Privacy Policy

Who we are

DriverGuide is published by Frimpong Studios, an independent developer based in Ghana ([YOUR FULL LEGAL NAME TBC], [ADDRESS IN GHANA TBC]). In this policy "we" and "us" mean Frimpong Studios. We decide how your data is used and why, which makes us the "data controller".

Contact for anything about your data: [CONTACT EMAIL TBC]. We are registered with the Ghana Data Protection Commission under number [DATA PROTECTION COMMISSION REGISTRATION NO. TBC].

What we keep, and when

What stays on your phone: your answers when you set up the app (country, goals, topics, pace and reminder time), your colours, sound settings, and your progress if you haven't signed in. We don't receive these unless you make an account, and then only your trip (above).

The website has no accounts, no cookies and no analytics. Its fonts and pictures come from our own server.

What we don't do

• We don't sell your personal data.
• We don't ask for your location, and the app doesn't use it. The road trip is a game; it is not tracking where you are.
• We don't read your contacts or photos. Friends are added by code, handle or search.
• We don't use advertising trackers or build advertising profiles.
• We don't show your phone number to other learners.

Why we may use your data

The law says we need a reason. Ours are:

• Your consent, for the waitlist. You tick a box when you join, and you can take it back at any time.
• To provide the app you asked for, for accounts, saved progress, friends and calls.
• Our legitimate interests in keeping the service secure, stopping abuse and understanding which countries people want, in ways that don't override your rights.
• The law, where we must keep or share something.

Who sees it

• Your friends see your name, handle, car and colours, how far you've got on the trip, and your kilometres this week. They don't see your phone number.
• Other learners can find you by handle or name only if you leave "findable" on. A public leaderboard also lists only people who left it on. Turn it off in your account and you disappear from both. Anyone who has your exact friend code can still send you a request.
• Companies that help us run DriverGuide, only for that job:
  • Nalo Solutions, which sends text messages in Ghana. It gets your phone number and the message (a sign-in code, or the one text we send when the app opens).
  • [HOSTING PROVIDER AND COUNTRY TBC], where our servers and database are.
  • [EMAIL SERVICE TBC], to send you the one email when the app opens.
  • Google (Firebase Cloud Messaging) and Apple, which deliver notifications to Android phones and iPhones. They receive your phone's notification token and the text of the notification (a friend's name and a short line).
  • Google Play and the Apple App Store, which handle downloads and, later, payments. They have their own privacy policies.
• Authorities, if the law requires it.

Some of these companies are outside your country. Where that happens we make sure the data is protected as the law requires [TRANSFER SAFEGUARDS TBC].

Ads

DriverGuide shows ads on its map. They are chosen by where you are on the road trip, not by who you are, and they don't use anything about you personally. We count views and taps as totals with no account or device number attached. We will not use profile-based ads for anyone under 18, or anyone whose age we don't know. If this ever changes, we will tell you and ask first.

Young learners

DriverGuide is for people learning to drive. You can use the lessons at any age without an account or a waitlist sign-up. To make an account or join the waitlist you must be 16 or older. The app asks you to confirm this, and we don't knowingly collect data from anyone younger. If you are a parent or guardian and think a child has given us their details, write to us and we will delete them.

How long we keep it

• Waitlist: until we have told you the app is open in your country, then we delete it within 30 days. You can ask us to remove you sooner.
• Account and trip: until you delete your account. Deleting it in the app (Me, then Account, then Delete account) removes your profile, trip, friends and calls, and ends all your sign-ins.
• Proof of what you agreed to: the date and the version of the wording you agreed to is kept with your sign-up or account, and deleted with it.
• Sign-in codes: they stop working after 10 minutes.
• Friend news: 14 days.
• Totals with no name: as long as we need them for reports, and they can't be traced to you.
• Backups: deleted data can stay in our backups for up to 35 days before it is overwritten.

Your rights

Wherever you live, you can ask us to tell you what we hold about you, to fix it, to delete it, to stop using it, or to give you a copy. If we use your data because you agreed, you can take that back at any time, and it won't affect what we did before. You can also object to uses based on our legitimate interests.

