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Privacy Policy — EFAD GO

This is an English translation. The Arabic text is the governing version.

Operator: Efad Smart Information Technology Company
Version: 2.0
Last updated: 9 August 2026
Effective: 9 August 2026

This is the English translation of the Arabic policy. Where the two differ in
interpretation, the Arabic text prevails.

1. Who is responsible for your data

We act as the data controller for the personal data covered by this policy, under the Saudi Personal Data Protection Law (PDPL) and its Implementing Regulations.

2. Scope and purpose

This policy explains how we collect, process, use, disclose and protect personal data when you use the EFAD GO app and our electric wheelchair mobility service, together with the operational and technical systems behind them.

It applies to:

• Users who register for, or use, the app or the mobility service.
• Companions who use the app on behalf of a person using the service.
• Field operators using our staff application, to the extent described in section 9.

This policy forms an integral part of the Terms and Conditions and does not replace them.

3. Definitions

4. Data we collect

We collect the minimum data needed to run the Service.

4.1 Account and identity data

Name, mobile number, email address (optional), profile photo (optional), preferred language, and your account identifier in our systems.

4.2 Trip and usage data

Booking time, pickup and return points, duration of use, trip start and end status, trip history, companion details where applicable, and inspection results at handover and return.

4.3 Location data

Device location while you are using the app or while a trip is active — used to find the nearest handover point, guide you to it, validate trip completion, and respond to assistance or emergency requests. See section 9 for detail.

4.4 Wheelchair operational data

Battery level, operating status, technical position of the wheelchair, speed, and connectivity status. This originates from the wheelchair itself rather than your device, and is linked to your account only for the duration of an active trip.

4.5 Payment and transaction data

Transaction history, wallet balance, gift cards, refunds, and tax invoices. Card payments are completed on a secure hosted page provided by a licensed payment provider; full card numbers and CVV codes never reach or reside on our systems.

4.6 Support and communications data

The content of support messages and attachments you send us, our correspondence history with you, and your service ratings.

4.7 Device and technical identifiers

Device type, operating system, app version, IP address, installation identifier, push notification token, crash logs, and in-app usage events.

4.8 What we do not collect

• No bank card data is stored on our systems.
• No access to contacts, calendar, SMS, call logs, or device files.
• No advertising data. We use no advertising networks and no advertising identifiers.

5. Sources of data

1. Directly from you — registration, profile updates, contacting support.
2. Automatically from your use of the app and the Service.
3. From the wheelchair and its telemetry systems during a trip.
4. From approved service providers, e.g. a payment status confirmation.
5. From our field operations team, when logging an operational event or a wheelchair inspection.

6. Legal basis for processing

Every processing activity rests on one or more of the following:

You may withdraw consent at any time (section 15). Withdrawal does not affect the lawfulness of processing carried out before it.

7. Why we use your data

1. Operating the Service — account creation and verification, booking, handover and return, trip start and end.
2. Payments and billing — charging fees, managing the wallet and gift cards, issuing invoices, processing refunds.
3. Safety — responding to assistance requests, managing operating zones, monitoring the fleet and preventing incidents.
4. Fraud and misuse prevention — detecting use that breaches the Terms and taking lawful action.
5. Support and customer service — answering enquiries and handling complaints.
6. Service improvement — operational analysis, performance measurement, and feature development, using aggregated or anonymised data wherever possible.
7. Compliance — meeting regulatory requirements in the Kingdom of Saudi Arabia.

We do not make solely automated decisions that produce legal or similarly significant effects on you without human involvement.

8. Disclosure and sharing

We do not sell, rent or trade personal data.

We may share the minimum data necessary with:

Every provider processing data on our behalf is bound by a contract requiring it to process data only on our instructions and to apply appropriate protection measures.

We may also use aggregated, anonymised data — which cannot be linked back to an individual — for statistical analysis and service development.

9. Location data and safety

Because location data is sensitive, we set out its use separately.

9.1 In the customer app

• Location permission is requested with your explicit consent and can be refused or withdrawn from your device settings at any time.
• It is used to find the nearest handover point, guide you to it, validate where a trip ends, and respond to assistance requests.
• The customer app does not collect location in the background when the app is closed and no trip is active.
• Refusing location permission may prevent some features from working, but does not necessarily prevent use of the Service altogether.

