Privacy – AVFLIMO

Privacy Notice

Effective Date: 1st November 2023

This Privacy Notice and its Addendum(s) (“Privacy Notice”) describe how AVF Rental Pte Ltd, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “AVFLIMO”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of AVFLIMO’s mobile applications and websites (respectively “Apps” and “Websites”), as well as products, features and other services globally, operated by AVFLIMO (collectively, “Services”).

This Notice applies to our consumers, agents, vendors, suppliers, partners (such as driver, delivery and merchant partners), contractors and service providers (collectively “you”, “your” or “yours”).

“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information.

We typically collect, use, disclose or otherwise process your Personal Data in accordance with this Privacy Notice with your consent, or in compliance with applicable laws, such as where:

it is required for us to comply with legal requirements;
it is required for us to enter into or perform a contract with you; and/or
for our legitimate interests or the legitimate interests of any other persons, including but not limited to for the purposes set forth in this Privacy Notice.

I. COLLECTION OF PERSONAL DATA

We collect Personal Data about you in the ways listed below. We may also combine Personal Data collected via these various channels:

You provide your Personal Data to us

We collect your Personal Data when you provide it to us. For example, when you:

complete a user profile or registration forms (such as your name, contact information and other identification information where needed);
provide information to assess your eligibility to provide services as a AVFLIMO driver partner or delivery partner (such as your driver’s license information, vehicle information and background check results);
interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
participate in contests or events organised by us (such as the pictures, audio, or videos you may submit, which may include images of yourself);
verify your identity through various means (such as social media logins, submission of selfie images or independently verified payment card information);
fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation and income information); and
agree to take a ride with in-vehicle audio and/or video recording features.

When our services are used

Personal Data may be collected through the normal operation or use of our Apps, Websites and Services. Some examples are:

your location information;
feedback, ratings and compliments;
transaction information (such as payment method);
information about how you interacted with our Apps, Website or Services (such as features used and content viewed);
device information (such as hardware model and serial number, IP addresses), file and app names and versions, GPS location, IMEI number, and advertising identifiers or any information that may indicate device or app modification);
telematics data (such as your speed, acceleration and braking data);
- we work with partners to install telematics devices in rental vehicles for the following purposes:
  - to ensure that vehicles are maintained appropriately and serviced in a timely fashion;
  - to help maintain the safety, security and integrity of our products and Services;
  - to improve and enhance our products and Services; and
  - for internal tracking of the vehicle, analysis and administrative purposes.
- these partners own and share such telematics data with us:
  - our partners are also contractually obliged to safeguard this data.
personal data you enter in messages when you use our in-app communication features; and
personal data that may be captured through your interaction with us, our agents, in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).
- our in-vehicle applications or devices
  - we may install in-vehicle audio and/or video recording applications or devices to promote the safety and security of our driver partners, delivery partners and consumers.
  - your Personal Data may be captured in these audio and/or video recordings. Where in-vehicle audio and/or video recordings are made, such recordings are collected, processed, used and stored in a manner in accordance with this Privacy Notice and applicable laws.
- personal in-vehicle applications or devices
  - some AVFLIMO partners may install personal in-vehicle applications or devices in their vehicles for their own purposes. This practice is not endorsed nor prohibited by AVFLIMO;
  - the collection, use and disclosure of Personal Data obtained from personal in-vehicle applications or devices is the responsibility of the relevant partner. Please check with the relevant partner if you have any queries about their use of personal in-vehicle cameras.

From other sources

We may collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources. Such sources include:

referral programmes;
our business partners, such as fleet partners, payment providers, ride-hailing partners and transport partners;
insurance and financial providers;
credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
publicly available or governmental sources of data;
when our users add you as an emergency contact;
when our users add you as a recipient or beneficiary of any use of our Services;
when you use our in-app chat; and
marketing services providers or partners.

Sensitive Personal Data

Some of the Personal Data that we collect may be sensitive in nature. This may include Personal Data pertaining to your race, national ID information, religious beliefs, background information (including financial and criminal records, where legally permissible), health data, disability, marital status and biometric data, as applicable. We collect sensitive Personal Data only with your consent and/or in strict compliance with applicable laws. In the event that you are required to furnish any documentation or information to us for any Purpose which may contain such sensitive Personal Data (which is not required that Purpose), you agree to redact such sensitive Personal Data before providing such documentation or information to us.

When you provide Personal Data of other individuals to us

In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may add them as your emergency contact, when you use the in-app chat or when you add them as recipients or beneficiaries of any use of our Services. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Privacy Notice.

Personal Data of minors

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to AVFLIMO. In the event that such Personal Data of a minor is disclosed to AVFLIMO, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Notice and take responsibility for his or her actions.

