Last updated: 1 July 2020
This Policy applies to our customers, partners, suppliers, contractors and service providers (collectively “You”, “Your” or “Yours”).
“Personal Data” refers to any information which is related to an identified or identifiable individual and it includes, without limitation, your name, nationality, identification numbers, age, telephone numbers, mailing address and date of birth.
COLLECTION AND PROCESSING OF PERSONAL DATA
Where your Personal Data is collected and/or processed by an affiliate entity or a parent company of BlueSG, that entity will act as a subcontractor of BlueSG and will collect and process Your Personal Data strictly within the scope of providing the carsharing, charging and ancillary services to You and BlueSG Members.
(i) Data You Provide
When You register as a Member of the Service and use the Service, the following Personal Data may be collected and processed:
- information stated on Your NRIC for Singaporeans and Permanent Residents (“PRs”) such as Your name, address, date of birth and NRIC number;
- information stated on Your driver’s licence such as the issue date and driver’s licence number;
- information stated on Your Passport for non-Singapore citizens and PRs and such as Your Name, date of birth and passport number;
- information stated on Your international driver’s license number for non-Singapore citizens and PRs;
- phone number;
- email address;
- postal mailing address;
- payment card information;
- PIN code registered to access the Service;
- any information provided by You when You contact the BlueSG CRC or otherwise share with BlueSG staff members before, during or after the termination of Your Membership; and
- any other Personal Data required by BlueSG as determined in its sole discretion.
(ii) Information Collected Automatically
The software used in the Service may automatically collect the following information from You that may alone or in connection with other information, constitute Personal Data:
- your Internet Protocol (“IP”) address;
- device ID numbers such as Apple Advertising ID;
- to the maximum extent permitted by law, Your location in accordance with the privacy settings of the device used to access the Service; and
- information about Your browsing activity such as Your browser type, Internet service provider, referring/exit pages, the files viewed on the Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data.
(iii) Car and Positioning Data
BlueSG Cars and BlueSG Charge Points include technology that enables Us to effectively service Memberships. Included within such technology is technology which allows us to collect certain information and GPS data to identify the location of BlueSG Cars in real time (collectively, “Car and Positioning Data”).
By using the Service, You authorize and expressly consent to Our use of the technology included in the BlueSG Car to the maximum extent permitted by law.
BlueSG also may collect Personal Data through the use of common information-gathering tools known as cookies. A cookie helps the Websites remember You and customize Your visit. You have the option to delete or decline cookies by changing Your browser’s settings.
(v) Web Beacons and Site Visits
BlueSG may also use single pixel images on the Websites or in Our emails to You. This technology tells Us more about browsing, click-tracking, viewing, and buying activity.
Finally, Google Analytics is an element of the Websites. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Websites, the IP address, and the type of operating system used in the devices used to access the Websites. By using a browser plugin provided by Google, you can opt out of Google Analytics.
INDIVIDUALS UNDER 21
BlueSG does not market to and does not knowingly collect any Personal Data from or about an individual under the age of 21 without the consent of the individual’s parent or legal guardian. If We discover that We have inadvertently collected information from an individual under 21 years of age, We will promptly take all reasonable measures to delete such data from Our systems.
USE OF INFORMATION COLLECTED
Direct Marketing: We may use Personal Data to generate and send marketing communications to You directly for products and services available for purchase on the Service and/or Our affiliate websites, coupons, or other marketing opportunities. If You do not wish to receive marketing communications directly from BlueSG, You may unsubscribe in the marketing email or communication sent to You by following the instructions in that communication.
We may also use Your Personal Data for the following purposes:
- to communicate with you;
- to prevent and investigate fraud and other misuses;
- to comply with a request for information from government authorities such as the Singapore Police Force or as otherwise required by law;
- to protect Our rights and/or Our property;
- to operate Our products and services;
- to manage the Service and/or the Websites and/or App;
- to enable you to obtain access to products and services and engage in offered activities;
- to provide you information about new and upgraded products and services, and other information where you have consented to be contacted for such purposes;
- to aggregate data;
- to improve Our products and services and Your experience interacting with Us;
- to audit and analyze the Websites; and
- to ensure the technical functionality and security of the Websites.
Telematics system: The BlueSG Cars are equipped with GPS or other “electronic surveillance technology” (collectively, “Telematics System”). You acknowledge that such Telematics System utilizes wireless technology to transmit data and, therefore, privacy cannot be guaranteed and is specifically disclaimed by You. You consent to and expressly authorize Us to monitor the BlueSG Cars through such Telematics System to the extent permitted by law. Further, You acknowledge and agree that:
- We, the operators of the Telematics System, or third parties may have access to the information supplied by the Telematics System including:
- Location of the BlueSG Car before, during and at the time of the conclusion of Your rental period, including real time location of any BlueSG car at any given time;
- date and time of departure and return of the BlueSG Car;
- total mileage driven;
- the charge level of the BlueSG Car; and
- other diagnostic, safety, and performance information to identify and/or repair any technological defects disclosed thereby.
