Privacy Policy

Last updated: 20 August 2024

Introduction

This Privacy Notice describes how we, GROUP20.LIMO and/or its affiliates (“GROUP20.LIMO”, “SPREE.LIMO”), collect, store, use, process, retain, transfer, disclose and protect your Personal Information. This Privacy Notice applies to all Users of our mobile applications (including the User application, merchant application and the driver partner application), websites, services and products (together, the “Applications”), unless covered by a separate privacy notice.

Please read this Privacy Notice thoroughly to ensure that you understand our data protection practices. Unless otherwise defined, all capitalized terms used in this Privacy Notice shall have the same meaning ascribed to them in the applicable Terms of Use between you and GROUP20.LIMO LLP.

Acknowledgment and Consent

By accepting the Privacy Notice, you acknowledge that you have read and understood this Privacy Notice and you accept all of its terms. In particular, you agree and consent to us collecting, using, sharing, disclosing, storing, transferring, or otherwise processing your Personal Information in accordance with this Privacy Notice.

In circumstances where you provide us with Personal Information relating to other individuals (such as Personal Information relating to your spouse, family members, friends, or other parties), you represent and warrant that you have obtained such individual’s consent for, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of his/her Personal Information by us.

You may withdraw your consent to any or all collection, use or disclosure of your Personal Information at any time by giving us reasonable notice in writing using the contact details stated below. You may also withdraw your consent for us to send you certain communications and information via any “opt-out” or “unsubscribe” facility contained in our messages to you.

Depending on the circumstances and the nature of the consent which you are withdrawing, you must understand and acknowledge that after such withdrawal of consent, you may no longer be able to use the Application or services. A withdrawal of consent by you may result in the termination of your account or of your contractual relationship with us, with all accrued rights and obligations remaining fully reserved.

Upon receipt of your notice to withdraw consent for any collection, use or disclosure of your Personal Information, we will inform you of the likely consequences of such withdrawal so that you can decide if indeed you wish to withdraw consent.

Personally Identifiable Information We Collect

The Types of Personal Information We Collect About You “Personal Information”

means information which identifies or can be used to identify, contact, or locate the person or device to whom that information pertains. Personal Information includes, but not limited to, name, address, date of birth, occupation, phone number, e-mail address, bank account and credit-card details, gender, identification (including passport or national identity documents) or other government issued identifier, vehicle information, photo, nationality, phone number of our Users and non-Users in your mobile phonebook, health data, financial related information, and biometric information (including but not limited to facial recognition).

Additionally, to the extent other information, including a personal profile, and/or unique identifier, is associated or combined with Personal Information, then that information is also Personal Information.

The types of Personal Information that we collect depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.

To the extent permitted by Applicable Law, we may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

Identity Data includes name, username, identity card, taxpayer identification number, user ID, or other identifier, title, date of birth, gender, place of birth, occupation, nationality, photos and/or biometric data.
Contact Data includes billing address(es), delivery address(es), email address(es), phone numbers and phonebook.
Eligibility Data includes, in relation to Service Provider, the licences, approvals and other authorizations permitting you to operate the vehicle and provide transportation or other services, and insurance policy details.
Transaction Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses, in relation to Users, the type of service sought, details as to the pick-up and/or delivery; and in relation to Service Provider, the type of services that can be accepted at the time.
Financial Data includes bank account and payment card details such as the type of payment card or account used, the name of the issuer of that payment card or account, the name of the holder for that payment card or account, the identification number of that account or payment card, the verification code of that payment card or account, and the expiration date of that payment card or account, as applicable, financial history (including but not limited to payment card or account transaction history, payment card or account details and mapping and/or payment card or account status and states) and credit score.
Payment Data includes details on payments or transfers made through any electronic money and/or electronic wallet facility provided by us such as information relating to the utilization, payment, recipient details (including their account details), amount of payment paid, bill details, and invoice details.
Technical Data includes details on your usage of our Applications such as in app messages, in app search history, internet protocol (IP) address, information as web pages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, mobile advertising ID and other device information including information regarding the manufacturer, model and operating system of the device that you use to access the Applications and crash logs.
Location Data includes your real-time geo-location information.

