Privacy Policy

This Privacy Policy explains how Kumbai B.V. collects, processes, and uses your personal data. It applies to the Kumbai website (kumbai.io) and the Kumbai mobile app. In this document, "Kumbai" refers to Kumbai B.V.

We value your privacy and strive to ensure the confidentiality of your information. Our commitment is to be transparent about how we handle your personal data, why we collect it, and how you can manage it. This Policy is written to align with the Landsverordening Bescherming Persoonsgegevens (Curaçao's National Ordinance on the Protection of Personal Data), which is overseen by the College Bescherming Persoonsgegevens (the Curaçao Data Protection Authority).

What is personal data?

Personal data refers to any information related to an identified or identifiable person.

What data does Kumbai collect and why?

Kumbai processes only the personal data necessary to provide the services you request. Additionally, we use this data to enhance our services and tailor them to your needs (set up, manage and offer services that meet your needs). We may also retain data to comply with legal obligations. Kumbai collaborates with various partners, including IT service providers, to maintain and improve our technology infrastructure and security.

Who does Kumbai collect personal data from?

We collect personal data from:

• Customers using our taxi services.
• Taxi drivers.
• Representatives of business partners.
• Visitors to our website.
• Employees and job applicants.

How does Kumbai collect personal data?

Kumbai may collect your personal data in the following situations:

• When you contact us by phone.
• When you book or use our services.
• When you sign a service agreement or partner agreement with Kumbai.
• When you communicate with us via email or our contact forms.
• When you use Kumbai's website, mobile app, or other digital services.
• When you interact with Kumbai's social media platforms or leave a review.

Legal basis and purpose of data processing

Kumbai processes your personal data for various legitimate purposes, including:

• Fulfilling agreements, such as booking a taxi ride.
• Improving service quality, such as reducing waiting times.
• Ensuring the safety of drivers and passengers.
• Complying with legal requirements (e.g., tax regulations).
• Improving our website and customer experience.
• Preventing fraud and ensuring security.

Data security

Kumbai will gather and handle data using appropriate technical and organizational safeguards to ensure the security of personal information. These measures protect against unauthorized or unlawful processing (such as cyber threats) as well as accidental loss, destruction, or damage.

Cookies and website data collection

Kumbai uses cookies to improve website functionality and user experience.

• Functional cookies ensure smooth website performance.
• Analytical cookies help us analyze user behavior to optimize services.

We use tools to track how users engage with our website and mobile app. These tools may collect data such as IP addresses or mobile IDs. Users can opt out of cookies by adjusting their browser settings.

Newsletter and communication

Users can subscribe to our newsletter (if available) to receive updates about promotions, services, and other relevant news. Subscriptions require explicit consent, and users can unsubscribe at any time.

Third-party data sharing

For the purposes outlined in this Policy, Kumbai may disclose your personal data to third parties, including but not limited to:

• Service-related third parties — organizations relevant to the services we provide.
• Regulatory and legal compliance — entities we engage with to fulfill legal and regulatory obligations.
• Third-party suppliers — service providers that assist with processing personal data, such as IT providers, communication service providers, or other outsourced support services.

Kumbai ensures that personal data is shared with these third parties only for the purposes and legal grounds stated in this Policy. Any third party receiving your personal data is independently responsible for compliance with privacy regulations. Kumbai is neither responsible nor liable for how these third parties process your data. However, if a third party acts as a data processor on behalf of Kumbai, a data processing agreement will be established to ensure compliance with applicable legal requirements.

External websites and third-party privacy policies

Kumbai's website may contain links to external websites. However, Kumbai is not responsible for how those websites handle personal data. Users should review the privacy policies of any external sites they visit.

Data retention policy

Kumbai does not retain personal data longer than necessary for the purposes for which it was collected.

Your rights

When your personal data is collected and processed, you are entitled to the following rights:

• Right to information — you have the right to be informed about how your personal data is collected and used.
• Right to access — you may request access to and copies of the personal information stored in our records.
• Right to rectification — if you believe your personal data is inaccurate or incomplete, you can request corrections or updates.
• Right to erasure — you may request the deletion of your personal data at any time.
• Right to withdraw consent — you can withdraw your consent for data processing by contacting us at info@kumbai.io.
• Right to restriction of processing — you can request that the processing of your personal data be limited or suppressed.
• Right to data portability — you have the right to obtain and transfer your personal data for use across different services.
• Right to object to marketing — you may opt out of receiving personalized marketing communications.
• Right to lodge a complaint — if you are dissatisfied, you have the right to file a complaint with the local data protection authority.

Please note that these rights are not absolute, and in certain situations, Kumbai may be legally required to deny requests to comply with regulatory obligations.

Identity Verification & Biometric Data

This section reflects the implementation of Apple's TrueDepth camera API in our driver applications.

Where identity verification is enabled, the app may process biometric data (facial imagery) to verify your identity and prevent misuse. The app may use depth data for liveness detection. This depth data is processed locally on your device and is not stored or transmitted. The app may ask you to take a selfie, which may be securely transmitted to our trusted Service Providers solely for verification purposes and is deleted after verification is completed. Biometric data is used only for identity verification and liveness detection, and not for advertising, marketing, or profiling.

We do not collect, store, or transmit any biometric data (including depth maps, face mesh, or ARFaceAnchor data) and do not create biometric templates. All data is used temporarily and discarded immediately after processing.

Privacy Policy updates

This Privacy Policy may be updated periodically to take into consideration changes in legislation, technology, or other issues that may arise. The most recent version will always be available on Kumbai's website.

Contact

Questions about this policy? Email info@kumbai.io.