BLUESG PRIVACY STATEMENT

BLUESG PRIVACY POLICY
Last updated: 28 May 2019

This Privacy Policy (the “Privacy Policy”) sets forth BlueSG’s (“BlueSG,” “We,” “Us,” or “Our”) privacy practices and the possible uses of the Personal Information (as defined below) that it gathers from its members (“Member,” “You,” or “Your”) pertaining to their membership in the BlueSG carsharing program and the BlueSG charging service (“Membership”). 

 

SCOPE

This Privacy Policy applies to certain information collected by the BlueSG website (the “Site”), the BlueSG mobile application (the “App”), global positioning service (“GPS”) technology, BlueSG cars (“BlueSG Car”), charge points (“BlueSG Charge Points”) or the BlueSG Customer Relations Centre (“BlueSG CRC”) (collectively, the “Service”). The Service may contain links to or information about other web sites that are outside the control and/or custody of BlueSG. We encourage You to review the privacy policies of each of those sites to obtain an understanding of how Your information is used or shared by those third-parties. BlueSG is not responsible for the privacy practices of any external website or mobile application.

 

COLLECTION AND PROCESSING OF PERSONAL INFORMATION

All information that You provide within the Service and information that is otherwise collected by the Service that may be used to identify You (“Personal Information”), could be collected or processed by BlueSG as well as its affiliate entities and parent companies. If Your Personal Information 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 Information strictly within the scope of providing the carsharing, charging and ancillary services to You and BlueSG Members.

 

INFORMATION COLLECTED

(1) Information You Provide

When You register as a Member of the Service and use the Service, the following Personal Information 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 contact the BlueSG CRC or otherwise share with BlueSG staff members before, during or after the termination of Your Membership; and  
  • any other Personal Information 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 Information:

  • 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.

 

(iv) Cookies 

BlueSG also may collect information through the use of common information-gathering tools known as cookies. A cookie helps the Site 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 Site 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 Site. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Site, the IP address, and the type of operating system used in the devices used to access the Site. 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 Information 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 that data from Our systems. 

 

USE OF INFORMATION COLLECTED

Direct Marketing: We may use Personal Information 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.

Improving Your Experience: We track Your visits to the Site through the use of cookies and identify You upon subsequent visits to improve Your experience while browsing the Site.

Moreover, We may use Your Personal Information 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 Singapore Police Force, HDB, URA or as otherwise required by law when We believe in good faith that disclosure is necessary to protect Our rights, protect Your safety or the safety of others or respond to a government request;
  • to protect Our rights and/or Our property;
  • to operate Our products and services;
  • to manage the Service and/or the Site;
  • 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 Site; and
  • to ensure the technical functionality and security of the Site.

 

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 Information 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 Information 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 Information 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 Information 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 Information 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 Site.
  • Fraud and Risk Management: You agree to allow Us to collect and disclose the Personal Information about You to a credit reference agency and that such credit reference agency may lawfully process and keep a record of Your Personal Information for the purpose of conducting identity verification and prevent fraud.
  • Sale or Acquisition of Assets:  If BlueSG becomes involved in a transaction involving the sale of its assets, such as a merger or acquisition, or if BlueSG is transferred to another company, BlueSG may disclose and/or transfer Personal Information about You as part of the transaction. If the surviving entity in that transaction is not BlueSG, the surviving entity may use Personal Information pursuant to their own privacy policies, and those policies may be different from this Privacy Statement. 
  • General Marketing: We may share Personal Information 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 Information in the manner detailed herein, BlueSG cannot ensure or warrant that Personal Information 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 Information 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 the Site 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 Information.

 

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 Information 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 privacy@bluesg.com.sg.

Do Not Call Registry. The main messages (SMS, notifications…) that BlueSG may send to Your registered telephone number, or when You are using Our mobile application, are specifically linked to the proper information about and delivery of the BlueSG Service 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.

 

MODIFICATIONS

You can check when this Privacy Policy was last modified by viewing the “Last Updated” legend above.  BlueSG reserves the right to update this Privacy Policy from time to time, and You should check the Site periodically for changes.

 

CONTACTING US

For any questions regarding this Privacy Policy You may contact Us via Our website or by mail to: General Counsel, BlueSG, 16 Science Park Drive, #04-01 DNV GL Technology Centre, Singapore 118227, Attn: Legal Dept.