Privacy Policy

Wobble operates a technology platform that facilitates ordering, payments, merchant discovery and delivery services.

For purposes of applicable data-protection law, the entity responsible for determining why and how your personal information is processed will generally be:

WOBBLE TECHNOLOGIES LIMITED
Trading as: Wobble
Registered Address: 27, central town golf course RD, Kasama, Zambia
Email: support@gowobble.com
Telephone: +260 962 901 793

Where required by law, Wobble will maintain applicable registrations with the relevant Zambian data-protection authority.

The information we collect depends on how you use Wobble.

2.1 Account Information

When you register for or use a Wobble account, we may collect:

• your full name;
• email address;
• telephone number;
• account identifier;
• profile information;
• authentication information; and
• account preferences.

Passwords and authentication credentials may be processed through secure authentication infrastructure and are not intended to be available to Wobble personnel in readable form.

2.2 Delivery and Address Information

To fulfil orders and delivery requests, we may collect:

• delivery address;
• pickup address;
• latitude and longitude;
• map pin location;
• building name;
• building type;
• nearby landmarks;
• entrance or access instructions;
• delivery notes; and
• saved addresses such as Home, Work or Other.

You should avoid including unnecessary sensitive or confidential information in delivery instructions.

2.3 Location Information

With appropriate device permissions, Wobble may collect location information from your device.

Depending on the feature being used, this may include:

• approximate location;
• precise GPS location;
• latitude and longitude;
• location accuracy;
• location timestamps; and
• location-related device information.

We may use location information to:

• identify merchants available near you;
• determine whether a merchant can deliver to your area;
• select relevant products or services;
• calculate delivery distances;
• calculate or estimate delivery charges;
• identify delivery pickup and drop-off locations;
• support navigation;
• prevent fraud;
• improve location accuracy; and
• operate location-dependent features.

You may control location permissions through your device settings.

Certain features may not work correctly if location access is disabled.

Where possible, Wobble may allow you to manually enter or select your location instead.

When a delivery partner is performing a delivery through Wobble, Wobble may process that delivery partner's location information.

This may include:

• current latitude and longitude;
• GPS coordinates;
• timestamps;
• delivery route information;
• location accuracy;
• approximate distance from pickup or delivery points; and
• delivery status.

A customer's application may display the approximate current position of the delivery partner assigned to the customer's active order.

Delivery-partner location information is used for purposes such as:

• assigning delivery requests;
• determining nearby available delivery partners;
• delivery navigation;
• estimating arrival times;
• displaying delivery progress;
• investigating delivery incidents;
• preventing fraud;
• improving dispatching; and
• protecting customers, merchants and delivery partners.

Wobble should not make live delivery-partner location information available to customers after it is no longer reasonably required for the delivery.

Additional rules governing delivery-partner location information may be contained in the Wobble Delivery Partner Agreement and Delivery Partner Privacy Notice.

When you place or receive an order, we may collect information including:

• order number;
• products ordered;
• quantities;
• merchant information;
• order amount;
• delivery charge;
• service fees;
• discounts;
• order status;
• payment status;
• transaction references;
• order timestamps;
• cancellation information;
• refund information;
• merchant preparation information;
• assigned delivery partner; and
• delivery completion information.

We may retain transaction records where necessary for financial accounting, dispute resolution, fraud prevention and legal compliance.

Wobble may support payments through third-party payment providers, banks, mobile-money operators or other authorised payment services.

Depending on the payment method, we may process:

• payment method;
• mobile-money provider;
• telephone number associated with a payment;
• transaction reference;
• payment amount;
• payment status;
• payment timestamps; and
• refund information.

Wobble does not need your Mobile Money PIN

You should never provide your mobile-money PIN, banking password, OTP or other secret authentication credential to Wobble, a merchant or a delivery partner.

Where authentication is required by a mobile-money provider or financial institution, that authentication should normally occur through the provider's authorised system.

Wobble may receive confirmation from a payment provider that a transaction succeeded, failed, expired or was reversed.

Payment providers may process your information under their own privacy policies and regulatory obligations.

When you use Wobble, we may automatically collect technical information including:

• device type;
• operating system;
• application version;
• browser type;
• IP address;
• device identifiers;
• language;
• network information;
• application events;
• crash information;
• session information;
• timestamps; and
• security-related logs.

