Privacy Policy

1. INTRODUCTION

LipaGo is committed to protecting the privacy and personal information of its customers, passengers, Bus Operators, business partners and other users of the LipaGo platform.

This Privacy Policy explains how iMartGroup Ltd., through its LipaGo service, collects, receives, uses, processes, stores, shares and protects personal information obtained from individuals who access or use LipaGo.

LipaGo is an online bus ticketing and travel booking platform through which customers may search for transportation services, make bookings, select available seats, make payments, receive electronic tickets and receive information relating to their journeys.

By accessing or using LipaGo, you acknowledge that you have read and understood this Privacy Policy.

Where you provide personal information to us, you consent to its processing where consent is the applicable legal basis, and you acknowledge that we may otherwise process your information where such processing is permitted or required under applicable law.

This Privacy Policy should be read together with the LipaGo Terms and Conditions, which govern the use of the LipaGo platform and services.

2. WHO WE ARE

LipaGo is a digital bus ticketing and travel booking service operated by iMartGroup Ltd.

For purposes of this Privacy Policy, "LipaGo", "we", "us" and "our" refer to LipaGo and iMartGroup Ltd. in relation to the operation and provision of LipaGo services.

"You", "your", "customer", "passenger" or "user" refers to an individual who accesses, registers for, books a ticket through, communicates with or otherwise uses LipaGo.

iMartGroup Ltd. is responsible for the operation, management and technological infrastructure supporting LipaGo.

3. OUR PRIVACY COMMITMENT

We recognise that personal information belongs to the individual to whom it relates and should be handled responsibly.

We therefore seek to process personal information in a manner that is lawful, fair, transparent and proportionate to the purposes for which it is collected.

We seek to ensure that personal information is collected only where there is a legitimate reason for doing so, used for appropriate purposes, protected against unauthorised access and retained only for as long as reasonably necessary or required by law.

Our processing of personal information is intended to comply with applicable laws and regulations of the United Republic of Tanzania relating to privacy and personal-data protection, including the Personal Data Protection Act, 2022, together with applicable regulatory requirements and guidance.

4. INFORMATION WE COLLECT

The type of personal information collected by LipaGo depends on how you interact with the platform and the services you use.

We may collect information directly from you when you create an account, make a booking, make a payment, contact customer support, communicate with us or otherwise provide information through the LipaGo platform.

We may also receive information from Bus Operators, payment providers, communication providers and other authorised service providers involved in delivering the LipaGo service.

5. PERSONAL AND IDENTIFICATION INFORMATION

When necessary to provide our services, we may collect information such as your full name, passenger name, username, identification information, date of birth, age or other information necessary to identify or verify you.

The amount of information requested will depend on the particular service and the requirements applicable to the transaction. We will seek to avoid collecting information that is not reasonably necessary for the service being provided.

6. CONTACT INFORMATION

We may collect contact information such as your telephone number, mobile-money number, email address or other contact details.

This information enables us to communicate with you regarding your account, bookings, tickets, payments, refunds, changes to journeys, customer support and other matters relating to your use of LipaGo.

Where you voluntarily provide an alternative or emergency contact, we will use such information only for the purpose for which it was provided or as otherwise permitted by applicable law.

7. BOOKING AND TRAVEL INFORMATION

When you make a booking through LipaGo, we may collect information necessary to create and administer the booking.

This may include your origin, destination, travel date, departure time, boarding location, arrival location, seat number, Bus Operator, ticket number, booking reference, QR code or other ticket identifier.

We may also maintain information regarding your booking status, cancellations, changes, refunds and other transaction-related activities. This information is necessary to provide the ticketing service and to enable the relevant Bus Operator to fulfil the transportation service.

8. PAYMENT AND TRANSACTION INFORMATION

When you make a payment through LipaGo, we may process information relating to the transaction. Such information may include the transaction reference, payment reference, amount, currency, date, time, payment channel, transaction status, refund reference and reversal information.

Where a third-party payment provider processes your payment, the payment provider may independently process payment credentials and other information in accordance with its own privacy policy and applicable legal obligations.

LipaGo does not require customers to provide their confidential payment PINs or one-time passwords to LipaGo employees. You should never disclose your mobile-money PIN, card PIN, OTP or other confidential authentication credentials to anyone claiming to represent LipaGo.

9. INFORMATION ABOUT YOUR DEVICE AND USE OF THE PLATFORM

When you access LipaGo, certain technical information may be collected automatically. This may include your IP address, browser type, operating system, device type, application version, session information, login activity, error information, security logs and other technical information generated through your interaction with the platform.