These rights come from the law where you live, including the Ghana Data Protection Act, 2012 (Act 843), the Nigeria Data Protection Act, 2023, and the UK and EU GDPR. To use them, write to [CONTACT EMAIL TBC] from the email address or phone number you gave us, so we know it's you. We aim to answer within one month.

If you are not happy with our answer, you can complain to the data protection authority where you live. In Ghana, that is the Data Protection Commission.

Your choices, in one place

• Leave the waitlist: every message we send has an unsubscribe link, and the same link works on the unsubscribe page. Or write to us.
• Delete your account: in the app (Me, then Account, then Delete account), or follow these steps if you can't get into the app. It removes your data straight away and can't be undone.
• Be less visible: turn off "Find me by name or username" in your account. You leave search and the public leaderboard.
• Texts and emails: we send you a sign-in code when you ask for one, and one message when the app opens in your country. We don't send marketing, and we don't pass your details to anyone to do so.
• Notifications on your phone: off until you switch them on in the app (we offer after your first friend, and your phone asks too). Turn them off, or pick which kinds you want (calls from jail, friend requests, friends' news), in Me, then Account. We send at most 3 a day, not counting calls, and none from 21:00 to 07:00 on your phone's clock. A notification shows a friend's name and a short line, so it can appear on your lock screen.

If you live in the EU, EEA or UK

The GDPR and UK GDPR apply to you. Section "Why we may use your data" gives our legal reasons. You have the rights in "Your rights", and you can also ask us to move your data to another service (portability). Giving us your data is your choice, but without an email or phone number we can't put you on the waitlist, and without a phone number we can't make you an account. We don't make decisions about you by computer alone that have legal effects on you.

Our servers and some companies that help us run DriverGuide are outside the EU, EEA and UK, including in Ghana [HOSTING COUNTRY TBC]. When your data goes there we rely on [TRANSFER MECHANISM TBC: for example standard contractual clauses, or the provider's adequacy decision]. Our representative in the EU/UK is [EU/UK REPRESENTATIVE TBC, IF REQUIRED].

You can complain to your data protection authority, such as the Information Commissioner's Office in the UK or your national authority in the EU. We would like to fix the problem first, so please write to us.

If you live in California or another US state

State privacy laws such as the California Consumer Privacy Act (CCPA, as amended by the CPRA) give residents rights over their personal information. In the past 12 months we collected these kinds of information, from you, for the reasons in "What we keep, and when": identifiers (email, phone number, name or nickname, handle, friend code, IP address), commercial information (none yet; paid features are not on sale), internet or app activity (your lessons, answers and friend activity inside DriverGuide), and inferences (none). We do not collect precise location, health, biometric or similar sensitive information.

• We do not sell your personal information and we do not share it for cross-context advertising, and we have not in the past 12 months. We don't knowingly sell or share data of anyone under 16.
• You have the right to know and get a copy of what we hold, to have it deleted or corrected, to limit use of sensitive information (we don't use any), and not to be treated worse for using these rights.
• To use them, write to [CONTACT EMAIL TBC] from the email address or phone number you gave us. We will check it's you, and answer within 45 days. Someone acting for you can write on your behalf with your written permission.

We don't respond differently to "Do Not Track" signals, because the website uses no tracking.

If you live in Ghana or Nigeria

We follow the Ghana Data Protection Act, 2012 (Act 843) and the Nigeria Data Protection Act, 2023. We collect only what we need, tell you why, keep it safe, keep it no longer than needed and let you see, fix or delete it. You can complain to the Data Protection Commission in Ghana or the Nigeria Data Protection Commission.

Keeping it safe

Connections to our servers are encrypted. Sign-in codes and sign-in keys are stored as hashes, so we can't read them back. We limit how often a phone number can ask for a code and how often the waitlist form can be used. No system is perfectly safe. If something goes wrong that puts your data at risk, we will tell you and the authorities as the law requires.

Changes to this policy

If we change how we use your data, we will update this page and its date. For big changes we will also tell you in the app or by email before they start.

Contact

Frimpong Studios
[ADDRESS IN GHANA TBC]
[CONTACT EMAIL TBC]