VIETMAP PRIVACY POLICY

VIETMAP Privacy Policy

Last modified: 15 May 2021

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

This Policy applies to our customers, passengers, agents, vendors, suppliers, 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.

I. COLLECTION OF PERSONAL DATA

We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession.If you have or are a party to multiple relationships with us (for example if you use our Services across our various business verticals, we will link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below.

You Provide Your Personal Data To Us

We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us 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 VIETMAP driver partner or service user (such as your driver’s license information, vehicle information and background check results (as legally permissible));
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 files, 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);
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.

In certain circumstances, you may need to provide your Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstance, may constitute failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.

When our services are used

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

your location (to detect locations and set up route for navigation);
feedback, ratings and compliments;
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 address, file names and versions and advertising identifiers or any information that may provide indication of device or app modification);
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 products, in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).

From other sources

When we collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include:

referral programmes;
our business partners, such as fleet partners, payment providers and business vendor;
publicly available sources of data;
governmental sources of data;
when our users add you as an emergency contact; and
marketing services providers or partners.

Personal Data about Software User

If you are a Software User, we may collect:

telematics data (such as your speed, acceleration, and braking data);
device data (such as accelerometer data, GPS location, your IMEI number and the names of apps you have installed on your device);
your vehicle registration data; and
personal data that may be captured through your interaction with us, our agents, our in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).

Sensitive Personal Data

Some of the Personal Data that we collect is sensitive in nature. This includes 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 this information only with your consent and/or in strict compliance with applicable laws.

In-vehicle recording

VIETMAP’s applications or devices

Some VIETMAP User may install personal in-vehicle cameras solution providing by VIETMAP in their vehicles for their own purposes (including safety and security). The use of such in-vehicle cameras is not endorsed or prohibited by VIETMAP. The collection, use and disclosure of Personal Data obtained from personal in-vehicle cameras 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.

VIETMAP works with some partners (including, but not limited to, Toyota and Hyundai) to install telematics devices in selected rental vehicles for the following purposes:

To ensure that the vehicle is 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.

If you are a device user, these devices will collect telematics data (such as your speed, acceleration, and braking data) and your location information. If you are a passenger onboard one of our vehicles fitted with these devices, your location data (i.e. the position of the car) will be incidentally collected as well.

The data collected by these devices are owned by these partners who have entered into appropriate contractual undertakings with VIETMAP to safeguard this data. While these partners share such telematics data with us (to enable us to fulfil the purposes stated above), we do not share any personally identifying information about our driver partners or passengers with these partners.

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. 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 Policy.

II . USE OF PERSONAL DATA

VIETMAP may use, combine and process your Personal Data for the following purposes (“Purposes”):

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:

provide you with Services across our various business verticals;
engage you to provide Services;
create, administer and update your account;
conduct due diligence checks;
verify your identity;
verify your age (where necessary);
offer, obtain, provide, facilitate or maintain insurance or financing solutions;
track the progress of your trip and detect abnormal trip variations;
enable features that personalise your App, such as lists of your favourite places and previous destinations;
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;
process and manage your rewards;
enable communications between our users;
process, manage or verify your application of promotions, rewards and subscriptions with VIETMAP;
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 VIETMAP 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 VIETMAP;
Using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
Monitoring compliance with our terms and conditions, policies and Driver’s Code of Conduct; and
Detecting, preventing and prosecuting crime.

Customer support

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

investigate and address concerns;
monitor and improve our customer support responses;
respond to questions, comments and feedback; and
inform you about steps taken to resolve customer 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 insurance and finance solutions.

Legal purposes

We may use the Personal Data we collect to investigate and resolve claims or disputes, 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.

We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.

Marketing And Promotions

We may use your Personal Data to market VIETMAP and VIETMAP’s partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:

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 post, telephone call, short message service, online messaging service, push notification by hand and by email.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings.

III. DISCLOSURE OF PERSONAL DATA

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

With the owner of VIETMAP accounts that you may use

For example, if you requested a service through a VIETMAP partner or used a promotion provided by a VIETMAP partner, VIETMAP may share your Personal Data with that VIETMAP partners. Our partners include partners that integrate with our App or our App integrates with, vehicle services partners, or business partners which VIETMAP collaborates with to deliver a promotion, competition or other specialised service.

With subsidiaries and affiliates

We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.

With VIETMAP’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 and other credit reporting agencies;
background check and anti-money laundering service providers;
cloud storage providers;
marketing partners and marketing platform providers;
data analytics providers;
research partners, including those performing surveys or research projects in partnership with VIETMAP or on VIETMAP’s behalf;
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.

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).

IV. RETENTION OF PERSONAL DATA

We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Policy 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 Policy, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

VIETMAP PRIVACY POLICY

VIETMAP Privacy Policy

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