- We, the operators of the Telematics System, or third parties may use or disclose such information to third parties to:
- to provide navigation assistance to You;
- determine the date and time the BlueSG Car departs from and is returned to the BlueSG Station, and the total mileage driven and the charge level of the returned vehicle;
- locate a stolen, abandoned or missing BlueSG car;
- allow for remote locking and unlocking of the BlueSG Car;
- respond to an accident or other emergency or otherwise to ensure Your safety;
- respond to a specific request from law enforcement;
- respond, process, pay for or transfer liability for any ticket, citation, fine or penalty issued by any respective authority;
- establish or prove the validity of charges imposed by BlueSG to Your account; and
- at Your request, provide You with roadside assistance, such as towing, flat tire, or charging services, and otherwise, to the extent permitted by law.
SHARING OF INFORMATION COLLECTED
We may disclose Personal Data about You to the following categories of third parties:
- Our parent companies, affiliates, and subcontractors: You agree to allow Us, Our parent and affiliated companies, and Our and their subcontractors, some of whom may be located outside of Singapore, including, without limitation, in France, in the US and in the UK, to retain and utilize the data collected by Us for the purposes set out in this statement. Those companies, including Our providers and subcontractors are contractually bound to ensure adequate Personal Data protection.
- Service Providers: These entities assist BlueSG in fulfilling orders from Members, providing marketing and advertising services, billing, delivering packages, sending mail, providing search results and links, or similar services.
- Regulatory Bodies: If You apply for Membership, some of the Personal Data about You may be shared with regulatory bodies to obtain Your driving record or to comply with any legal, regulatory or contractual obligation BlueSG may have.
- Law Enforcement and other authorities: Personal Data about You may be shared with law enforcement officials if it relates to a criminal investigation or alleged illegal activity or breach of any applicable laws and regulations, including but not limited to any traffic or parking laws or regulations.
- Necessary for Safety, Security or Protection Reasons: BlueSG may also disclose Personal Data about You if required or permitted to do so by law, for fraud protection and credit risk reduction purposes, or in the good-faith belief that such action is necessary to protect and defend the rights or property of BlueSG, its Members, or the users of the Websites.
- Fraud and Risk Management: You agree to allow Us to collect and disclose the Personal Data about You to a credit reference agency and that such credit reference agency may lawfully process and keep a record of Your Personal Data for the purpose of conducting identity verification and prevent fraud.
- Reorganization / Business Transfer: BlueSG may also disclose Your Personal Data in connection with any merger, demerger, divestment, consolidation, restructuring and/or acquisition of all or a portion of it’s assets, business and/or share capital by or into another entity or any similar transaction or combination thereof. Any such successor entity, assignee and/or purchaser may use Personal Data pursuant to its own privacy policies, and those policies may differ from this Policy.
- General Marketing: We may share Personal Data with third parties for the purpose of marketing products or services to You in compliance with applicable laws.
PROTECTION OF PERSONAL INFORMATION
Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be 100% secure. As a result, while BlueSG takes reasonable measures to protect all Personal Data in the manner detailed herein, BlueSG cannot ensure or warrant that Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network. BlueSG will notify You in the event We become aware of a security breach involving Personal Data that constitutes personally identifiable information under the applicable state and federal laws stored by or for Us. By disclosing Your email address to Us for any reason, You expressly consent to receiving electronic notice from Us in the event of such a security breach.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Some of the elements of the Service and/or Websites and/or App may be hosted on servers located in countries outside Your own country, such as in France. The laws applicable to the protection of Personal Information in such countries may be different from those applicable in Singapore or Your country of residence but are deemed to ensure an adequate level of protection of Personal Data.
YOUR SINGAPORE DATA PRIVACY RIGHTS
Subject to the exceptions as set out in the Personal Data Protection Act 2012, You are permitted to request for access to Your Personal Data that is in Our possession or under Our control and information about the ways in which such Personal Information has been used or disclosed by Us within a year before the date of Your request. In addition, You may request for Us to correct an error or omission in Your Personal Information that is in Our possession or under Our control. If You would like to make such a request, please email Us at email@example.com.
Do Not Call Registry. The main messages (SMS, notifications…) that BlueSG may send to Your registered telephone number, or when You are using Our App, are specifically linked to the proper information about and delivery of the Services to You. Such messages are therefore not considered as “specified messages” under the PDPA. In any case We would like to send You from time to time any specified message pursuant to a special product or service offer or a voucher, We would ask You to actively give Us Your consent to receive such specified messages.
You may check when this Policy was last modified by viewing the “Last Updated” legend above. BlueSG reserves the right to update this Policy from time to time, and You should check the Websites periodically for changes.
For any questions regarding this Policy You may contact Us via Our website or by email to firstname.lastname@example.org.