We may create, use, license or disclose Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Information but would not be considered Personal Information as this data will not directly or indirectly reveal your identity as we will ensure:

(i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and

(ii) the data is then combined with similar data such that the original data forms a part of a larger data set.

If you provide incomplete Personal Information
Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you either choose not to provide that Personal Information or provide us with incomplete Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).

How We Collect Your Personal Information
The Personal Information which we collect may be provided by you directly or by third parties (for example: when you register for or use the Applications, when you contact our customer services, or you otherwise provide Personal Information to us). We may collect information in various forms and for various purposes (including purposes permitted under Applicable Law).

Information obtained from you or from your mobile device directly
You may give us your Identity, Contact, Eligibility, Profile, Financial, and Payment Data, including in situations where requested by us or where required by Applicable Law, when interacting with us directly or by corresponding with us by post, phone, email or otherwise. This includes Personal Information you provide when you:

register and create an Account with us using the Applications;
use the Applications, including if you register as a Service Provider or use the services as a User;
utilize any electronic money and/or electronic wallet facility provided by us (whether as payer or recipient);
apply as a registered or verified account holder of an electronic money facility;
add a source of funds for payment in the Applications;
use the chat features in the Applications; and
give us feedback or contact us.

Information collected whenever you use the Applications
You may give us Technical and Location Data whenever you use and/or visit the Applications. Whenever you access the Applications through your Mobile Device, we will track and collect your geo-location information in real-time.

In some cases, you will be prompted or required to activate the Global Positioning System (GPS) on your Mobile Device to enable us to give you a better experience in using the Applications (for example, to give you information as to how close a Service Provider is to you. You can always choose to disable the geo-location tracking information on your Mobile Device temporarily. However, this can affect the functionalities available on the Applications.

If you use and/or when a payment or transfer is made through the electronic money and/or electronic wallet facility provided by us (whether as payer or recipient), we may collect certain Financial, Profile and Payment Data relating to such payments and transfers.

In addition, whenever you use and/or visit the Applications, certain information may also be collected on an automated basis using cookies. Cookies are small application files stored on your computer or mobile device. We use cookies to track user activity to enhance user interface and experience.

Most Mobile Devices and internet browsers support the use of cookies; but you may adjust the settings on your Mobile Device or internet browser to reject several types of certain cookies or certain specific cookies. Your Mobile Device and/or browser would also enable you to delete at any time whatever cookies have previously been stored. However, doing so may affect the functionalities available on the Applications.

Information collected from third parties
We may also collect your Personal Information from third parties (including our agents, vendors, suppliers, contractors, partners and any others who provide services to us, who collect your Personal Information and/or perform functions on our behalf, or whom we collaborate with).

In such cases, we will only collect your Personal Information for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be).

Specifically if you register for a payment card or account through the Applications and/or access, add and/or link a payment card or account to the Applications (as applicable in your country), we may collect certain financial information and financial history of yours (including but not limited to payment card or account transaction history, payment card or account details and mapping and/or payment card or account status and states) from the issuer of such payment credential or any other third parties.

Information about third parties you provide to us
You may provide us with Personal Information relating to other third-party individuals (including Personal Information relating to your spouse, family members, friends, or other individuals). In such cases, you will, of course, need their consent to do so – see “Acknowledgement and Consent”, above, for further information.

When you are using the chat features in our mobile applications, you will provide us with phone numbers stored on your mobile phonebook to enable you in using our chat features and for other purposes.

In-vehicle recording
We do not mandate or endorse, nor prohibit, the installation or use of in-vehicle recording devices in any Vehicles.

Where such devices are installed and used in any Vehicles, we do not collect any Personal Information from any in-vehicle recordings by such devices, and any collection of Personal Information from such in-vehicle recordings is not being done on our behalf.

The collection of Personal Information from such in-vehicle recordings is solely at the discretion of the Service Provider. We have no control over such collection of Personal Information by the Service Provider and any subsequent use or disclosure by the Service Provider of the Personal Information so collected.

Where you are a Service Provider and choose to install and use such in-vehicle recording devices in your Vehicle, it is your sole responsibility to notify the User of the same. Where you are a User and you have any objection to the use of in-vehicle recording devices within the Vehicle of any Service Provider, you must inform the Service Provider directly and it will be your personal responsibility to do so.

