This Privacy Statement (the “Privacy Statement”) 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 you (“Member,” “You,” or “Your”) pertaining to Your membership or use in the BlueSG carsharing program (“Membership”).
This Privacy Statement applies to certain information collected by the BlueSG website (the “Site”), mobile application, global positioning service (“GPS”) technology, BlueSG cars (“BlueSG Car”), charge points (“BlueSG Charge Points”) or the BlueSG Customer Relations Center (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.
- Information You Provide
When You register as a Member of the Service and use the Service, We may collect the following information that You provide to Us and which may be used to identify You (“Personal Information”):
- Driver’s license number;
- NRIC number for Singaporeans and Permanent Residents;
- International driver’s license number for non Singapore citizens;
- Passport number for non Singapore citizens;
- Phone number;
- Email address;
- Postal mailing address;
- Payment card information;
- PIN code registered to access the Service; or
- other personal documents.
- 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.
- 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 technology which allows Us to identify the location of BlueSG Cars (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 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.
- 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.
Moreover, We may use Personal Information about you for the following purposes:
- To communicate with you;
- To prevent and investigate fraud and other misuses;
- To comply with a subpoena or other legal process 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.
Finally, We may use the Car and Positioning Data for the following purposes:
- When the GPS or other technology installed in the BlueSG Car is used by Us for the purpose of locating a stolen, abandoned, or missing BlueSG Car after one of the following: (i) You or law enforcement has informed Us that the vehicle is missing or has been stolen or abandoned, (ii) the BlueSG Car has not been returned following one week after the contracted return date or by one week following the end of an extension of that return date, (iii) We discover the BlueSG Car has been stolen or abandoned, and, if stolen, We have reported the BlueSG Car stolen to law enforcement by filing a stolen vehicle report, unless law enforcement has already informed Us that the vehicle is missing or has been stolen or abandoned;
- In response to a specific request from law enforcement pursuant to a subpoena or search warrant.
- To provide navigation assistance to You;
- To allow for the remote locking or unlocking of the vehicle at Your request;
- To provide you with roadside assistance, such as towing, flat tire, or fuel services, at Your request;
- For the purpose of determining the date and time the BlueSG Car departs from and is returned to the BlueSG Station, and the total mileage driven and the fuel level of the returned vehicle; and
- Any other purpose 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 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, 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. Personal Information about You may be shared with law enforcement officials if it relates to a criminal investigation or alleged illegal activity.
- 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 firstname.lastname@example.org.
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 message
You can check when this Privacy Statement was last modified by viewing the “Last Updated” legend above. BlueSG reserves the right to update this Privacy Statement from time to time, and You should check the Site periodically for changes.
For any questions regarding this Privacy Statement 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.