We may use this information for:

• application functionality;
• troubleshooting;
• analytics;
• performance monitoring;
• security;
• fraud prevention; and
• improving Wobble.

When you communicate with Wobble, we may process information contained in:

• customer-support requests;
• emails;
• telephone communications;
• chat messages;
• complaints;
• feedback;
• dispute information; and
• communications related to orders.

Where lawful and appropriate, communications may be retained for quality assurance, fraud prevention, dispute resolution and legal compliance.

If Wobble enables ratings, reviews, photographs or other submissions, we may collect:

• ratings;
• written reviews;
• photographs;
• merchant feedback;
• delivery feedback; and
• related account information.

Some information you intentionally post may be visible to merchants, delivery partners or other Wobble users depending on the feature.

Merchants may provide Wobble with information necessary to operate the platform.

This may include information regarding:

• orders;
• fulfilment;
• cancelled orders;
• product availability;
• customer complaints;
• refunds; and
• suspected fraud.

Merchants should only use customer information made available through Wobble for legitimate purposes associated with the order and their legal obligations.

Delivery partners may provide or generate information including:

• delivery status;
• pickup confirmation;
• location;
• delivery confirmation;
• photographs where required for delivery evidence;
• reported customer issues;
• timestamps; and
• safety incident information.

This information may be associated with the relevant customer's order.

We may receive information from third parties including:

• payment providers;
• mobile-money operators;
• authentication providers;
• mapping providers;
• telecommunications providers;
• merchants;
• delivery partners;
• fraud-prevention services; and
• regulators or law-enforcement authorities where legally permitted.

Wobble may process personal information where necessary to:

Provide the Wobble service

For example:

• creating and maintaining accounts;
• showing nearby merchants;
• processing orders;
• facilitating payments;
• arranging deliveries;
• calculating delivery charges;
• communicating order status;
• providing customer support; and
• administering refunds.

Protect Wobble and its users

We may process information for:

• detecting fraud;
• preventing account takeover;
• detecting suspicious transactions;
• verifying activity;
• preventing abuse;
• maintaining security;
• investigating incidents; and
• enforcing our Terms and Conditions.

Meet legal obligations

We may process or retain information where required for:

• accounting;
• tax obligations;
• regulatory requirements;
• lawful government requests;
• court orders;
• dispute resolution; and
• other legal obligations.

Improve our services

We may use appropriate data to:

• understand how Wobble is used;
• diagnose technical problems;
• improve navigation and search;
• improve merchant recommendations;
• improve delivery estimates;
• develop new features;
• monitor system reliability; and
• improve user experience.

Where reasonably possible, aggregated or de-identified information may be used for analytics and service improvement.

Where applicable law requires a lawful basis for processing personal information, Wobble may rely on one or more appropriate grounds, including:

• your consent;
• performance of a contract or actions necessary to provide a service you requested;
• compliance with a legal obligation;
• protection of legitimate interests where permitted and balanced against your rights;
• protection of vital interests where applicable; and
• other grounds permitted under applicable law.

Where processing relies specifically on consent, you may withdraw that consent where permitted.

Withdrawal of consent does not necessarily affect processing that occurred lawfully before consent was withdrawn.

Wobble does not sell your personal information to advertisers or data brokers.

We may share information where reasonably necessary with the following categories of recipients.

14.1 Merchants

When you place an order, the relevant merchant may receive information required to prepare and fulfil the order.

This may include:

• customer name;
• order information;
• delivery or pickup information where necessary;
• customer instructions; and
• relevant contact information.

Merchants must not use customer information received through Wobble for unrelated marketing or other unauthorised purposes.

14.2 Delivery Partners

A delivery partner assigned to your order may receive information reasonably necessary to complete the delivery, including:

• your name or appropriate customer identifier;
• pickup information;
• delivery location;
• address;
• map pin;
• telephone contact functionality or number where necessary;
• delivery instructions; and
• order information necessary for delivery.

Delivery partners must not use this information for unrelated purposes.