II. USE OF PERSONAL DATA

AVFLIMO may use your Personal Data for the following purposes set out in the list below. (“Purposes”). Additionally, if you use AVFLIMO in various capacities (for example, if you use multiple AVFLIMO Services, or if you are both a driver partner/delivery partner and a consumer), we may link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below:

Providing services and features

Your Personal Data will be used to provide, personalise, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:

engage you to provide you with Services across our various business verticals;
create, administer and update your account;
process, manage or verify your eligibility for or application of products, Services, promotions, rewards and subscriptions with AVFLIMO;
conduct due diligence checks and risk assessments / analysis;
verify your identity and age (where necessary);
validate your ride and process payments;
offer, obtain, provide, facilitate or maintain insurance or financing solutions;
track the progress of your trip and detect abnormal trip variations;
allow you to participate in the loyalty programmes or marketing activities organized by our merchant-partners and/or in collaboration with AVFLIMO;
personalise your App experience (such as to recommend products and services relevant to you, identify your preferences or otherwise personalise your experience with AVFLIMO);
make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;
perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
enable communications between our users;
invite you to participate in our surveys and studies;
enable our partners to manage and allocate fleet resources; and
fulfil the services to you as a data processor, where you have provided consent to the data controller (i.e. the organisation you had purchased goods or services from, and for whom AVFLIMO is providing services on behalf of) for such services to be rendered.

Safety and security

We use your data to ensure the safety and security of our Services and all users. This includes:

screening driver and delivery partners before enabling their use of our Services;
identifying unsafe driving behaviour such as speeding, harsh braking and acceleration, and providing personalised feedback to driver partners;
verifying your identity when you log in to AVFLIMO;
using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
sharing drivers and passengers of driver partners’ location and details when the emergency button or the “Share My Ride” feature is activated; and
monitoring compliance with our terms and conditions and policies.

User support

We use Personal Data to resolve user support issues. For example, we may:

investigate and address concerns;
monitor and improve our user support responses;
respond to questions, comments and feedback; and
inform you about steps taken to resolve user support issues.

Research and development and security

We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services, and facilitate development of insurance and finance solutions.

Legal purposes

We may use the Personal Data we collect for legal purposes, such as to investigate and resolve claims or disputes, detect/prevent/prosecute crime, or as allowed or required by applicable law.

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

comply with court orders or other legal, governmental or regulatory requirements;
enforce our Terms of Service or other agreements; and
protect our rights or property in the event of a claim or dispute.

Marketing and promotions

We may use your Personal Data to send you marketing communications relating to customised products or services (that may be of interest or relevance based on your profile), or AVFLIMO‘s partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:

send you special offers that may be of interest or relevance to you across all of AVFLIMO‘s service offerings;
send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
notify, invite and manage your participation in our events or activities.

We may communicate such marketing to you by various means, where applicable (including by SMS, chat applications (e.g. WhatsApp, Telegram, LINE, Viber, WeChat, Zalo), push notification, call, and by email).

If you wish to unsubscribe to the receiving of such marketing communications, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings. Please note that while you may opt out of marketing or promotion communications, AVFLIMO may still send you account and / or service-related messages (such as two-factor authentication, information on your transactions, rewards, etc.).

User Published Content

If you publish content (such as a review or comment) on AVFLIMO’s platform, it will be shown publicly along with your personal data (such as profile name, uploaded photo(s)), and other information you choose to include in your content.

III. DISCLOSURE OF PERSONAL DATA

We need to share Personal Data with various parties for the Purposes. These parties include:

Other users

For example:

if you are a passenger of driver partners, we may share your username, pick-up and drop-off locations with our driver partner fulfilling your service request;
if you are a driver partner, we may share your Personal Data with your passenger including your name and photo; your vehicle make, model, number plate, location and average rating;
if you are participating in loyalty programmes or marketing activities organized by our merchant-partners, we may share your Personal Data with them, including your name and contact details;
if you are a delivery partner, we may share your Personal Data with your selected merchant-partner and user, including your name and photo; your vehicle make, model, location and average rating;
if you use our in-app chat service, we may share your mobile number and AVFLIMO -registered name with the other parties to your chat.

With third parties related to your use of AVFLIMO Services

For example:

if you are a passenger of driver partners, we may share a vehicle’s location and driver’s and/or your name with third parties when you use the “Share My Ride” feature or activate the Emergency Button.
if you are a driver-partner, we may disclose your vehicle plate number or other personal data to the insurance company and/or to your passenger for the purpose of submission of insurance claims.
if you use our payment services, we may share your Personal Data with another individual should you authorise and enable connection of his or her third party service payment method to our payment service for the purposes of enabling your payment on AVFLIMO.

With administrators of AVFLIMO accounts that you may use

For example:

your employer may receive transaction data (tagged as business expenses) when you use your employer’s AVFLIMO for Business account.
the administrator of any community group to which you link your AVFLIMO account may receive transaction data when you carry out a transaction.

With subsidiaries and affiliates

We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates. The companies in the AVFLIMO group share resources, such as infrastructure and technology with each other to provide you with a consistent, relevant and secure experience when you use our products or Services, and for the Purposes set out in this Privacy Notice.

For example, we do this to make your experience more seamless, such as by automatically completing your registration information from your use of one AVFLIMO Product or Service when you sign up for a new AVFLIMO Product or Service.