Use of Personal Information

How We Use Your Personal Information

We may use Personal Information collected for any of the following purposes as well as for such other purposes as are permitted by Applicable Law (“Purposes”):

Where you are a User, we may use your Personal Information:

to identify you and to register you as a User and to administer, verify, deactivate, or manage your account as such;
to facilitate or enable any verification as we may in our discretion consider necessary before the Service Provider provides you with the services or before we register you as a User, including performing Know Your Customer (KYC) and credit scoring (where applicable);
to enable Service Provider to provide you with such of the services as you have requested;
to process and facilitate orders and payment transactions made by you, including where applicable, transactions made through any payment card or account available over the Applications;
to notify you of any transaction or activities occurred within the Applications or other system linked to our Applications;
to facilitate account and/or wallet linking, if you initiate account and/or wallet linking feature between your GROUP20.LIMO account or SPREE wallet and third party platform (as applicable);
to communicate with you and to send you information in connection with the use of the Applications;
to notify you of any updates to the Applications or changes to the services available;
to process and respond to enquiries and feedback received from you;
to maintain, develop, test, enhance and personalize the Application to meet your needs and preferences as a User;
to monitor and analyse user activities, behaviour, and demographic data including trends and usage of the various services available on the Application;
to process and manage reward points (as applicable);
to offer or provide services from our affiliates or partners (as applicable); and
to send you direct or targeted marketing communications, advertisement, vouchers, surveys, and information on special offers or promotions.

Where you are a Service Provider, we may use your Personal Information:

to identify you and to register you as a Service Provider and to administer, manage or verify your Account as such;
to facilitate or enable any verification as we may in our discretion consider necessary before we register you as a Service Provider, including for KYC and credit scoring (as applicable);
to enable you to provide services to Users;
to process, facilitate, and complete payments due to you relating to any services you have provided;
to communicate with you and send you information in relation to the provision of your services, including to relay User orders to you and to facilitate your acceptance of such orders;
to provide you with notification and updates on the Applications or changes to the manner in which services are to be provided;
to provide you with a report in relation to the services that you have provided;
to process and respond to feedback from Users on the services which you have provided;
to maintain, develop, test, enhance and personalize the Applications to meet your needs and preferences as a Service Provider;
to monitor and analyse User activities, behaviour, and demographic data including trends and Service Provider responsiveness for the various services available on the Applications;
to process and manage your reward points (as applicable);
to offer or provide services from our affiliates or partners (as applicable); and
to send you direct or targeted marketing communications, advertisement, promos, surveys, and information on special offers or promotions.

Whether you are a User or a Service Provider or otherwise provide Personal Information to us, we may also use your Personal Information more generally for the following purposes (although we will in each such case always act reasonably and use no more Personal Information than what is required for the particular purpose):

to undertake associated business processes and functions;
to monitor usage of the Applications and administer, support and improve the performance efficiency, growth, user experience and the functions of the Applications;
to provide assistance in relation to and to resolve any technical difficulties or operational problems with the Applications or the services;
to generate statistical information and analytics data for the purpose of testing, research, analysis, product development, commercial partnership, and collaboration;
to prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activities;
to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us and/or any of our affiliates;
to enable us to comply with our obligations under any Applicable Law, including but not limited to responding to regulatory enquiries, investigations or directives, complying with statutory or regulatory filing, reporting, and licensing requirements, and conducting audit checks, due diligence and investigations; and
for any other purpose that we notify you of and, where required by Applicable Law, obtain your consent to.

Disclosures Of Your Personal Information

We may disclose to, allow access to, or share with Affiliates and other parties your Personal Information for any of the following purposes as well as for such other purposes as are permitted by Applicable Law:

