Privacy Policy

1. Controller and contact

• Fatuka Management Shuttle & Tours CC
• 7 Schuster Street, Windhoek, Namibia
• Phone / WhatsApp: +264 81 452 1250
• Email: reservations@fatuka.com

This statement covers this website, the booking routes of our partner businesses, and our driver app ("Transfer planner", Android). Section 4 describes the app separately, because the data processed there belongs to our drivers rather than to our guests.

2. Applicable law

As at September 2026, Namibia has no comprehensive data protection statute in force. A Data Protection Bill has been before Parliament since 2025 but has not been enacted. What applies today is Article 13(1) of the Namibian Constitution, which protects the privacy of homes, correspondence and communications, together with a number of sector-specific rules. There is currently no dedicated supervisory authority for data protection in Namibia. We process personal data carefully regardless — collecting only what is needed for the purposes described below, and securing it as set out in section 11.

Many of our guests book from within the European Union. Where a person is located in the EU at the time personal data about them is collected, the General Data Protection Regulation (GDPR) may apply under its Article 3(2), even though we are established in Namibia and not in the EU. Section 10 sets out the rights this gives such guests.

3. What data we collect

Booking data: first and last name of the contact person, email address, phone number with country code, nationality of the travelling guests, number of passengers, pickup and destination address including coordinates, date and time, optionally a flight number, a preferred vehicle type, and any free-text notes you add.

Payment and document data: quotes, invoices and, for partners billed on a monthly basis, consolidated statements; these may include a billing address and tax number if you provide one. We do not collect or store card data — there is no payment card integration; payment is made by bank transfer, cash deposit or cash in person.

Login credentials: only for business customers with their own account (partners, lodges and agents). We store a username and a password hash, never the password itself.

Email delivery data: booking confirmations, quotes and invoices are sent through a third-party email delivery service; delivery status is logged.

Flight numbers: if you provide a flight number, we store it with your booking so that we can plan the pickup time. We do not query any external flight data service; the interface merely links to public flight-tracking websites that you can open yourself. We transmit no data to those websites.

Routing data: to calculate distance and travel time, we send pickup and destination coordinates to mapping and routing services that we operate ourselves, on our own servers.

Booking-edit link: the confirmation email contains a link with a random token that lets you view and change your booking without creating an account — see section 8.

Technical request data: to protect the booking forms and the login against automated abuse, we count how many requests come from the same sender. Your IP address is not stored: it is turned into a short, irreversible fingerprint (SHA-256), and only that fingerprint is recorded, with a timestamp. The IP address cannot be recovered from it. These counting entries are deleted automatically once the relevant time window has passed. We do not keep web server access logs containing IP addresses, and we do not record IP addresses against bookings or accounts. The booking and enquiry forms additionally use two simple robot checks: a hidden field that a person never sees, and the time taken to complete the form.

4. Driver data in the driver app

Our drivers use a dedicated Android app ("Transfer planner"). It is a work tool for our drivers and is not open to guests. No account can be created in the app: accounts are set up by the business only.

The app processes:

Driver credentials: a username and a password hash, never the password itself. Plus a device marker, so that a lost device can be signed out individually.

Trip data: the trips assigned to that driver, with times, places and the contact details of the guests to be collected, so that the driver can carry out the trip; the start and end of the trip, which the driver records in the app.

Vehicle checks: answers about the vehicle's condition before and after a trip, the odometer reading, the fuel level, photographs of the vehicle, and a signature drawn with a finger by the driver.

Damage and incidents: a description, photographs and the time. When a driver reports damage, the app requests the device's current location once, to record where the damage occurred.

Receipts and refuelling: amount, date, purpose and a photograph of the receipt, when a driver submits an expense or records a refuelling.

Notifications: to deliver alerts about new or changed trips we use Google Firebase Cloud Messaging. A device identifier generated by Google (a push token) is sent to us and stored. It contains neither a name nor a location.

On location, explicitly: the app does not track the driver. There is no continuous location tracking, no movement trail and no location request in the background — the app deliberately does not request the Android permission needed for that, ACCESS_BACKGROUND_LOCATION, and our interface does not accept a movement trail either. Location is requested only at the single moment when a driver reports damage. A separately available vehicle-tracking option concerns the vehicle, not the driver's app.

A running foreground service: while a trip is under way, the app shows a persistent notification with the route and a running timer. It serves only to keep the driver informed; no additional data is collected and nothing is transmitted in the background.

Where the GDPR applies, the legal basis is the performance of the employment relationship (Art. 6(1)(b)) and our legitimate interest in being able to evidence vehicle condition and damage events (Art. 6(1)(f)).