14.3 Service Providers

We may use service providers for purposes such as:

• cloud infrastructure;
• database hosting;
• authentication;
• communications;
• maps;
• location services;
• analytics;
• application monitoring;
• customer support;
• payment processing; and
• fraud prevention.

These providers may process personal information only as permitted under their agreements with Wobble and applicable law.

Payment information may be transmitted to:

• mobile-money operators;
• banks;
• payment gateways;
• payment processors; and
• financial-service providers

where necessary to process or verify payments.

Those organisations may independently be required to retain transaction information under financial-services or other laws.

Wobble may disclose information where reasonably believed to be required by law, including in response to:

• lawful court orders;
• warrants;
• regulatory requirements;
• lawful law-enforcement requests;
• tax requirements; or
• other legally binding requests.

We may also disclose information where legally permitted and reasonably necessary to:

• prevent serious fraud;
• investigate criminal activity;
• protect the safety of a person;
• establish or defend legal claims; or
• protect the security of the Wobble Platform.

Wobble will not voluntarily provide personal information to authorities merely because someone requests it where lawful authority is required.

Some of the technology providers used by Wobble may operate infrastructure or personnel outside Zambia.

Where personal information is transmitted, accessed or stored outside Zambia, Wobble will take measures required under applicable law to protect that information and ensure that any applicable cross-border data-transfer requirements are addressed.

Where Zambian law requires particular categories of information to be stored or processed within Zambia, Wobble will comply with those requirements.

Wobble does not intend to retain personal information indefinitely.

Retention periods may differ depending on the type of information and why it is needed.

We may retain information for as long as reasonably necessary to:

• maintain your account;
• provide services;
• fulfil completed transactions;
• meet financial and tax obligations;
• prevent fraud;
• maintain security;
• resolve disputes;
• enforce agreements; and
• comply with legal requirements.

When information is no longer reasonably required, Wobble may securely delete, anonymise or otherwise dispose of it in accordance with applicable law and our retention procedures.

Certain records may need to be retained after an account is deleted where required by law or necessary for legitimate legal purposes.

Where available, you may request deletion of your Wobble account through the application or by contacting Wobble.

Deleting an account may result in deletion or anonymisation of personal information that Wobble is no longer required to retain.

Account deletion does not necessarily require deletion of information that Wobble must retain for reasons such as:

• financial records;
• tax requirements;
• fraud prevention;
• legal disputes;
• regulatory obligations; or
• enforcement of legal rights.

Subject to applicable law, you may have rights concerning personal information about you.

These may include rights to:

• be informed about processing of your personal information;
• request access to personal information held about you;
• request correction of inaccurate information;
• request deletion where legally applicable;
• object to certain processing;
• restrict certain processing;
• request portability of personal information where legally applicable;
• request human review of qualifying automated decisions;
• withdraw consent where processing depends upon consent; and
• lodge a complaint with the Data Protection Commission or exercise other rights provided under applicable data-protection law.

Some rights may be subject to lawful exemptions.

To exercise a privacy right, contact:

support@gowobble.com

Wobble may need to reasonably verify your identity before acting on a request in order to prevent unauthorised access to personal information.

Wobble will request device location permissions where required by a feature.

Your operating system may allow you to choose options such as:

• precise or approximate location;
• location while using the application;
• one-time access; or
• no location access.

Availability of these options depends on your device.

You may change permissions through your device settings.

Removing permission may prevent certain features from functioning correctly.

Where Wobble sends promotional marketing, it will do so in accordance with applicable legal requirements.

You may be able to opt out through:

• an unsubscribe facility;
• application notification settings;
• account preferences; or
• contacting Wobble.

Opting out of marketing will not prevent Wobble from sending essential service communications such as:

• order confirmations;
• payment notices;
• security alerts;
• delivery updates; or
• account-related notices.

Wobble may send push notifications concerning:

• order activity;
• courier arrival;
• payment status;
• account security;
• service updates; and
• promotions where permitted.

You may manage push-notification permissions through your device.

Wobble's websites may use cookies, local storage and similar technologies.

Essential technologies may be used for:

• authentication;
• security;
• maintaining sessions;
• remembering preferences;
• application functionality;
• fraud prevention;
• fraud prevention; and
• recording your browser-storage choice.

With your permission, functional browser storage may also remember your basket and selected location on the device.

