LANE APP PRIVACY POLICY

Introduction

Lane App Ltd ("we," "our," or "us") owns and operates Lane, a platform that provides booking and hospitality management services. Lane is a comprehensive application and website designed to allow users to seamlessly, swiftly, and securely: Make hotel and short-term rental reservations; Book flights, trains, and bus tickets; Hire cars; Access property rental services; (collectively "Services").

Our Platform is designed to provide a convenient, secure, and efficient experience for all users. This Privacy Policy explains how we collect, use, store, and protect your personal information when you access or use our Platform.

1. Definitions

2. The Personal Data we collect and how we collect them

We only collect information that we need to provide our services to you as User.

3. How We Use Personal Data

We use the Personal Data we collect for the following purposes:

• A. To enable users to create and maintain accounts on our Platform, access secure features, and enjoy our booking and hospitality services.
• B. To process your hotel and short-term rental reservations, flight, train, and bus bookings, car hire requests, and other services accessed through Lane. This includes sending confirmations, updates, and other service-related notifications.
• C. To contact you via email, phone calls, SMS, in-app notifications, or other electronic means regarding: Your bookings and transactions; Your account activity; The use of our Platform; New features, updates, and changes to our services; and Security alerts and important notices
• D. To detect, prevent, and manage risks relating to fraud, unauthorized activity, or illegal conduct, using internal tools and vetted third-party service providers.
• E. To analyze usage trends, improve Platform functionality, enhance user experience, and develop new products, features, or service offerings.
• F. To send newsletters, promotions, and marketing content tailored to you. You may opt out of receiving marketing communications at any time.
• G. To verify your identity and the information you provide, using internal systems and third-party verification tools, in line with our legal and regulatory obligations.
• H. To maintain accurate and up-to-date records of our users, transactions, and interactions.
• I. To manage and resolve complaints or disputes, including responding to investigations or requests from law enforcement or regulatory authorities.
• J. To monitor the performance and security of our Platform and ensure the continuous delivery and stability of our services.
• K. For any other purpose disclosed to you at the time we collect your Personal Data or as otherwise permitted by law.

4. The lawful basis we rely on for processing your personal information

Our processing of your Personal Information is lawful if:

• You have consented to the processing of your Personal Information for one or more specific purposes; or
• The processing is necessary for the performance of a contract to which you are a party, or to take steps -your request- prior to entering a contract; or
• Processing is necessary for compliance with a legal obligation to which we are subject to; or
• Processing is necessary to protect your vital interests or that of another natural person; or
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of an official public mandate vested in us.
• Processing is necessary for our legitimate business interests, provided these interests do not override your rights and freedoms. These legitimate interests include:

5. How We Share Personal Data

6. Cookie

We use cookies and similar tracking technologies to track the activity on our service and store certain information. For more information on Cookies and how you can control them, please see our Cookies Policy.

7. How We Protect Your Information

We are committed to managing your Personal Information in line with global best practices. We protect your Personal Information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. We also use industry-recommended security protocols to safeguard your Personal Information and maintain a data breach procedure to deal with incidents of breach. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files and only granting access to Personal Information to only employees who require it to fulfil their job responsibilities.

If you notice or suspect any breach of your personal information or suspect that your access credentials have been compromised, please contact our Data Protection Officer dpo@laneapp.com immediately. This will enable us to take the necessary steps towards ensuring the security of your Personal Information or account. We will report any breaches that will compromise your rights and freedoms to the relevant regulatory authority within 72 hours of discovery of the breach.