With AVFLIMO’s service providers and business partners

We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:

payment processors and facilitators;
debt collectors;
credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
background check and anti-money laundering service providers;
cloud storage providers;
document storage and management providers;
advertising and marketing partners and platform providers;
data analytics providers;
research partners, including those performing surveys or research projects in partnership with AVFLIMO or on AVFLIMO’s behalf;
educational and training institute partners;
fleet and merchant partners;
insurance and financing partners;
third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
service providers who perform identity verification services; and
vehicle solutions partners, vendors or third-party vehicle suppliers.

For example:

If you requested a service through a AVFLIMO partner or used a promotion provided by a AVFLIMO partner, AVFLIMO may share your Personal Data with that AVFLIMO partner.
If you have rented a vehicle from our recommended fleet partners to drive with AVFLIMO, we may share relevant information (e.g. the status of your account, applicable incentives/promotions, your ride statistics) for collaborative efforts (e.g. create new incentives and benefits for you or improving supply of driver partners).

With our legal advisors and governmental authorities

We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:

where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or
where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).

Business transfers

We may share your Personal Data with other parties, in connection with any acquisitions, sales, mergers, joint ventures, consolidation, restructuring, financing or any other type of business transactions. Your Personal Data will however remain subject to our obligations made in any pre-existing Privacy Notice that you have agreed to.

IV. RETENTION OF PERSONAL DATA

We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Notice unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Notice, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

V. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Your Personal Data may be transferred from the country, state and city (“Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”).

When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.

VI. COOKIES, RELATED TECHNOLOGIES AND ADVERTISING ON THIRD PARTY PLATFORMS

AVFLIMO, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (such as software development kits (SDKs), which have similar functions to cookies and which may be installed in the AVFLIMO App to allow partners to collect certain information about your interaction with the AVFLIMO App) (collectively, “Cookies”) in connection with your use of the Websites and Apps, which may be persistent or stored only during an individual session on your browsers or devices.

Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may be used for various purposes such as to:

provide the essential, basic functions of the use of our Websites, Services or Apps;
authenticate you, or remember your user preferences and settings;
delivering and measuring the effectiveness of advertising campaigns, such as by measuring number of views or clickthroughs;
analyse site traffic and trends;
serve you relevant advertisements across other apps and websites owned by other companies (whether by us or by other advertisers); and
enhance user interface and experience by generally understanding the online behaviors and interests of users who interact with our Website, Services or Apps.

AVFLIMO may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes AVFLIMO does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

Disabling the collection of cookies on our websites

You have the right to choose to disable, block or deactivate cookies. Please note that however refusal or removal of some cookies could affect the availability, functionality or use of our Website, Services or Apps.

You may adjust your internet browser settings to disable, block or deactivate cookies, delete your browsing history or clear the cache from your internet browser. The settings may be contained within the “History”, “Preferences”, “Settings” or “Privacy” section of your internet browsers, or you may otherwise consult the help section of your internet browser for more information. You may also adjust your cookie settings here:

Cookies Settings

Disabling the display of Targeted Ads on other platforms

We may facilitate the display of targeted advertising on other platforms, such as on other online platforms that you may be a user of.

You may be able to limit our use of your Personal Data to display targeted advertisements on behalf of our advertisers, by adjusting your preference through our AVFLIMO App. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Apple’s IDFA or Google’s GAID) and the ability to track you across apps and websites owned by other companies by adjusting the settings available on your mobile devices. Through adjusting the settings on your device, you can typically reset, delete, limit and/or otherwise restrict the use of such mobile identifiers.

Although we will not use your Personal Data to show you such targeted advertisements on other platforms, you may still see generic ads that appear relevant to you. This may be because we have engaged third party advertisers / platforms to display ads to users of specific attributes or demographic makeups who may find them relevant. You may be able to limit seeing these advertisements through managing your preferences on these platforms.

VII. PROTECTION OF PERSONAL DATA

We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.

VIII. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

In accordance with applicable laws and regulations, you may be entitled to:

inquire about the processing of your Personal Data and be provided with a copy of it;
in some cases, request the correction and/or deletion of your Personal Data;
in some cases, request the restriction of or object to the processing of your Personal Data;
withdraw your consent to the processing of your Personal Data within our possession or control (and where we are processing your Personal Data based on your consent);
request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and
complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment as a result of unlawful processing of your Personal Data.

Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, choosing not to share your Personal Data with us, withdrawing your consent to our use of it or to your agreement with our Privacy Notice could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of App or the Services.

After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

IX. AMENDMENTS AND UPDATES

AVFLIMO may modify, update or amend the terms in this Privacy Notice at any time. Such amendments shall be notified to you through the Application and/ or other appropriate means at least five (5) business days before the effective date. The updated version will be posted on the website https://www.avflimo.com. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Apps, Websites or Services, purchase products from AVFLIMO or continuing to communicate or engage with AVFLIMO following the modifications, updates or amendments to this Notice, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.

X. HOW TO CONTACT US

If you have any queries about this Notice or would like to exercise your rights set out in this Notice , please fill-in the following form or direct your mail to our Data Protection Officer. :

For users in other countries,
Name: c/o AVF Rental Private Limited. (Attention: AVFLIMO Privacy Office)
Email Address: Info@avfrental.com

In order for us to attend to your queries expeditiously, we prefer that inquiries be made via the online form.

The original of this Notice is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.