5. Purposes and legal basis

We process this data in order to:

• receive, confirm, plan and carry out the transfer you booked;
• produce quotes, invoices and consolidated statements, and meet our accounting and tax record-keeping obligations;
• calculate routes, distances and travel times;
• maintain accounts for business partners;
• assign trips to our drivers and keep a traceable record of vehicle condition, damage and expenses;
• keep our systems secure and our records accurate.

To the extent this maps onto the GDPR's scheme, the closest bases are: performance of a contract (Art. 6(1)(b)), legal obligation such as tax or commercial retention (Art. 6(1)(c)), legitimate interests (Art. 6(1)(f)), and, where we obtain it separately, consent (Art. 6(1)(a)).

We send no marketing newsletters, carry out no profiling, and make no automated decisions with legal or similarly significant effects for you.

6. Recipients and service providers

We share personal data only where it is necessary to provide the service:

• Resend, our email delivery provider, to deliver confirmations, quotes and invoices;
• Google Firebase Cloud Messaging, solely to deliver notifications to our drivers' devices (see section 4);
• mapping and routing services (OSRM and OpenRouteService), which we operate ourselves on our own servers — your pickup and destination coordinates go to no third-party map provider.

Where a partner business — a lodge, a hotel or an agent — books on your behalf, that partner can see, in their portal, the bookings they created for you.

We do not share personal data with advertising networks and we do not sell personal data.

Hosting and location of our servers: Hetzner Online GmbH, Germany (European Union). The database, documents and photographs are held on that server; our staff in Namibia access it over the internet, encrypted.

7. Cookies

This website uses exactly two cookies, both technically necessary:

• a cookie that stores the language you chose;
• a session cookie, set after you sign in or after you open your booking-edit link.

We use no advertising cookies, no analytics cookies and no other tracking technology. The driver app contains no advertising, no analytics tooling and no cookies.

8. The booking-edit link and its security

The confirmation email for a public booking contains a link with a random token, so that you can view and change your booking without an account and without signing in. We do not store the token itself, only its SHA-256 hash, so the token cannot be reconstructed from our database. The link is valid for a limited time only. Please do not forward the confirmation email to people who should not have access to your booking.

9. Retention

We keep booking and accounting records for as long as our tax and commercial retention obligations require, and we do not keep personal data longer than the purpose for which it was collected requires.

Exception: damage and accident records. Records of damage and accidents — description, photographs, time, place, and the vehicle and driver involved — are kept permanently, including after a driver has left our employment or a vehicle has been disposed of. The reason is evidence: claims arising from a road accident, queries from insurers and authorities, and a vehicle's history can arise years later, and an accident file without the people and vehicles involved answers none of those questions. A deletion request therefore does not lead to the deletion of these records; in such cases we consider whether restricting the processing is possible instead.

Counting entries from the abuse protection (section 3) are deleted automatically once their time window has passed.

If you wish to request deletion of a partner portal account or a driver account, a message to the address in section 13 is enough.

10. Your rights

Guests in the EU (GDPR)

If you are located in the European Union at the time personal data about you is collected, you have the right under the GDPR to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased, unless a retention obligation or an exception under section 9 stands in the way;
• have processing restricted;
• receive your data in a portable format;
• object to processing based on our legitimate interests;
• lodge a complaint with a supervisory authority in an EU member state.

Your data is stored on a server in Germany and therefore within the European Union (section 6). Fatuka itself is established in Namibia; the European Commission has made no adequacy finding for Namibia. Access by our staff from Namibia is therefore, from an EU perspective, a transfer to a third country. We limit collection to what your booking requires and secure the data as described in section 11.

All other guests and customers

Wherever you are located, you can contact us at any time using the details in section 13 to find out what data we hold about you, to ask for it to be corrected, or to ask for it to be deleted once we no longer need to retain it for tax or commercial reasons and no exception under section 9 applies. We respond within the bounds of Namibian law and our own retention obligations.

11. Data security

We transmit data encrypted (TLS); in its published build, the driver app refuses unencrypted connections. Credentials are stored as a hash, never in clear text. Credentials for tracking providers are held encrypted in the database. Access to booking, payment and account data is limited to staff who need it for their work; in the app, a driver sees only the trips assigned to them.

12. Changes to this statement

We may update this privacy statement from time to time, for example when our services or the legal requirements change. The version published on this website at the time is the one that applies.

13. Contact for data protection matters

For questions about this privacy statement, about the data we hold about you, or to request deletion of an account, please contact:

• Fatuka Management Shuttle & Tours CC
• Email: reservations@fatuka.com

Last updated: 24 September 2026