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Privacy Policy

Effective date: 17 April 2026  ·  Last updated: 16 October 2026  ·  Version: 1.0

Important notice: This Privacy Policy has been drafted to comply with the Nigeria Data Protection Act 2023 (NDPA), the General Application and Implementation Directive (GAID) 2025 issued by the Nigeria Data Protection Commission, and the Nigeria Data Protection Regulation 2019 where it still applies. It has been prepared for informational purposes and should be reviewed by a qualified Nigerian legal practitioner before the platform goes live commercially. Ganusii is operated by Undaunted Lab, Lagos, Nigeria.

1. Who We Are

Ganusii is an AI-powered carpooling and ride-sharing marketplace operated by Undaunted Lab, a business incorporated in Lagos, Nigeria. We connect Lagos-based working professionals who share daily commute corridors, enabling them to carpool, split fares, and coordinate rides through WhatsApp.

For the purposes of the Nigeria Data Protection Act 2023 (NDPA), Undaunted Lab is the Data Controller for all personal data processed through the Ganusii website (ganusii.com) and any related waitlist forms.

Our contact details:
Undaunted Lab (trading as Ganusii)
Lagos, Nigeria
Email: privacy@ganusii.com
General: hello@ganusii.com

2. What Information We Collect

We only collect information that is necessary for the purpose of operating our waitlist, validating corridor demand, and preparing to match riders with drivers on the Ganusii platform.

2.1 Information you provide directly

CategoryData FieldsWho Provides It
IdentityFull nameAll users
ContactWhatsApp phone number; email address (drivers at signup; riders only if they give a work email during onboarding)All users
Commute profileHome area, work destination, morning departure window, evening return window, commute frequencyAll users
Vehicle informationSeats available, car type, vehicle ownership confirmationDrivers only
RoleRider or Driver designationAll users

2.2 Information collected automatically

When you visit ganusii.com, we may automatically collect certain technical data including:

Our hosting provider (Vercel) records basic request logs, including your IP address, and keeps them for about an hour. Our pages also load Google Tag Manager and Google Fonts, so Google receives your IP address. As of 16 October 2026 no analytics or advertising tags are switched on: the site does not run Google Analytics or the Meta (Facebook) Pixel and sets no analytics or advertising cookies. UTM tags in a link you followed are saved with your signup so we know which campaign reached you. If we switch analytics or advertising on, we will update this policy first and ask for your consent where the law requires it. We do not use this data to identify you individually without your consent.

2.3 Information we do not collect

We do not collect payment card details, bank account numbers, government ID numbers, passport details, or biometric data at any stage of the current pre-launch waitlist process.

3. How We Collect Your Information

4. Why We Collect Your Information (Legal Basis)

Under the NDPA 2023, we must have a lawful basis to process your personal data. Our legal bases are:

Processing ActivityLegal Basis (NDPA)
Adding you to the waitlist and messaging you on WhatsApp and by email about your carpool (profile set-up, matches on your route, ride confirmations)Consent — you ticked the consent checkbox on our registration form. We record the time and the wording you agreed to.
Matching you with riders or drivers on your commute corridorConsent; and legitimate interest (to provide our core service)
Sending service updates, waitlist status, and launch notificationsConsent; or legitimate interest where you are an existing contact
Analytics and website improvementLegitimate interest; where cookies are involved, consent
Complying with legal obligations (e.g., data breach notifications)Legal obligation
Safety screening and fraud preventionLegitimate interest

Where we rely on consent as our legal basis, you may withdraw that consent at any time by contacting us at privacy@ganusii.com. Withdrawing consent will not affect the lawfulness of any processing carried out before your withdrawal.

5. How We Use Your Information

We use the personal data we collect for the following purposes:

We will not use your personal data for automated decision-making that produces legal or significant effects without your explicit consent, and we will not use it to build individual profiles for commercial advertising purposes unrelated to Ganusii.

6. Who We Share Your Information With

We do not sell your personal data. We share it only as necessary with the following categories of recipients, all of whom are bound by confidentiality obligations or their own privacy policies:

6.1 Service providers and data processors

ProviderPurposeLocation
AirtableLead database — stores waitlist registrations and corridor dataUnited States
Meta (WhatsApp Business)Direct communication with registered usersUnited States
Resend (sending through Amazon SES)Sending the welcome email to drivers who registerUnited States
VercelWebsite hosting and the signup form's server functions; short-lived request logsUnited States / Global CDN
Google (Tag Manager and Fonts)Loads our tag manager script and web fonts; receives your IP address. No analytics tags are active.United States

6.2 Other Ganusii users (at matching stage only)

When you are matched into a carpool, we share your first name, WhatsApp number and pickup point only with the other people riding in the same car, so you can reach each other on the day. Riders also see their driver's car make, model and colour. Every ride is confirmed ahead; if a seat in your car goes to someone else on the route, that person receives the same details and we tell everyone in the car who is riding. We tell you this when you sign up on WhatsApp, and again when your carpool is formed. If you would rather not share your number, tell us before you are matched and we will not place you in a carpool until we can offer you another way to coordinate.

