COMOOVA ProLegal documents Français

COMOOVA Pro

Terms of use and privacy

The rules of the COMOOVA Pro application and how your data is protected.

Privacy policy

Version 2.0 of 14 November 2026 | Reference COMOOVA-PRO-PDCP-2026-V2

This policy explains what data the COMOOVA Pro application uses, why, who it is shared with, how long it is kept and how to exercise your rights. It complies with Togolese Law No. 2019-014 of 29 October 2019 on the protection of personal data and, for people located in the European Union, with the General Data Protection Regulation (GDPR).

Contents
  1. Data controller
  2. Who this policy applies to
  3. The data we use
  4. Why, and on what basis
  5. Who sees your data
  6. Our service providers
  7. Data sent outside Togo
  8. How long we keep it
  9. Security
  10. Your rights
  11. Complaint to an authority
  12. Minors
  13. Changes
  14. Contact

1. Data controller

CompanyCOMOOVA SAS, simplified joint-stock company with a share capital of 30,000 FCFA
RegistrationRCCM TG-LFW-01-2025-B16-00039, Commercial Court of Lomé
Registered officeLomé, Qt. Kanyi-kope, Rue derrière le Lycée Folly-Bebe, BP 99345, Togo
Legal representativeMr AFANGBEDJI Kodjo Jeovane, President
Personal data contactinfo@comoova.com, +228 90 17 06 42

2. Who this policy applies to

It applies to couriers, drivers, carriers and merchants who use the COMOOVA Pro application. Clients have their own policy in the COMOOVA application (clients).

3. The data we use

  • Account: last name, first name, email address, phone number, profile photo, date of birth, chosen trade (courier, driver, merchant), language. The password is stored in an unreadable form.
  • Signing in with Apple or Google: the name and email address these services send us (with Apple, this may be a hidden address). We never receive your Apple or Google password.
  • Documents: a photo of your identity document (ID card or passport), its number and expiry date, a selfie taken with the camera to compare it with the document, driving licence, vehicle insurance and registration certificate.
  • Vehicle: vehicle type, registration plate and, if you add it, its photo.
  • Location: your phone's location, only when COMOOVA Pro is open and you are "Online" or on a ride, to offer you nearby requests and let the client follow their ride. It is updated about every 20 seconds. It is no longer read when you go "Offline" or when COMOOVA Pro is closed.
  • Jobs: requests received, prices offered and accepted, routes, proof-of-delivery photos, handover codes, cancellations and their reasons, ratings received and tips.
  • Money: earnings, withdrawal requests, the account where you receive your money (operator, number or account, holder's name), debts relating to cash or the Shop. Your 4-digit secret code is stored in an unreadable form. We never store a full card number.
  • Shop (merchants): shop name and photos, the Mobile Money number where clients pay you, items (photos, videos, price, stock, preparation time), orders, payment screenshots sent by clients, your confirmations or refusals of payments, refund screenshots, reviews received and reports.
  • Exchanges: messages with clients or customer service, reports and complaints, with the photos you attach.
  • Technical data: phone model and system, application version, notification identifier, and error reports when COMOOVA Pro runs into a problem.

If you turn on unlocking with your fingerprint or face, the check is done inside the phone: we receive neither your fingerprint nor an image of your face. On Android, COMOOVA Pro does not use the microphone.

4. Why, and on what basis

Creating and securing your accountPerformance of the contract
Checking your documents before giving you JobsLegitimate interest: protecting clients and preventing fraud; legal obligations for transport
Offering you requests and letting clients follow a ridePerformance of the contract
Using your location while you are OnlineYour consent (you can withdraw it in the phone's settings, or go Offline)
Collecting payments, paying out your earnings, keeping accounts and statementsPerformance of the contract and legal obligations (accounting and tax)
Managing debts (cash, delivery share, refunds made in your place)Performance of the contract and legitimate interest
Running the Shop (items, orders, reviews, reports)Performance of the contract
Keeping proof of delivery and handling complaintsPerformance of the contract and legitimate interest
Applying quality rules (cancellations, ratings, failed orders)Legitimate interest
Responding to the authorities and fighting money launderingLegal obligation
Fixing outages and improving COMOOVA ProLegitimate interest
Sending you notifications about your Jobs and ordersPerformance of the contract