We use this information primarily to operate, secure, monitor and improve the LipaGo platform. Technical information may also be used to investigate system errors, detect suspicious activity and protect the platform against unauthorised access.

10. CUSTOMER SUPPORT INFORMATION

When you contact LipaGo customer support, we may collect information contained in your communication with us. This may include your name, telephone number, email address, booking reference, payment reference, complaint, question, supporting documents, screenshots and other information that you voluntarily provide for purposes of resolving your issue.

We may retain customer-support communications where reasonably necessary for service management, quality assurance, dispute resolution, fraud prevention, audit or legal and regulatory purposes.

11. INFORMATION RECEIVED FROM BUS OPERATORS

LipaGo works with Bus Operators that provide transportation services through the platform. Bus Operators may provide information concerning their routes, schedules, fares, available seats, booking status and other operational information required to provide the ticketing service.

Where necessary to fulfil a customer's booking, LipaGo may exchange relevant passenger information with the Bus Operator responsible for the journey. Bus Operators are expected to handle passenger information responsibly and in accordance with applicable legal and regulatory requirements.

12. INFORMATION RECEIVED FROM PAYMENT PROVIDERS

Where payments are made through banks, mobile-money providers, card processors, payment gateways, LipaPay or other authorised payment providers, we may receive information necessary to confirm and reconcile the transaction.

This may include payment status, transaction reference, amount, date, refund status and other transaction information. The payment provider may also process personal information under its own privacy policy and applicable legal requirements.

13. WHY WE COLLECT PERSONAL INFORMATION

LipaGo collects and processes personal information primarily to provide the services requested by customers. This includes enabling customers to create accounts, search for bus services, make bookings, select seats where available, process payments, issue tickets, communicate journey information and provide customer support.

We may also process information where necessary to maintain platform security, prevent fraud, reconcile financial transactions, investigate complaints, improve the platform, comply with legal and regulatory obligations and protect our rights and the rights of our customers.

We will not intentionally collect personal information for a purpose that is incompatible with the purpose for which the information was originally obtained unless such processing is permitted by law or otherwise appropriately authorised.

14. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Depending on the nature of the processing activity, LipaGo may process personal information because it is necessary to perform a contract or provide a service requested by you.

We may also process information where we are required to do so by law or where processing is necessary to comply with regulatory, accounting, tax, audit, security or other legal obligations.

In certain circumstances, we may rely on your consent. Where consent is the applicable legal basis, you may withdraw that consent subject to the limitations explained in this Privacy Policy and applicable law.

We may also process information where we have a legitimate and lawful business purpose, provided that the processing is appropriate and does not unlawfully override your rights and interests.

15. USE OF PERSONAL INFORMATION

Your personal information may be used to administer your LipaGo account, process bookings, issue tickets, process and reconcile payments, communicate with you, provide customer support and manage refunds or cancellations.

We may also use information to monitor the performance and security of the platform, detect fraudulent activity, investigate technical problems, resolve disputes and maintain appropriate business and financial records.

Where permitted by law, information may also be used for service improvement, analytics and development of new LipaGo features.

16. COMMUNICATIONS WITH CUSTOMERS

When you use LipaGo, we may communicate with you through SMS, WhatsApp, email, telephone, notifications or other communication channels.

Service-related communications may include booking confirmations, electronic tickets, payment confirmations, travel reminders, boarding information, schedule changes, cancellations, refunds, security notifications and customer-support responses.

These communications are considered an important part of providing the service and may continue even where you have opted out of marketing communications.

17. MARKETING COMMUNICATIONS

Where permitted by applicable law, LipaGo may send customers information concerning promotions, discounts, new services, campaigns and other marketing communications.

Where marketing communication requires consent, we will seek the appropriate consent. You may request that we stop sending marketing communications by following the available unsubscribe or opt-out instructions or by contacting us.

Opting out of marketing communications will not prevent us from sending essential communications relating to an existing booking, payment, ticket, security matter, refund or other service you have requested.

18. SHARING PERSONAL INFORMATION

LipaGo may share personal information with third parties where such sharing is necessary to provide the service, fulfil a booking, process a payment, meet a legal obligation, protect the security of the platform or otherwise comply with applicable law.

This may include sharing appropriate information with the Bus Operator responsible for your journey. We may also share information with authorised payment providers, communication providers, technology providers, hosting providers, security providers, professional advisers, regulators, law-enforcement authorities and other service providers where necessary and legally permitted.

We do not treat customer personal information as a commodity for sale.

19. BUS OPERATOR ACCESS TO CUSTOMER INFORMATION

Where you purchase a ticket through LipaGo, the relevant Bus Operator may need access to certain passenger information in order to provide the transportation service.

