measures to ensure:

• Data security
• Confidentiality
• Integrity
• Prevention of unauthorized access, loss, alteration or disclosure

These measures include access controls, secure hosting and role-based permission limitations.

Cookies and similar technologies

The ClickBus Driver application and associated services may use cookies or similar technologies for strictly technical and statistical purposes. These technologies may be used to:

• Ensure proper functioning of the services
• Analyze application usage
• Improve performance and stability

ClickBus does not use advertising cookies for commercial targeting purposes.

User consent

By using the ClickBus Driver application, you expressly consent to the collection and processing of your personal data in accordance with this policy. You also agree to receive service-related communications (notifications, SMS, emails). You may request to stop receiving these communications at any time by contacting ClickBus at: sales@clickbus.tn

User rights

You have the following rights regarding your personal data:

• Right of access
• Right to rectification
• Right to deletion, subject to technical and contractual limitations

Any request may be sent by email to: sales@clickbus.tn

Policy changes

ClickBus reserves the right to modify this policy at any time to adapt it to the evolution of services or legal and technical requirements. The updated version will be published on the application and will enter into force immediately. Continued use of the application constitutes acceptance of the new version.

Effective date

This Privacy Policy is effective from its publication on the ClickBus Driver application and applies to all users of the ClickBus Libya platform.