31 May of 2021
This Policy applies to our customers, partners, suppliers, contractors and service providers (collectively “You”, “Your” or “Yours”).
In this Policy:
“Data Protection Laws” means all applicable laws and regulations in any jurisdiction which relate to the collection, disclosure, use or processing of Personal Data, including without limitation to the Singapore Personal Data Protection Act 2012 (“PDPA”), including all amendments thereto and subsidiary legislation enacted thereunder, whether now or in the future.
“Personal Data” refers to any data, whether true or not, about an individual who can be identified, (a) from that data, or (b), from that data and other information to which an organisation has or is likely to have access, and includes, without limitation, Your name, nationality, identification numbers, age, telephone numbers, mailing address and date of birth.
“Data Intermediary” refers to a data intermediary that processes Personal Data on behalf of and for the purposes of Bluecharge.
COLLECTION AND PROCESSING OF PERSONAL DATA
Where your Personal Data is collected and/or processed by an affiliate entity or a parent company of Bluecharge, any subcontractor or third party, that entity (the Personal Data Processor) will act as a subcontractor of Bluecharge and will collect and process Your Personal Data strictly within the scope of executing the Contract and providing the electric vehicle charging and ancillary services to You and Bluecharge Members.
PERSONAL DATA COLLECTED
(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 Passport for non-Singapore citizens and PRs and such as Your Name, date of birth and passport number;
- phone number;
- vehicle registration 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 Bluecharge CRC or otherwise share with Bluecharge staff members before, during or after the termination of Your Membership; and
- any other Personal Data required by Bluecharge 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.
- In order to use some of the functions provided by the App (such as locating a charge point) Bluecharge uses an application program interface which uses GPS, Wifi and mobile network information technology to determine Your current location when using the App. When You first open the App, Bluecharge will ask You for Your consent to use Your location data for this purpose. When You are not using the App Bluecharge does not collect location data. You can withdraw Your consent at any time by changing Your location data settings in the App or on Your mobile device, but this will affect Your ability to use the Service.
Bluecharge 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.
(iv) Web Beacons and Site Visits
Bluecharge 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 18
We do not market to and do not knowingly collect any Personal Data from or about an individual under the age of 18 without the consent of the individual’s parent or legal guardian. If We discover that We have inadvertently collected information from an individual under 18 years of age, We will promptly take all reasonable measures to delete such data from Our systems.
USE OF PERSONAL DATA 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 Us, You may unsubscribe from 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 verify Your identity
- to prevent and investigate fraud and other misuses;
- to comply with a request for information from, or assist in investigations or law enforcement conducted by government and/or authorities whether in Singapore or abroad (including without limitation to the Land Transport Authority of Singapore, Singapore Police Force, Traffic Police, Urban Redevelopment Authority) or as otherwise required by any applicable laws, regulations, codes of practices, guidelines to protect Our rights and/or Our property;
- to operate Our products and Services;
- to manage the Services 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 with 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.
SHARING OF PERSONAL DATA COLLECTED
- We may disclose or transfer 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 Us 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 We may have.
- Worldpay: We do not have any access to Your credit/debit card details (or any other payment means). The actual collection and processing of any online credit/debit card payments is done directly with the secure payment gateway Worldpay, which does not share such data with Us. Worldpay will use Your Personal Data for the purposes of processing Your payment transactions. For more information about the collection and processing of Your Personal Data by Worldpay, please refer to Worldpay’s privacy statement which is available on their website: https://online.worldpay.com/terms/privacy
- 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: We 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 Our rights or property, that of Our members, or of the users of the App and 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: We may also transfer Your Personal Data in connection with any sale, merger, demerger, divestment, consolidation, restructuring and/or acquisition of all or a portion of its assets, business and/or share capital by or into another entity or any similar transaction or combination thereof. For such transfer of Your Personal Data Your consent will be requested. If you do not agree with the transfer of your Personal Data or if You have refused to novate the Contract in accordance with Section 13.5 of the Terms and Conditions, the transfer will not be carried out. Consequently, Your Contract will terminate on the date of Your refusal and you will then have a period of thirty (30) calendar days to proceed with the recovery of your Personal Data. If You wish to recover them You will address your request at the following email address: email@example.com your Personal Data are not recovered within this period, Your Personal Data will be deleted.
- 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 DATA
Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be 100% secure. As a result, while We take reasonable measures to protect all Personal Data in the manner detailed herein, We 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. We will notify You in the event We become aware of a security
breach involving Personal Data in accordance with the requirements under applicable Data Protection Laws. By disclosing Your email address to Us for any reason, You expressly consent to receiving electronic notices from Us in the event of such a security breach.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
Some of the elements of the Services and/or Websites and/or App may be hosted on servers located in countries outside Singapore. The laws applicable to the protection of Personal Data in such countries may be different from those applicable in Singapore or Your country of residence. If We are required to transfer Your Personal Data out of Singapore or Your country of residence, We will ensure that such transfers are compliant with the requirements under the applicable Data Protection Laws. In this regard, We will take such necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations (such as local laws, data transfer agreements or binding corporate rules where applicable) to ensure that these overseas recipients provide a standard of protection to the Personal
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 Data has been used or disclosed by Us within a year before the date of Your request. In addition, You may request Us to correct any error or omission in Your Personal Data 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, what’s app messages...) that We 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..
We may send You from time to time marketing messages pursuant to a special product or service offer or a voucher to Your registered telephone number via SMS or Whatsapp if You have given Us Your clear and unambiguous consent to do so.
You may check when this Policy was last modified by viewing the “Last Updated” legend above. We 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 email@example.com.