8. Your Data Protection Rights

You have the following rights regarding the Personal Data we control about you:

• You can request confirmation of whether we process Personal Data relating to you, and if so, to request a copy of that Personal Data.
• You can request that we rectify or update your Personal Data that is inaccurate, incomplete, or outdated.
• You can request that we erase your Personal Data in certain circumstances such as where the data is no longer required. However, this right is limited as we may be required by law to retain the data.
• You can request that we restrict the use of your Personal Data in certain circumstances. When such a request is made, it means your Personal Data can only be used for certain purposes e.g., to exercise legal rights
• You can request that we export your Personal Data (which you have given to us) that we hold to another company, where technically feasible.
• You can object to the processing of your Personal Information for marketing purposes by adjusting your preference on the settings page or by clicking the unsubscribe link in our marketing emails.
• You can object to automated decision-making and processing and request for human review of the decision.
• The basis for processing your Personal information is consent. You can withdraw your consent at any time for further processing of your Personal Data. Please note that where you object to the processing of your Personal Information, we may not be able to provide our Services to you.
• If you have an account with us, you can review your User Account settings, update your Personal Information on it, and close your user account at any time, subject to the User Terms and Conditions.
• If you wish to exercise any of these rights, you may write to us at [please insert dedicated email for privacy]

9. Storage Limitation

• We retain your Personal Data for as long as is reasonably necessary to provide our services to you, to operate and maintain your account, or for any other purpose described in this Privacy Policy. Your information will also be kept for as long as your account remains active and we have your consent to process your data. Where a dispute or legal claim arises, we may continue to retain relevant information until the matter is resolved or the applicable limitation period expires.
• Our retention of Personal Data is further influenced by legal, regulatory, accounting, administrative, and operational requirements. This means that even after you close your account, we may be required to retain certain personal and transactional information in order to comply with statutory obligations, resolve disputes, enforce our agreements, maintain financial records, or meet other legitimate business needs.
• Once retention is no longer necessary, we will either securely delete your Personal Data or anonymize it so that it can no longer be linked to you.

10. Transfer of Personal Data

In the course of providing our booking and hospitality services, we may rely on third-party service providers whose servers or data centres are located outside Nigeria. This may involve transferring your Personal Data to foreign countries where such servers or systems are hosted. Any transfer of your Personal Data outside Nigeria will be carried out in accordance with applicable data protection laws and regulations.

We will only transfer your Personal Data outside Nigeria when one or more of the following conditions apply:

• You have given your consent for your data to be transferred.
• The transfer is necessary for the performance of a contract between you and Lane App, including the processing of bookings or reservations with hotels, airlines, transportation providers, and other service partners based outside Nigeria.
• The transfer is necessary to conclude or perform a contract between us and a third party for your benefit—for example, where international travel or overseas accommodation partners require your information.
• The transfer is required for reasons of public interest as permitted by law.
• The transfer is necessary for the establishment, exercise, or defence of legal claims.
• The transfer is necessary to protect your vital interests, particularly in circumstances where you are unable to provide consent.

Regardless of destination, we will take all reasonable steps to ensure that your Personal Data is transmitted, stored, and processed securely and that appropriate safeguards are in place to maintain its confidentiality and integrity.

11. Policy Violations

Any violation of this Privacy Policy should be brought to the attention of the Data Protection Officer for appropriate sanctioning and treatment. By signing up to our Platforms, you certify that the information provided for registration is correct to the best of your knowledge. Also, when providing the personal data of any other person, you confirm that you are only providing accurate and up-to-date data in accordance with their instructions and can provide evidence of their consent to the data processing described in this Policy as and when required by us. Please note that any attempt to mislead may result in prosecution and the deliberate provision of inaccurate data results in a privacy violation.

12. Dispute Resolution

We are dedicated to ensuring that you are satisfied with our management of your Information. However, in the unlikely event that you have a complaint, please contact us via the details below, stating your name and details of your complaint. Upon receipt of your complaint, we will endeavour to contact you within 10 working days with a view to amicably resolving such complaint within the shortest possible time. The foregoing notwithstanding, all disputes arising from this policy shall first be resolved by amicable negotiation. However, if we fail to resolve the disputes amicably by such mutual consultations, both of us shall further attempt to resolve the dispute by Mediation at the Multi-Door Courthouse ("MDC") (of respective States in Nigeria and the Mediator shall be appointed by both of us (we and you). Where both of us are unable to agree on the choice of a Mediator, the choice of Mediator shall be referred to the MDC. The awards or decisions of MDC shall be binding on both of us. Each of us shall bear our respective costs in connection with the mediation.