The information made available to the Bus Operator may include your name, booking reference, route, travel date, seat information and other information reasonably necessary for the journey.

The Bus Operator should use such information only for legitimate operational purposes and should comply with applicable privacy and data-protection requirements.

20. LIPAPAY AND PAYMENT SERVICES

LipaGo may use LipaPay, a digital payment service operated within the iMartGroup ecosystem, to facilitate customer payments.

Where LipaPay is used, information necessary to initiate, process, verify and reconcile the payment may be exchanged between LipaGo and LipaPay. Such information may include transaction identifiers, payment amounts, payment status, timestamps, refund references and other information necessary for the transaction.

LipaGo and LipaPay are separate services within the iMartGroup ecosystem, although both are operated under iMartGroup Ltd.

21. OTHER IMARTGROUP SERVICES

iMartGroup Ltd. operates a number of digital and technology services, which may include LipaPay, OneClick, LipaWakala, iHost and LipaGo.

The fact that these services form part of the same corporate group does not mean that your LipaGo personal information will automatically be shared with every other iMartGroup service.

Where information is shared between LipaGo and another iMartGroup service, the sharing will be based on a legitimate operational requirement, your request, an applicable contractual relationship, a legal obligation or another lawful basis.

22. WHATSAPP, FACEBOOK AND META

LipaGo may use WhatsApp Business Platform and other Meta technologies to communicate with customers.

For example, WhatsApp may be used to provide booking confirmations, electronic tickets, payment notifications, travel reminders, customer support and other service-related communications.

When you interact with LipaGo through WhatsApp, your information may also be processed through Meta's systems and may therefore be subject to applicable Meta and WhatsApp terms and privacy practices.

LipaGo is operated by iMartGroup Ltd. and is not owned, operated, sponsored or endorsed by Meta Platforms, Inc., Facebook or WhatsApp unless expressly stated otherwise.

23. THIRD-PARTY TECHNOLOGY PROVIDERS

LipaGo may use third-party technology providers to support the operation of its services. These providers may provide services such as cloud hosting, web hosting, databases, security monitoring, payment processing, SMS delivery, email delivery, WhatsApp integration, system monitoring, backup, analytics and technical support.

Where a third party processes personal information on behalf of LipaGo, we will seek to ensure that appropriate contractual, technical and organisational measures are in place to protect the information and limit its use to authorised purposes.

24. COOKIES AND SIMILAR TECHNOLOGIES

LipaGo may use cookies and similar technologies to enable the proper functioning of the website and to support security, authentication, preferences, performance monitoring and analytics.

Some cookies may be essential for the website to function correctly, while others may help us understand how customers use the platform and improve the user experience.

You may control certain cookies through your browser settings. However, disabling essential cookies may affect the availability or functionality of some LipaGo services.

25. DATA SECURITY

iMartGroup recognises the importance of protecting personal information against unauthorised access, loss, misuse, alteration, disclosure or destruction.

We therefore seek to maintain reasonable technical and organisational security measures appropriate to the nature of the information and the risks associated with its processing.

These measures may include access controls, authentication mechanisms, role-based permissions, secure communications, system monitoring, logging, backups, vulnerability management, patch management, security testing and incident-response procedures.

Access to personal information is intended to be restricted to authorised persons who require access for legitimate business or operational purposes.

No internet-based system can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect personal information, we cannot guarantee absolute security against every possible threat.

26. CUSTOMER RESPONSIBILITY FOR SECURITY

Customers also have an important role in protecting their personal information. You are responsible for keeping your account credentials confidential and should not disclose your password, OTP, mobile-money PIN, card PIN or other security credentials to anyone.

If you believe that your account or personal information has been compromised, you should contact LipaGo as soon as reasonably possible.

27. PERSONAL DATA INCIDENTS AND BREACHES

Where LipaGo becomes aware of a personal-data security incident, we will take reasonable steps to investigate and contain the incident.

Depending on the nature and severity of the incident, we may take corrective measures, notify relevant authorities where required, notify affected individuals where legally required or appropriate, and maintain records concerning the incident and the measures taken in response.

Our response will be guided by applicable Tanzanian law and regulatory requirements.

28. DATA RETENTION

LipaGo will retain personal information for as long as reasonably necessary to fulfil the purposes for which it was collected, provide services, maintain appropriate business records, comply with legal and regulatory obligations, resolve disputes, prevent fraud and protect our legitimate interests.