where you are a User, for the purpose of enabling a Service Provider, to perform or deliver a service, including to contact you;
where you are a Service Provider, for the purpose of enabling a User to request or receive a service from you, including to contact you;
where required or authorised by Applicable Law (including but not limited to responding to regulatory enquiries, investigations or directives, or complying with statutory or regulatory filing, reporting, and licensing requirements), for the purpose so specified in that Applicable Law;
where instructed, requested, required or authorised by the government authorities, for the purpose as specified in the government policy, regulations or Applicable Law;
where there is any form of legal proceeding between you and us, or between you and another party, in connection with, or relating to the services, for the purposes of that legal proceeding;
in relation to any verification as we or other third party may consider necessary before the Service Provider provide you with the services or we register you as a User, including for KYC and credit scoring (as applicable);
where we enable our services in any third party’s platform, (i) to assist us in obtaining your Personal Information and/or (ii) to register you or allow you to use our services from such platforms;
in an emergency concerning your health or safety (whether you are a User or a Service Provider) for the purposes of dealing with that emergency;
in a situation concerning your health or public interest (whether you are a User or a Service Provider), we may share your Personal Information to the government authorities and/or other institutions that may be appointed by the government authorities or have a cooperation with us, for the purposes of contact tracing, supporting government initiatives, policies or programs, public safety and any other purposes reasonably needed;
in connection with, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company, for the purposes of such a transaction (even if the transaction is eventually not proceeded with);
in connection with insurance claim, we will share your Personal Information for the purpose of processing the insurance claim to the insurance company that we engage or have collaboration with;
to third parties (including our agents, vendors, suppliers, contractors, partners and any others who provide services to us or you, perform functions on our behalf, or whom we enter into commercial collaboration with) for or in connection with the purposes for which such third parties are engaged, to perform certain disclosure to the relevant third parties which are technically required to process your transaction or for the purposes of our collaboration with such third parties (as the case may be), which may include allowing such third parties to introduce or offer products or services to you, authenticate you or connect with your Account, or conducting other activities including marketing, research, analysis and product development; and
where we share Personal Information with affiliates, we will do so for the purpose of them helping us to provide the Applications, to operate our business (including, where you have subscribed to our mailing list, for direct marketing purposes), or for the purpose of them conducting data processing on our behalf. For example, a GROUP20.LIMO affiliate in another country may process and/or store your Personal Information on behalf of the GROUP20.LIMO group of companies in your country. All of our affiliates are committed to processing the Personal Information that they receive from us in line with this Privacy Notice and Applicable Law.

Where it is not necessary for the Personal Information to be associated with you, we will use reasonable endeavours to remove the means by which the Personal Information can be associated with you as an individual before disclosing or sharing such information.

We will not sell or lease your Personal Information.

Other than as provided for in this Privacy Notice, we may disclose or share your Personal Information if we notify you and we have obtained your consent for the disclosure or sharing.

International Transfers

When you are using our Applications and services in other countries where our Applications are also accessible (“Designated Country”), we may transfer your Personal Information from the origin country (“Origin Country”) to the Designated Country in order to enable and ensure smooth customer experience when you are using our Applications abroad.

Your Personal Information may also be stored or processed outside of your country by our personnel who work for us in other countries, or by our third-party service providers, vendors, suppliers, partners, contractors or affiliates.

We will comply with the Applicable Law and use all reasonable endeavours to ensure that our Affiliates abroad and all such third-party service providers provide a level of protection that is comparable to our commitments under this Privacy Notice and what is required under the laws of your country.

You understand and consent to the transfer of your Personal Information out of your home country and/or the Origin Country as described in this Privacy Notice.

Protection of Personal Imformation

Data Security

Confidentiality of your Personal Information is of utmost importance to us.

We will use all reasonable efforts to protect and secure your Personal Information against access, collection, use or disclosure by unauthorized persons and against unlawful processing, accidental loss, destruction and damage or similar risks.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Information which you transmit over the Internet, nor guarantee that such Personal Information would not be intercepted, accessed, disclosed, altered or destroyed by unauthorized third parties, due to factors beyond our control.

You are responsible for keeping your Account details confidential and you must not share your Account details, including your password and One Time Password (OTP), with anyone and you must always maintain and fully responsible for the security of the device that you use.

Data Retention

Your Personal Information will only be held for as long as it is necessary to fulfil the purpose for which it was collected, or for as long as such retention is required or authorized by Applicable Law.

We shall cease to retain Personal Information, or remove the means by which the Personal Information can be associated with you as an individual, as soon as it is reasonable to assume that the purpose for which that Personal Information was collected is no longer being served by retention of Personal Information and retention is no longer necessary for legal or business purposes.

