Privacy Policy — Ride-sharing and Parcels

1. Controller

GOMO CAPITAL MANAGEMENT LTD, registered in England and Wales under number 16395341, is the controller of the personal data processed across every brand of this platform. The corporate details are on the public Companies House register.

2. Privacy contact / DPO

Where required, we will appoint a DPO. Privacy contact: privacy@borai.run. If you are outside the United Kingdom, we operate under the UK GDPR representative rules.

3. Data we process in this activity

• Account and profile: nickname, photo, age, city, telephone number, email address and language
• Driver: driving licence, vehicle details (model, colour, year, number plate and vehicle registration document), fuel consumption, accepted payment methods, preferences and journey schedule
• Journeys and bookings: origin, destination, stops, dates, times, seats, prices, booking statuses, cancellations and no-shows
• Parcels: category, description, declared value, photo of the item at collection, collection code and recipient details
• Location: the driver's last position during a journey in progress
• Communications: booking messages, Assistant replies and notifications sent
• Trust and safety: verified face badge, ratings, incidents, reports and fraud signals

4. Verified face and driving licence

To use ride-sharing and parcels, the verified face badge is mandatory for drivers, passengers and senders, because it is the main protection against fraud, robbery and kidnapping. Verification is carried out with live gestures in the app and compares the face with the profile photo. We keep the result and the verification captures; no other user sees those captures, only the badge.

To carry people, the driver submits a photo of a driving licence valid in the country where they drive. The check is the same for a licence from any country: the app confirms that the document is legible and compares the portrait printed on it with the face verified live. Other users only see an indication that the licence has been approved, never the document.

5. Location

During a journey in progress, the driver's position is used to show the route, the arrival and the estimated time to those with a booking on that journey. It is only shown to the parties to that journey and to those who received the share-journey link, and only while the journey is taking place. We keep only the last position, for a few minutes; we do not record the route history.

The addresses and cities you enter are looked up in a mapping service to complete and locate the address. The distance used for the suggested price is calculated from the coordinates of the stops.

6. Parcel recipient data

To deliver a parcel, the sender provides the name and contact details of the person who will receive it — often someone who is not a Borai user. The sender declares that they are authorised to provide that data. It is used solely to send the tracking link with the collection code and to enable the driver to make the delivery, and the link ceases to be valid once the parcel is completed.

7. Who sees what

• Anyone: the driver's public profile (nickname, photo, rating, badges, schedule and cities of the stops)
• Passenger or sender with a confirmed booking: the vehicle's model, colour and number plate, the meeting point, the progress of the journey and the messaging
• Anyone who received the share-journey link: the progress of that journey until arrival
• Driver: the nickname, photo, badge, rating and leg of whoever booked; for parcels, the declaration and the item, never the contents beyond what was declared
• Recipient: the progress of the parcel and the code, via the link they received
• No one: facial verification captures, the image of the driving licence and the vehicle registration document

8. Legal bases

• Performance of the contract: publishing, searching, booking, messaging, delivering parcels and rating
• Fraud prevention and safety of the data subject (the fraud-prevention and safety legal basis of the applicable law): verified face and comparison with the driving licence
• Compliance with a legal obligation: retention of records and responding to orders from authorities
• Legitimate interest: journey safety, anti-fraud, reputation and service improvement
• Consent: device location permission, WhatsApp notifications and marketing, which may be withdrawn at any time

9. Automated decisions

Approval of the face badge and the driving licence, reading of the document and some fraud signals are automated. A refusal may be challenged and reviewed by a person: write to privacy@borai.run or use the appeals channel. Verification may also be redone through the app.

10. Sharing

We do not sell your data. We share only with essential processors (hosting, authentication, anti-fraud, moderation, support) under contract, and with authorities where required by law. See Sub-processors.

We use Google reCAPTCHA Enterprise to protect account access against abuse and automated login attempts. It runs invisibly at that step and sends usage data to Google — IP address, device and browser information, and on-page interactions — to compute a risk score; we do not use it for advertising. That processing is governed by Google's Privacy Policy and Terms of Service (policies.google.com/privacy and policies.google.com/terms).

11. The HZION group and centralised identity

Borai is a white-label brand served by HZION, the group's core platform. Your account, your identity and your profile data are created and held ONCE on HZION's central infrastructure — there is no per-brand copy — even though you registered and sign in on borai.run.

HZION is operated by the SAME controller, GOMO CAPITAL MANAGEMENT LTD: this centralisation is not disclosure to a third party, which is why it does not appear in the processor list in the previous section. The infrastructure is globally distributed, so processing may take place in more than one country — see the international transfers section.

In practice: an account created on any brand in the group is the same account before HZION; a data-subject right you exercise applies to all of them at once; and deleting your account deletes the central record, not just the brand you signed up on. Questions: privacy@borai.run.

Each brand may process data specific to its own activity — for example, the route and location of a trip, the delivery address of an order or the account of a legal case. That data is also held on HZION's central infrastructure, under the same controller, and is described, with purpose, legal basis and retention period, in the Privacy Policy of the brand on which you use that activity.

12. International transfers

Restricted transfers rely on UK GDPR safeguards: adequacy decisions, the UK International Data Transfer Agreement (IDTA), the UK Addendum to the SCCs, or another valid mechanism.

13. How long we keep data

• Bookings, journeys, parcels, incidents and ratings: for the limitation period for consumer claims required by the law of the user's country
• Driver's position: only the last one, for a few minutes, while the journey is taking place; the route is not recorded
• Recipient data: until the end of the claim period for the parcel
• Facial verification captures and image of the driving licence: for as long as the badge or the licence is used on the account and for up to 6 months afterwards, to investigate fraud
• Access logs: for the period required by the law of the user's country
• Once the account is deleted, the data is erased or anonymised at the end of these periods

14. Your rights (Art. 15-22)

• Access a copy of your data
• Correct incomplete or out-of-date data
• Request erasure
• Restrict or object to processing
• Portability
• Withdraw consent
• Complain to the ICO at ico.org.uk

15. Security and breaches

We use encryption in transit and at rest, access control and continuous moderation. In the event of a breach with material risk, we will notify the ICO within 72 hours and inform you where required. Contact: privacy@borai.run.

Private conversations and moderation. Private messages are end-to-end encrypted and the server that carries them cannot read them. To investigate reports and enforce the Terms and the Guidelines — for example grooming, scams or harassment —, your devices also keep a copy of your history key encrypted for the platform's moderation. With it, the support team can read, in a support session recorded in an audit trail, the account's kept history (up to 72 hours, according to the retention period chosen) and decide a block or a ban. Outside that session, nobody at the platform opens these messages.