Different categories of information may therefore be retained for different periods. For example, information relating to financial transactions may need to be retained for accounting, tax, audit or regulatory purposes even after a customer has stopped using LipaGo.

When information is no longer required, we will take reasonable steps to delete, securely destroy, anonymise or otherwise dispose of it in accordance with applicable requirements.

29. CROSS-BORDER DATA PROCESSING

Some technology, hosting, communication or payment service providers used by LipaGo may operate infrastructure or process information outside Tanzania.

Where personal information is transferred, stored or accessed outside Tanzania, iMartGroup will seek to ensure that the transfer and processing are carried out in accordance with applicable Tanzanian data-protection requirements and any required safeguards, approvals, authorisations or contractual arrangements.

We may also apply appropriate security and access controls to reduce the risks associated with international processing.

30. YOUR RIGHTS RELATING TO PERSONAL INFORMATION

Subject to applicable law and any lawful limitations, you may have rights concerning the personal information we hold about you.

These rights may include the right to know whether we hold personal information about you, to request access to such information, to request correction of inaccurate information and, where legally applicable, to request deletion or restriction of processing.

Depending on the circumstances, you may also have rights relating to objection to processing, withdrawal of consent, data portability, automated decision-making and other rights provided under applicable data-protection law.

The exercise of a particular right may be subject to legal or operational limitations. For example, we may be required to retain certain financial or transaction records even where a customer requests deletion.

31. ACCESS REQUESTS

If you wish to obtain access to personal information held by LipaGo about you, you may submit a request using the contact details provided at the end of this Privacy Policy.

We may request reasonable information to verify your identity before responding to the request. This verification process is intended to prevent personal information from being disclosed to an unauthorised person.

32. CORRECTION OF PERSONAL INFORMATION

If you believe that personal information held by LipaGo is inaccurate, incomplete or outdated, you may request that we correct the information.

Where the platform allows customers to update information directly through their account, you may make the correction yourself. Where direct modification is not available, you may contact LipaGo and request that the information be corrected.

33. REQUEST FOR DELETION

You may request deletion of personal information where such deletion is permitted under applicable law.

A request for deletion does not necessarily mean that all information can be immediately removed. We may be required to retain certain information because of legal, regulatory, financial, tax, accounting, audit, fraud-prevention, security or dispute-resolution requirements.

Where retention is legally required, the information will be retained only for the applicable period and handled in accordance with this Privacy Policy and applicable law.

34. WITHDRAWAL OF CONSENT

Where LipaGo processes your personal information based on your consent, you may withdraw that consent by contacting us or using an available consent-management mechanism.

Withdrawal of consent will not affect the lawfulness of processing that occurred before the withdrawal. Withdrawal may also not stop processing where we have another lawful basis for continuing the processing, such as fulfilling a contract, complying with a legal obligation or protecting our legitimate interests.

35. DATA PORTABILITY

Where applicable and technically practicable, you may request certain personal information in a structured format or request that information be transferred to another service provider.

Such requests will be assessed in accordance with applicable law and any limitations relating to security, confidentiality, third-party information and technical feasibility.

36. OBJECTION TO PROCESSING

Where applicable law provides you with a right to object to particular processing activities, you may contact us to raise such an objection.

We will consider the request in accordance with applicable law and the circumstances of the processing. Where processing is necessary to provide a service you have requested or is required by law, the objection may not result in termination of that processing.

37. AUTOMATED PROCESSING AND FRAUD DETECTION

LipaGo may use automated systems to perform operational functions such as checking payment status, determining ticket availability, validating bookings, identifying unusual transaction patterns and protecting the platform against fraud.

These systems may process information automatically for security and operational purposes.

We do not intend to make decisions based solely on automated processing where such decisions produce significant legal or similarly significant effects on an individual unless such processing is permitted by law and appropriate safeguards are applied.

Where applicable, customers may exercise rights relating to automated decision-making under relevant data-protection requirements.

38. CHILDREN'S INFORMATION

LipaGo is a general ticketing service and is not intended to collect unnecessary personal information from children.

Where a ticket is purchased for a minor, certain information may be necessary to complete the booking and enable the Bus Operator to provide the transportation service.

Parents, guardians or other authorised adults should provide information relating to minors where appropriate and should ensure that information supplied to LipaGo is accurate and necessary for the relevant journey.

39. INFORMATION RELATING TO OTHER PEOPLE

If you make a booking for another person, you may provide personal information belonging to that passenger.

You should only provide another person's information where you are authorised to do so or where you have a legitimate reason to provide it for the purpose of making the booking. You are responsible for ensuring that the information provided is accurate.