Wobble does not currently use advertising cookies or cross-site advertising trackers.

Where legally required, Wobble will request consent before using non-essential tracking technologies.

Wobble may introduce privacy-appropriate analytics tools to understand:

• feature usage;
• application performance;
• crashes;
• general usage patterns;
• customer journeys; and
• technical problems.

Before optional analytics are introduced, Wobble will update this Policy and request consent where required. Analytics will be configured to collect only information reasonably necessary for legitimate operational purposes.

Wobble may use automated systems to assist with functions such as:

• matching delivery partners;
• determining delivery availability;
• estimating delivery times;
• identifying potentially fraudulent transactions;
• recommending merchants or products; and
• detecting abnormal account activity.

Where a decision produces significant legal or similarly significant effects and applicable law provides additional rights, Wobble will comply with those requirements.

Wobble uses administrative, technical and organisational safeguards intended to protect personal information.

These may include:

• access controls;
• authentication controls;
• encrypted network communications;
• secure cloud infrastructure;
• role-based permissions;
• monitoring;
• audit logging;
• credential-management practices;
• backups;
• security updates; and
• incident-response procedures.

However, no online system can guarantee absolute security.

Users are responsible for keeping their own account credentials and devices secure.

If Wobble becomes aware of a personal-data breach, Wobble will investigate the incident and take appropriate measures to contain and remediate it.

Where notification to the Data Protection Commission, affected users or another authority is required under applicable law, Wobble will make the required notification.

Wobble is not intended to knowingly collect personal information directly from children who do not have the legal capacity to use the service independently.

If Wobble learns that personal information relating to a child has been collected unlawfully, appropriate steps will be taken to delete or otherwise lawfully handle that information.

Where services involving minors are permitted, additional protections may apply.

Wobble does not intentionally require users to provide sensitive personal information unless necessary for a lawful and clearly identified purpose.

Users should not include unnecessary sensitive information in:

• delivery notes;
• reviews;
• customer-support messages; or
• merchant instructions.

Where Wobble processes information classified as sensitive personal data under applicable law, additional safeguards will be applied as required.

Information made available to merchants and delivery partners through Wobble must only be used for legitimate Wobble-related purposes.

For example, a delivery partner must not:

• retain a customer's phone number for personal reasons;
• contact a customer after a delivery for an unrelated purpose;
• publish a customer's address;
• share delivery information with unauthorised persons; or
• use customer information for private marketing.

Likewise, merchants must not use Wobble customer information for unrelated direct marketing unless they independently have a lawful basis to do so.

Misuse may result in suspension or termination and may expose the person responsible to legal action.

Wobble may maintain records relating to suspected:

• payment fraud;
• chargeback abuse;
• refund fraud;
• fake accounts;
• promotion abuse;
• account takeover;
• courier fraud;
• merchant fraud; and
• other security threats.

Access to such information will be limited according to operational and security requirements.

Wobble may update this Privacy Policy to reflect:

• changes in our services;
• new features;
• changes in technology;
• changes in legal requirements;
• regulatory guidance; or
• changes in our privacy practices.

The current version will display its effective date and last-updated date.

Where a change materially affects how personal information is processed, Wobble will provide appropriate notice and obtain consent where consent is legally required.

If you believe Wobble has improperly handled your personal information, please contact Wobble first so that we can investigate the issue.

Privacy Contact:
support@gowobble.com
+260 962 901 793

You may also have the right to lodge a complaint with the relevant Zambian data-protection authority.

Personal-data protection in Zambia is overseen by the Data Protection Commission under the Data Protection Act.

Nothing in this Privacy Policy prevents you from exercising any right to approach the Commission where applicable.

Commission information and complaint channels are available at www.dataprotection.gov.zm.

This Privacy Policy is governed by the laws of the Republic of Zambia, including applicable data-protection legislation.

For questions, requests or concerns regarding this Privacy Policy or Wobble's handling of personal information, contact:

Wobble
Operated by: WOBBLE TECHNOLOGIES LIMITED
Registered Address: 27, central town golf course RD, Kasama, Zambia

Privacy: support@gowobble.com
Support: support@gowobble.com
Telephone: +260 962 901 793