6.3 Legal and regulatory disclosures

We may disclose your personal data to law enforcement agencies, courts, or regulatory bodies (including the Nigeria Data Protection Commission) where we are legally required to do so, or where necessary to protect the safety of users or the public.

6.4 Business transfers

If Undaunted Lab or the Ganusii business is acquired, merged, or transferred to another entity, your data may be transferred as part of that transaction. We will notify you before your data is subject to a different privacy policy.

7. International Data Transfers

Some of our third-party service providers (including Airtable, Google, and Meta) are located outside Nigeria, primarily in the United States. The NDPA requires that when personal data is transferred outside Nigeria, adequate protections must be in place.

Where we transfer your data internationally, we ensure that:

For more information about the specific safeguards applied to any particular transfer, please contact us at privacy@ganusii.com.

8. How Long We Keep Your Data

Data TypeRetention PeriodReason
Waitlist registration data24 months from registration, or until you request deletionTo manage corridor launches and contact you when your route is ready
Inactive waitlist entries (no corridor launched)Deleted or anonymised after 24 monthsData minimisation principle
Active user data (after corridor launch)Duration of your use of the service, plus 12 monthsService delivery and dispute resolution
Server request logs (including IP address)About 1 hour (Vercel)Security and fixing errors
Email communications36 monthsCustomer service and legal record keeping
Legal/compliance records7 yearsNigerian statutory requirements

After the applicable retention period, personal data is either deleted securely or anonymised so that it can no longer be associated with any individual.

9. Your Rights Under the NDPA

The Nigeria Data Protection Act 2023 (NDPA) grants you the following rights in relation to your personal data. To exercise any of these rights, please email us at privacy@ganusii.com. We will respond within 30 days of receiving a verified request.

Right of Access Request a copy of the personal data we hold about you and information about how we process it.
Right to Rectification Ask us to correct any inaccurate or incomplete personal data we hold about you.
Right to Erasure Ask us to delete your personal data where we have no overriding legitimate reason to retain it.
Right to Restrict Processing Ask us to limit how we use your data in certain circumstances, for example while we investigate an accuracy complaint.
Right to Data Portability Receive your personal data in a structured, commonly used, machine-readable format to transfer to another service.
Right to Object Object to our processing of your data where we rely on legitimate interests, including processing for direct marketing purposes.
Right to Withdraw Consent Where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.
Right to Opt Out of Marketing Unsubscribe from any marketing email by clicking the unsubscribe link, or reply STOP to any WhatsApp message from us and we will stop messaging you. You can also ask to be paused or removed at any time by messaging us.

Please note that some rights are not absolute and may be subject to exemptions or limitations under Nigerian law. We will always explain clearly if we are unable to fulfil a request.

10. Cookies and Analytics

Cookies are small text files a website stores on your device. As of 16 October 2026 our website sets no cookies: no analytics, advertising or tracking cookies, and none are needed for the signup form to work.

10.1 Google Tag Manager

Our pages load Google Tag Manager, a tool that would let us add analytics later. Right now it contains no tags, so it does not run Google Analytics or the Meta Pixel. Loading it, like loading Google Fonts, sends your IP address and browser details to Google.

10.2 If this changes

If we switch on analytics or advertising tags, we will update this policy before we do and, where the law requires it, ask for your consent before any non-essential cookie is placed. You can also block or delete cookies at any time in your browser settings.

11. Children's Privacy

Ganusii is intended for working professionals aged 18 years and above. We do not knowingly collect personal data from children under the age of 18. If you believe we have inadvertently collected data from a child, please contact us immediately at privacy@ganusii.com and we will delete it promptly.

12. Data Security

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee absolute security. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, we will notify the Nigeria Data Protection Commission within 72 hours of becoming aware of it, and notify you, as required by the NDPA.

13. Links to Third-Party Sites

Our website may contain links to third-party websites, including WhatsApp and social media platforms. This Privacy Policy applies only to ganusii.com. We have no control over and accept no responsibility for the privacy practices of any third-party websites. We encourage you to read the privacy policy of any site you visit.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our business practices, legal requirements, or the services we offer. When we make material changes, we will:

Your continued use of the Ganusii website after changes have been posted constitutes your acceptance of the updated policy.

15. How to Complain

If you believe your data protection rights have been violated, you have the right to lodge a complaint with Nigeria's data protection authority:

Nigeria Data Protection Commission (NDPC)
Website: ndpc.gov.ng
Email: info@ndpc.gov.ng
Phone: +234 916 061 5551
Address: 1919 Cadastral Zone C06, Mbora District, opposite Efab City Estate, Life Camp, FCT Abuja, Nigeria

We would, however, appreciate the opportunity to address your concerns directly before you contact the regulator. Please contact us first at privacy@ganusii.com.

16. Contact Us

For any questions, requests, or complaints regarding this Privacy Policy or our data practices, please contact our Data Protection contact at:

Undaunted Lab (Ganusii)
Email: privacy@ganusii.com
General enquiries: hello@ganusii.com
WhatsApp: +234 911 888 1185
Lagos, Nigeria