Privacy Policy

1. Introduction

This Privacy Policy defines how Lula Loop (Pty) Ltd t/a LULA (hereinafter referred to as 'us', 'our' or 'we') collects and processes personal information about you, how we use and protect this information, and your rights in relation thereto in accordance with the requirements of the Protection of Personal Information Act, 4 of 2013 (POPIA).

All personal information processed by us, regardless of form or medium, shall be processed in accordance with the provisions set out hereunder.

2. Personal Information We Collect

We may obtain your personal information from you directly or a third party or sources when you use our website, contact us or submit an online request for services. We will however ensure that the collection and processing complies with the prescripts of POPIA.

All personal information collected by us is required to comply with a contractual obligation we have to you or a third party. Failure to provide this personal information could prevent or cause a delay in the fulfilment of these obligations.

2.1 Information we collect directly from you:

The categories of personal information that we may collect directly from you include the following:

2.2 Information we may collect from other sources:

The following are examples of the categories of personal information we may collect from other sources such as the Companies and Intellectual Property Commission, or third-party service providers include but are not limited to the following:

• Name, Surname
• Location data which includes trip details (drop-off and pick-up)
• App data: app version, crash details
• Device data

2.2.1 Analytics

Google Analytics:
Tracks basic page views, device types, operating systems and browser type. No personally identifiable information can be tracked.

2.2.2 Personal Data: Cookies and Usage data:

Cookies do not reveal personal information, it just reveals that you are the same browser that visited earlier.

When using the LULA App (“the App”) operated by us, we will ensure that your personal information is processed in accordance with this policy. Information collected via this platform will be used to provide and improve the transport ecosystem and to help improve accessibility and plan transport better. By using our App, you agree to the collection and use of information in accordance with this policy.

2.2.3 Information Collection and Use

While using our App, we may ask you to provide us with personally identifiable information that can be used to contact or identify you. Personal identifiable may include but is not limited to your name (“Personal Information”).

2.2.4 Card Data

While you're required to add your credit or debit card information on the App, we do not save your card details on our App or servers. This information is only used when you pay for your rides or trips. This means that the wallet is used for your daily transactions, this will be your hop-on and hop-off.

2.2.5 Log Data

We collect information that your device sends whenever you use our App, which includes:

• Location (GPS coordinates), and;
• Mobile device information e.g., model type etc.

3. How We Use Your Personal Information

We will only process your personal information for the purpose(s) for the following purposes:.

• To comply with our contractual obligations, which includes but is not limited to:
  • Provide services to you, as set out in our terms and conditions.
  • For invoicing and record keeping purposes;
  • Communicate with you and carry out instructions and requests;
• To comply with any lawful obligation imposed on us;
• With your consent (where required);
• Where in pursuit of a legitimate interest of our Company; or
• If in your legitimate interest as the data subject.

A list of records processed by us is listed in our PAIA Manual, which is available via our website, www.lulaloop.co.za or email request to our Information Officer: Yusra van der Schyff at [email protected]

4. Information Sharing

We do not share your personal information with third parties unless there is a contractual requirement to do so for the completion of services rendered or unless we are legally obligated to do so.

5. Information Security

5.1 Organisational Security Measures

We have implemented generally accepted standards of technology and operational security to protect personal information from loss, misuse, alteration, or destruction.

We require all staff or contractors to keep personal information confidential and only authorised personnel have access to this personal information.

5.2 Staff

We require our staff to conduct themselves in a manner consistent with our guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards.

We further conduct regular staff training sessions to ensure awareness on best security practices and confidentiality of information.

5.3 Retention

In accordance with the prescripts of POPIA, we will retain your personal information in accordance with our data retention policy, which sets out data retention periods required or permitted by law.

5.4 International Data Transfers

We may transfer your information outside South African borders for retention purposes and/or if our service providers are cross border or uses cross border systems. We will only share your information with service providers who have comparable privacy policies in place.

6. Minors

We do not intentionally collect personal information from minor children. If you are the parent or guardian and believe we are processing said information please contact us at the address set out below and request the deletion thereof.

7. Third Party Information

It is the responsibility of the disclosing party, furnishing us with the personal information of a third party, to ensure that he or she has 1) advised them thereof, 2) obtain their consent (where required) and 3) advise them of their rights with respect to our processing of their personal information.

8. Your Rights

It is the responsibility of the disclosing party, furnishing us with the personal information of a third party, to ensure that he or she has 1) advised them thereof, 2) obtain their consent (where required) and 3) advise them of their rights with respect to our processing of their personal information.

8.1 Right to access information

You have the right to request, free of charge, what personal information we hold about you. You also have the right to request a copy of the record of personal information or a description of the personal information we hold about you. These requests need to be done in the correct format and manner as prescribed in the PAIA act.

8.2 Right to request correction or deletion of personal information

You have the right to request the correction, updating or deletion of the personal information held by us. You can also request the destruction or deletion of a record of information held by us.

8.3 Right to object to the processing of personal information

You have the right to object to the processing of your personal information, unless there is a legitimate legal basis, we need to continue to process your information (court order).

8.4 Right to object to automated decision-making

You have the right to object to automated decision making.

8.5 Right to unsubscribe from direct marketing

You have the right to opt-out of any direct marketing that is sent to you by clicking on the opt-out or unsubscribe link at the bottom of the email.

8.6 Right to withdraw consent

You have the right to withdraw your consent to us processing your information at any time, these requests need to be sent to [email protected]. We will consider your request in light of any other laws, regulations and/or contractual obligations restricting us from complying with your request.

8.7 Right to lodge a complaint

If you have any questions, concerns or complaints regarding our privacy practices please contact our Information Officer at the email address set out in clause 3 above.

You have the right to lodge a complaint with the Information Regulator, in the prescribed manner and form, if you believe that we are not complying with the protection of your personal information. You can contact the Information Regulator on 010 023 5200 (telephone number) and can lodge a complaint via email at:

9. Applicable Law

These conditions are governed by South Africa legislation. The court in the district where we have our place of business has the sole jurisdiction if any dispute regarding these conditions may arise, save when a legal exception applies.

10. Amendments to Policy

Amendments to this privacy policy will be done in accordance with any legislative requirements that may be issued from time to time.