5. Who sees your data

We do not sell or rent your data. It is shared only when necessary:

  • The client of a Job: your first name, photo, rating, vehicle and plate, your number so they can reach you and, during the ride, your location.
  • People with whom the client shares the tracking of their ride: the vehicle's location, until sharing stops or one hour after the ride ends.
  • Shop clients: your shop's name and photos, your items, your reviews and the Mobile Money number where they pay you.
  • The courier for a Shop order: the pick-up address and your number.
  • The COMOOVA team: only the people who need it for their work (document checks, payouts, customer service, security), with limited access.
  • The authorities: when the law requires it or by court order.

6. Our service providers

These providers process data on our behalf, following our instructions, and undertake to protect it:

SupabaseHosting of the database, accounts and files (servers outside Togo)
MapboxMaps, address search and route calculation
ResendSending emails (codes, alerts, statements)
Expo, Apple and GoogleSending notifications to the phone
Apple and GoogleSigning in with an Apple or Google account, if you choose it
Mobile Money operators (for example Mixx, Flooz) and banksClient payments and payout of your earnings

7. Data sent outside Togo

Some providers store data in other countries, in particular in Europe and the United States. These transfers are made with appropriate safeguards: contractual protection commitments and, for data of people located in the European Union, the European Commission's standard contractual clauses or an adequacy decision.

8. How long we keep it

Account, profile, documents, selfie and vehicleAs long as the account exists; erased with the account
Jobs, proof photos, messages, ratings and complaintsAs long as the account exists; erased with the account
Shop: items, orders, reviewsAs long as the account exists; erased with the account
LocationNot kept outside rides; a ride's route is kept with the ride
Error reports12 months, then erased automatically
Money owed (earnings not yet paid out, debts) and what proves itAfter the account is deleted, until it is fully settled or until the end of a dispute
History of payments and payouts (amount, date, number used)10 years, even after the account is deleted (accounting and payment disputes), then erased automatically
Proof of your deletion request (email, date)5 years after deletion, then erased automatically
Phone number of an account blocked for a debt or fraudUntil repayment or, for fraud, as long as needed to prevent a new account from being opened

When you delete your account, your data is erased within 30 days at the latest. Only what is needed to settle money still owed, the payment history (10 years) and proof of your deletion request (5 years) are kept separately.

9. Security

Exchanges between COMOOVA Pro and our servers are encrypted (HTTPS). Access to data is limited to the people who need it, each account can only read its own data, and documents are visible only to the team in charge of verification. Each withdrawal requires your secret code, checked by our servers with a lock after several wrong attempts. In the event of a data breach presenting a risk to you, we inform you and the competent authorities as the law requires.

10. Your rights

AccessKnow what data we hold about you and get a copy
RectificationCorrect inaccurate or incomplete data (Profile tab)
ErasureHave your data deleted, except what the law requires us to keep
Objection and restrictionObject to a use based on our legitimate interest, or ask for one to be suspended
PortabilityReceive your data in a machine-readable format
Withdrawal of consentWithdraw consent to location at any time, without affecting the past

To exercise a right: write to info@comoova.com from your account's email address, or go to the Profile tab, then Help. We reply within 30 days. To delete your account: the Profile tab, then Delete my account.

11. Complaint to an authority

If you believe your rights are not respected, write to us first: we will look for a solution. You can also contact the Personal Data Protection Authority (IPDCP) in Togo or, if you are in the European Union, the data protection authority of your country (in France, the CNIL).

12. Minors

You must be 18 or older to create a COMOOVA Pro account. If you believe a minor has created an account, write to info@comoova.com: we will close it.

13. Changes

If this policy changes significantly, we will notify you in COMOOVA Pro or by email at least 15 days in advance. The current version is always available in the Profile tab, then Terms and privacy, and on www.comoova.com.

14. Contact

Emailinfo@comoova.com
Phone+228 90 17 06 42
In COMOOVA ProProfile tab, then Help
AddressCOMOOVA SAS, Lomé, Qt. Kanyi-kope, Rue derrière le Lycée Folly-Bebe, BP 99345, Togo

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