Privacy Policy
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 Regulation (NDPR) 2019, 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
| Category | Data Fields | Who Provides It |
|---|---|---|
| Identity | Full name | All users |
| Contact | Email address, WhatsApp phone number | All users |
| Commute profile | Home area, work destination, morning departure window, evening return window, commute frequency | All users |
| Vehicle information | Seats available, car type, vehicle ownership confirmation | Drivers only |
| Role | Rider or Driver designation | All users |
2.2 Information collected automatically
When you visit ganusii.com, we may automatically collect certain technical data including:
- IP address and approximate geographic location (city level)
- Browser type, version, and operating system
- Pages visited, time on site, referring URL
- Device type (mobile, tablet, desktop)
- UTM parameters and campaign source tags
This data is collected through tools such as Google Analytics 4 (GA4) and, where implemented, the Meta (Facebook) Pixel. We use this data in aggregate to understand how our site is used and to measure the effectiveness of our marketing. 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
- Waitlist registration forms — when you complete the Rider or Driver registration form on ganusii.com.
- WhatsApp communication — when you message or interact with us through our WhatsApp Business number.
- Email — when you contact us directly at hello@ganusii.com or respond to communications from us.
- Cookies and tracking technologies — automatically as you browse our website (see Section 10).
- Referrals — when another Ganusii user refers you to the platform. In this case, we receive only the information you subsequently provide when completing the registration form.
4. Why We Collect Your Information (Legal Basis)
Under the NDPR 2019, we must have a lawful basis to process your personal data. Our legal bases are:
| Processing Activity | Legal Basis (NDPR) |
|---|---|
| Adding you to the waitlist and sending corridor-related communications | Consent — you ticked the consent checkbox on our registration form |
| Matching you with riders or drivers on your commute corridor | Consent; and legitimate interest (to provide our core service) |
| Sending service updates, waitlist status, and launch notifications | Consent; or legitimate interest where you are an existing contact |
| Analytics and website improvement | Legitimate interest; where cookies are involved, consent |
| Complying with legal obligations (e.g., data breach notifications) | Legal obligation |
| Safety screening and fraud prevention | Legitimate 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:
- Waitlist management — to record your interest, confirm your registration, and track your position on the waitlist.
- Corridor matching — to cluster riders and drivers on the same commute route so that, when demand is validated, we can match you with suitable carpool partners.
- Communication — to contact you by email or WhatsApp with updates on your corridor's launch status, safety information, and onboarding instructions.
- WhatsApp group coordination — to invite you to a private WhatsApp corridor group when your route reaches the minimum matching threshold for launch.
- Platform improvement — to analyse which corridors have the highest demand and make decisions about launch sequencing and product development.
- Safety and verification — to conduct basic identity and vehicle verification checks before adding drivers to active corridors.
- Analytics and marketing — to measure the performance of our advertising campaigns and improve our website experience.
- Legal compliance — to meet our obligations under Nigerian law, including the NDPR.
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
| Provider | Purpose | Location |
|---|---|---|
| Airtable | Lead database — stores waitlist registrations and corridor data | United States |
| Meta (WhatsApp Business) | Direct communication with registered users | United States |
| Google (GA4) | Website analytics and usage data | United States |
| Meta Pixel (where enabled) | Advertising measurement and retargeting | United States |
| ConvertKit / Mailchimp (where enabled) | Email communications and onboarding sequences | United States |
| Make (Integromat) / Zapier (where enabled) | Workflow automation between tools above | United States / EU |
| Vercel / Framer | Website hosting and delivery | United States / Global CDN |
6.2 Other Ganusii users (at matching stage only)
When your corridor reaches launch threshold and you are matched with carpool partners, we will share your first name, WhatsApp number, and approximate home area with the other members of your corridor group. You will be notified before any such sharing occurs and will have the opportunity to opt out.
6.3 Legal and regulatory disclosures
We may disclose your personal data to law enforcement agencies, courts, or regulatory bodies (including NITDA) 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 NDPR requires that when personal data is transferred outside Nigeria, adequate protections must be in place.
Where we transfer your data internationally, we ensure that:
- The recipient country provides an adequate level of data protection; or
- We have implemented appropriate safeguards such as Standard Contractual Clauses (SCCs), Data Processing Agreements (DPAs), or we rely on the recipient's adherence to frameworks such as the EU-US Data Privacy Framework.
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 Type | Retention Period | Reason |
|---|---|---|
| Waitlist registration data | 24 months from registration, or until you request deletion | To manage corridor launches and contact you when your route is ready |
| Inactive waitlist entries (no corridor launched) | Deleted or anonymised after 24 months | Data minimisation principle |
| Active user data (after corridor launch) | Duration of your use of the service, plus 12 months | Service delivery and dispute resolution |
| Website analytics data | 14 months (Google Analytics default) | Performance monitoring |
| Email communications | 36 months | Customer service and legal record keeping |
| Legal/compliance records | 7 years | Nigerian 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 NDPR
The Nigeria Data Protection Regulation (NDPR) 2019 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.
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
Our website uses cookies and similar tracking technologies. Cookies are small text files stored on your device that help us understand how visitors interact with our site.
10.1 Types of cookies we use
| Type | Purpose | Can you opt out? |
|---|---|---|
| Strictly necessary | Required for the website to function (e.g., security, form submission) | No — these are essential |
| Analytics (GA4) | Understand site traffic, page views, user journeys | Yes — via cookie banner or browser settings |
| Marketing (Meta Pixel) | Measure ad performance, enable retargeting campaigns | Yes — via cookie banner or Meta Ad Preferences |
Where required by law, we will obtain your consent before placing non-essential cookies. You can manage or withdraw your cookie preferences at any time through your browser settings or by contacting us.
10.2 Google Analytics
We use Google Analytics 4 with IP anonymisation enabled. This means your full IP address is not stored by Google. You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.
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:
- HTTPS encryption for all data transmitted to and from our website
- Access controls limiting who within Undaunted Lab can access your personal data
- Use of reputable third-party platforms (Airtable, Vercel) with their own security certifications
- Regular review of our data handling practices
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 you and the National Information Technology Development Agency (NITDA) as required by the NDPR.
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:
- Update the "Last updated" date at the top of this page
- Post a notice on our website homepage for at least 30 days
- Notify registered users by email or WhatsApp where the changes are significant
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:
National Information Technology Development Agency (NITDA)
Data Protection Compliance Portal: ndpr.nitda.gov.ng
Email: info@nitda.gov.ng
Address: No. 28 Port Harcourt Crescent, Off Gimbiya Street, Area 11, Garki, 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: +234 900 000 0000
Lagos, Nigeria