Where appropriate, you should inform the passenger that their information has been provided to LipaGo and may be shared with the relevant Bus Operator for purposes of fulfilling the booking.

40. FRAUD PREVENTION AND SECURITY MONITORING

LipaGo may monitor transactions and system activity for purposes of detecting fraud, abuse, unauthorised access and other security threats.

Where suspicious activity is detected, we may temporarily restrict a transaction or account while appropriate checks are undertaken.

Where necessary and legally permitted, information relating to suspected fraud or unlawful activity may be shared with payment providers, Bus Operators, regulators, law-enforcement authorities or other relevant parties.

41. GOVERNMENT, REGULATORY AND LEGAL DISCLOSURES

LipaGo may disclose personal information where required or authorised by applicable law.

This may include responding to valid requests from courts, regulatory authorities, law-enforcement agencies, tax authorities or other legally authorised government bodies.

Where legally permitted, we will seek to ensure that disclosures are limited to the information reasonably necessary for the relevant purpose.

42. PROFESSIONAL ADVISERS

iMartGroup may disclose appropriate information to professional advisers such as lawyers, auditors, accountants, consultants or other professional service providers where reasonably necessary for legitimate business, legal, financial, regulatory or dispute-resolution purposes.

Such parties may be subject to confidentiality and professional obligations.

43. BUSINESS TRANSFERS

If iMartGroup or LipaGo undergoes a restructuring, merger, acquisition, sale of assets, investment transaction or other corporate change, personal information may form part of the business assets or records transferred as part of that transaction.

Where such a transfer occurs, we will seek to ensure that personal information continues to be handled in accordance with applicable law and appropriate privacy protections.

44. LINKS TO OTHER WEBSITES AND SERVICES

LipaGo may contain links or integrations to websites, applications or services operated by third parties.

This Privacy Policy applies to LipaGo and does not automatically apply to third-party websites or services. Before providing personal information to another service, you should review the privacy notice or policy applicable to that service.

45. CUSTOMER COMPLAINTS

We encourage customers who have concerns about the handling of their personal information to contact LipaGo first so that we have an opportunity to investigate and address the matter.

When submitting a privacy complaint, you should provide sufficient information for us to understand the issue, including your name, contact information and relevant booking or account reference where applicable.

We will investigate the complaint and respond in accordance with our procedures and applicable law. Where you are not satisfied with the response or where applicable law provides you with a right to do so, you may also contact the relevant data-protection authority in Tanzania.

46. PERSONAL DATA PROTECTION COMMISSION

LipaGo recognises the role of the Personal Data Protection Commission (PDPC) as the relevant data-protection regulatory authority in Tanzania.

Nothing in this Privacy Policy is intended to restrict any statutory right you may have to lodge a complaint with the PDPC or exercise any other right available under applicable Tanzanian law.

47. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our services, technology, business operations, legal requirements or regulatory expectations.

When we make changes, we will publish the updated version on the LipaGo platform and update the effective date shown at the beginning of this document.

Where a change is material and applicable law requires additional notification, we will take reasonable steps to communicate the change to affected users.

Your continued use of LipaGo following the effective date of an updated Privacy Policy will constitute acknowledgement of the updated policy to the extent permitted by law.

48. RELATIONSHIP WITH THE LIPAGO TERMS AND CONDITIONS

This Privacy Policy should be read together with the LipaGo Terms and Conditions.

The Terms and Conditions establish the contractual framework governing your use of LipaGo, while this Privacy Policy explains how personal information is handled in connection with those services.

Where the two documents address different subjects, each document will apply to the subject matter for which it is intended.

49. CONTACTING LIPAGO ABOUT PRIVACY

If you have questions about this Privacy Policy or wish to exercise a privacy or personal-data right, you may contact us using the following details:

When submitting a personal-data request, please use the subject: "LipaGo Personal Data Request".

For a deletion request, you may use: "LipaGo Data Deletion Request".

We may request reasonable information to verify your identity before processing a request.

50. FINAL PRIVACY COMMITMENT

iMartGroup Ltd., through LipaGo, recognises that customers entrust us with personal information when they use our platform.

We are committed to handling that information responsibly and transparently and to maintaining appropriate measures designed to protect it.

Our objective is to collect information that is necessary for legitimate purposes, use it responsibly, share it only where appropriate and lawful, protect it through reasonable technical and organisational measures and respect the rights available to individuals under applicable data-protection laws.

Your continued use of LipaGo is subject to this Privacy Policy and the LipaGo Terms and Conditions.

LIPAGO

Book. Pay. Board.

Operated by iMartGroup Ltd.

Version 1.0 | Effective 2026