9.2 From the wheelchair itself

The wheelchair transmits its own operational and technical position data to our systems continuously while in operation, as an asset owned by the company, for safety, fleet management, misuse prevention and recovery. This continues even when you are not interacting with the app, and is linked to your account only for the duration of an active trip.

9.3 In the field operator app

An operator shares location only while on shift and on duty, for task dispatch and field safety. Collection stops automatically when the shift ends.

10. Transfers outside the Kingdom

Some data may be processed or stored with technical service providers inside or outside the Kingdom of Saudi Arabia, including data centres in other regions.

Any transfer outside the Kingdom is carried out in accordance with the PDPL, its Implementing Regulations and the data transfer rules issued by the competent authority, after confirming that:

• Appropriate contractual safeguards are in place with the receiving party;
• The transfer does not prejudice national security or the vital interests of the Kingdom; and
• The transfer is limited to the minimum necessary for the purpose.

11. How we protect your data

We apply security, technical and organisational measures appropriate to the level of risk, including:

• Encryption in transit between the app and our systems (HTTPS/TLS).
• Encryption of sensitive data at rest on end-user devices, with session credentials held in secure storage.
• Access restricted to authorised staff only, on a least-privilege basis.
• Multi-factor authentication on administrative systems.
• Audit logs for sensitive access and changes.
• Monitoring for abnormal usage and intrusion attempts.
• Periodic security reviews and vulnerability testing.

No information system can be guaranteed absolutely secure. You remain responsible for protecting your own sign-in credentials and not sharing them with others.

12. Retention

We keep data for as long as needed for the purpose it was collected for, or for the period required by law — whichever is longer:

After that, data is deleted or anonymised where practically and legally possible.

13. Account deletion

You can request deletion at any time from Settings → Delete account in the app, or by emailing support@efadgo.com if you can no longer sign in.

What happens next:

• The account is scheduled for deletion 30 days after the request. During that window you can sign in and restore the account to cancel the request.
• Once the window closes: the account is permanently deactivated, all sessions on all devices are revoked, and the mobile number is released so it can be used to register again.

What is kept despite deletion: tax invoices and financial transaction records (a five-year statutory obligation), and trip history under the retention policy above. To request erasure of additional data, contact privacy@efadgo.com.

14. Children's privacy and eligibility

The Service is intended for people aged 18 or over. We do not knowingly collect personal data from children; if we learn that we have, we take steps to delete it.

Where the Service is used for a person with a disability or limited mobility through a companion, the companion confirms they are authorised to do so and to provide data on that person's behalf.

15. Your rights

Under the PDPL you have the right to:

How to exercise them

Send your request to privacy@efadgo.com or through in-app support. We may ask you to verify your identity or ownership of the account before acting, to protect your data.

Response time: we respond within 30 days of receiving a complete request. If we cannot fulfil it in whole or in part for a legal reason, we will explain why.

Withdrawing consent or deleting data may make some or all of the Service unavailable to you.

Complaints

If you are not satisfied with our response, you may complain to the Saudi Data and Artificial Intelligence Authority (SDAIA), the authority supervising the application of the PDPL.

16. Notifications and messages

17. Cookies and similar technologies

The mobile app uses no advertising cookies. Our web platforms, where they exist, may use strictly necessary cookies for session and security purposes, and analytics cookies to measure performance. These can be managed from your browser settings.

18. Data breach notification

If a personal data breach, loss, or unauthorised access occurs that may cause harm to the individuals concerned, we will notify the competent authority within the statutory period and inform affected individuals without undue delay, describing the nature of the incident and the steps taken to limit its impact.

19. Changes to this policy

We may update this policy from time to time as the Service or regulatory requirements evolve.

• The Last updated date at the top of this document changes with every revision.
• For material changes, we notify users in the app or through approved channels before they take effect.
• Continuing to use the Service after a change takes effect means you are aware of the updated version.

Previous versions are available on request from privacy@efadgo.com.

20. Contact us

Governing language: this policy is issued in Arabic and English. In the event of any discrepancy in interpretation, the Arabic text prevails.

© Efad Smart Information Technology Company. All rights reserved.