PRIVACY POLICY

Effective Date: November 29, 2025

1. Introduction

This Privacy Policy explains how Babu Motors Uganda (“Babu Motors”, “we”, “our”, “us”) collects, uses, stores, and protects your personal information when you:

• Use our mobile application or website
• Apply for or use our Drive-To-Own (DTO) program
• Make vehicle pre-payments or security deposit top-ups
• Communicate with us through any digital channel

By using our services, you agree to the terms described in this Privacy Policy.

2. Who We Are

Babu Motors is a vehicle dealership and leasing company. We:

• Import vehicles from Japan and other markets
• Sell vehicles for full payment
• Offer structured Drive-To-Own leasing options
• Offer limited, short-term flexible payment/credit-style arrangements linked to specific vehicles (without interest) in some cases

We are not a bank, SACCO, or financial institution, and we do not operate savings accounts or investment products.

3. Information We Collect

We only collect information that is reasonably necessary to provide our vehicle and leasing services.

3.1 Personal Identification Information

• Full name
• Phone number
• WhatsApp contact
• Email address
• National ID or Passport number
• Driving permit or learner license information
• Residential district or address (where needed for documentation)

We do not collect or store:

• Bank account numbers
• Credit/debit card numbers
• Mobile money PINs or passwords

All payments are made through secure third-party payment channels (e.g., banks, mobile money providers).

3.2 Account & Application Information

When you register or apply for Drive-To-Own or a flexible payment arrangement, we may collect:

• Employment or business information (if voluntarily provided)
• Basic financial capability information (e.g., ability to meet payment obligations)
• Vehicle preferences and budget
• History of your interactions with Babu Motors (e.g., visits, previous applications)

This information helps us assess suitability for DTO or short-term payment plans, but we do not run external credit bureau checks without your consent.

3.3 Vehicle & GPS Information (DTO and Certain Deals)

For DTO and some controlled/credit-style arrangements, we may collect:

• Vehicle details (make, model, registration number)
• GPS-based location of the vehicle via a GPS device installed in the car
• Basic telemetry or movement data from the GPS system (where applicable)

GPS tracking is installed on the vehicle, not on your phone.

3.4 Location Data (Mobile App – Optional)

If you grant permission, our app may access approximate location from your device to:

• Support optional “customer discovery” or nearby services
• Improve relevance of information displayed to you

You can disable app location access at any time in your device settings. Disabling app location does not disable GPS tracking of DTO vehicles, which is independent and device-based on the car.

3.5 Device & Usage Information

We may collect:

• Device type and operating system
• App version and language
• IP address
• Log-in times and basic usage activity
• Error reports, crash logs, and performance data

This helps us secure and improve our app and services.

4. How We Use Your Information

We use your information solely to provide and improve vehicle-related services.

4.1 Service Provision

• To create and manage your user account
• To process applications for Drive-To-Own or flexible payment arrangements
• To allocate or reserve a vehicle for you
• To track your payment progress (e.g., how much you have paid and balance remaining)
• To maintain and enforce agreements, including DTO contracts and MOUs

4.2 Payments & Records

• To record payments made (security deposit, pre-payment, lease installments)
• To generate and share digital receipts
• To maintain your payment history and statements

We do not process or store your payment PINs or full card numbers; those are handled by secure payment processors.

4.3 Security & Fraud Prevention

• To protect vehicles and other assets through GPS tracking
• To detect and prevent fraudulent or suspicious activities
• To respond to theft, unauthorized use, or contract breaches

4.4 Assessment of Payment Arrangements

• To assess whether you may qualify for certain flexible payment options (e.g., partial upfront payment, short-term balance clearance)
• To determine whether DTO or a different arrangement is more suitable

We do not use complex profiling; we consider only the basic information you provide and your repayment history with us.

4.5 Legal & Regulatory Compliance

• To comply with Ugandan laws and lawful requests from authorities
• To maintain proper records as required by law

4.6 Communication

• To send payment reminders, due dates, and confirmations
• To inform you of changes to our services, terms, or policies
• To respond to your inquiries and support requests

Communication may be sent via SMS, WhatsApp, phone calls, email, or in-app notifications.

5. Legal Basis for Processing

We process your personal data based on:

• Performance of a contract: to provide Drive-To-Own, vehicle sale, or flexible payment services.
• Legitimate interests: to secure our vehicles, prevent fraud, and operate our business safely and effectively.
• Legal obligations: to comply with tax, regulatory, or law enforcement requests.
• Consent: for optional app features (such as mobile location-based services).

6. Data Storage & Security

We use appropriate technical and organizational safeguards to protect your data, including:

• Encrypted data transmission (e.g., HTTPS/SSL)
• Secure servers and restricted access based on role
• Password protection and, where applicable, multi-factor authentication
• Regular system updates and security checks

Only authorized staff members who need the information to perform their roles are allowed access to your data.

7. Data Sharing

We do not sell, rent, or trade your personal data.

We may share limited data only in the following situations:

1. With service providers

   • Cloud hosting providers
   • SMS and email gateways
   • App analytics and error-reporting tools

   These providers are required to protect your data and may not use it for their own purposes.

2. With law enforcement or regulators

   • When required by Ugandan law
   • When responding to a legal order, court directive, or lawful police request
   • In cases involving theft, fraud, or criminal investigation relating to Babu Motors vehicles or services

We do not share your personal data with other car dealers, lenders, banks, or commercial entities for marketing purposes.

8. Data Retention

We retain your data for as long as necessary:

• For the duration of your active account or agreement
• As required to maintain accurate financial and contractual records
• As required by Ugandan law (for example, for accounting and audit purposes)

We keep financial, contractual and KYC records for 7 years after your account is settled and closed. After this period, we securely delete or anonymize your personal data so it can no longer be linked to you.

Deleting your app account

You can ask us to close your DTO app account at any time — by email, WhatsApp or phone, or through Settings → Request Profile Update in the app. Full instructions are on our Delete Your Account page.

When we action a deletion request we remove your app login and password, profile picture and profile details, saved device settings, biometric login and push notification tokens.

We cannot delete records we are required by law to keep, or records tied to a balance you have not yet settled. These are your loan, lease, wallet and payment records, your KYC information (NIN, guarantor and next-of-kin details), signed agreements and receipts, and vehicle inspection and service history. They are retained for the 7-year period described above.

9. Your Rights

Subject to applicable law, you have the right to:

• Access: Request a copy of your personal information held by us
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your data where there is no ongoing legal or contractual need to retain it — see Delete Your Account
• Restriction: Request restriction of processing in certain situations
• Data portability: Request a copy of your data in a commonly used format, where applicable
• Withdraw consent: Withdraw consent for optional features (such as device location access in the app)

To exercise these rights, contact us using the details in Section 12.

10. Children’s Privacy

Our services are intended for adults 18 years and older. We do not knowingly collect personal data from children. If we become aware that data has been collected from someone under 18 without proper consent, we will delete it.

11. Third-Party Links & Services

Our website or app may contain links or integrations to third-party services (maps, analytics, app stores, payment gateways). These third parties have their own privacy policies and practices. You are encouraged to review those policies when using their services.

We are not responsible for the privacy practices of third-party websites or apps.

12. International Data Transfers

If your data is stored or processed outside Uganda (for example, on secure cloud servers), we take reasonable steps to ensure:

• Adequate protection of your information
• Appropriate technical and contractual safeguards

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When significant changes are made, we will notify you through:

• In-app notification, and/or
• SMS or email, and/or
• An update on our website

The “Effective Date” at the top will always show when the latest version came into effect.

Continued use of our services after an update means you accept the updated policy.

14. Contact Information

If you have questions, concerns, or requests regarding your privacy or this policy, please contact us:

Babu Motors Uganda

• Phone & WhatsApp (Primary): +256707412559
• Email: legal@babumotors.co.ug
• Location: Kampala, Uganda

15. Your Consent

By using the Babu Motors website, mobile application, or any related digital services, and by providing your personal information, you acknowledge that you have read, understood, and agree to this Privacy Policy, including:

• The use of your data to manage vehicle purchases, DTO agreements, and flexible payment plans
• GPS tracking of vehicles where applicable under DTO or related agreements
• Receipt of digital communications related to your account and payments

Last updated: November 29, 2025