Please note that there is still the possibility that some of your Personal Information might be retained by the other party, including by the government institutions in some manner. In the event we share your Personal Information to the authorised government institutions and/or other institutions that may be appointed by the government authorities or have a cooperation with us, you agree and acknowledge that the retention of your Personal Information by the relevant institutions will follow their respective policy on data retention.

Information relayed through communications between Users and Service Provider made other than through the use of the Applications (such as by telephone calls, SMS, mobile messaging or other method of communication and collection of your Personal Information by our agent) may also be retained by some means.

We do not encourage the retention of Personal Information by such means and we have no responsibility to you for the same. To the fullest extent permitted by Applicable Law, we shall not be liable for any such retention of your Personal Information.

You agree to indemnify, defend and release us, our officers, directors, employees, agents, partners, suppliers, contractors and affiliates from and against any and all claims, losses, liabilities, expenses, damages and costs (including but not limited to legal costs and expenses on a full indemnity basis) resulting directly or indirectly from any unauthorised retention of your Personal Information.

Your Legal Rights

Your Rights as a User

You may have certain rights under Applicable Law to request us for access to, correction of and/or deletion of your Personal Information in our possession and control. To the extent these rights are available to you under Applicable Law, you may exercise these rights by contacting us at the details provided in the section below.

We reserve the right to refuse your requests for access to, correction of and/or deletion of, some or all of your Personal Information in our possession or control if permitted or required under any Applicable Law. This may include circumstances where the Personal Information may contain references to other individuals or where the request for access or request to correct is for reasons which we reasonably consider to be trivial, frivolous or vexatious.

Subject to Applicable Law, we reserve the right to charge an administrative fee for any access and/or correction requests.

Other Websites & Services

Other Websites and Services

The Applications and Marketing Materials may contain links to websites that are operated by third parties. We do not control nor accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. Please consult the terms and conditions and privacy policies of those third-party websites to find out how they collect and use your Personal Information.

When you are using our Applications and enable the fingerprints and/or facial recognition features in your Mobile Device for authentication purposes, please note that we do not store such biometric data. Unless otherwise notified to you, such data is stored in your mobile device and may also be stored by third parties, such as your Mobile Device’s manufacturer. You agree and acknowledge that we are not responsible for any unauthorised access or loss towards such biometric data which is stored in your Mobile Device.

Advertisements contained on our Applications or Marketing Materials operate as links to the advertiser’s website and as such any information they collect by virtue of your clicking on that link will be collected and used by the relevant advertiser in accordance with the privacy policy of that advertiser.

Marketing And Promotional Material

We and our partners (including vendors, suppliers, merchants and/or other third-parties that engaged with us for commercial and/or non-commercial activities may send you direct marketing, advertisement, and promotional communications via push-notification app, message in Applications, post, telephone call, short message service (SMS), chat platform, social media, and e-mail (“Marketing Materials”) if you have agreed to subscribe to our mailing list, and/or consented to receive marketing and promotional materials from us.

You may opt out from receiving such marketing communications at any time by clicking on any “unsubscribe” facility embedded in the relevant message, or otherwise contacting us using the contact details stated below.

Please note that if you opt out, we may still send you non-promotional messages, such as ride receipts or information about your Account.

Updates To the Privacy Notice

We may review and amend this Privacy Notice at our sole discretion from time to time, to ensure that it is consistent with our future developments, and/or changes in legal or regulatory requirements. If we decide to amend this Privacy Notice, we will notify you of any such amendments by means of a general notice published on the Application and/or website, or otherwise to your e-mail address set out in your Account.

You agree that it is your responsibility to review this Privacy Notice regularly for the latest information on our data processing and data protection practices, and that your continued use of the Application or website, communications with us, or access to and use of the services following any amendments to this Privacy Notice will constitute your acceptance to this Privacy Notice and all of its amendments.

Country Specific

If You Are Located in Singapore

This section applies if you are located in Singapore.

How we collect your Personal Information

In-vehicle recording
Where you are a Service Provider and choose to install and use in-vehicle recording devices (IVRDs) in your Vehicle, it is your sole responsibility to comply with all Applicable Law (including but not limited to any directions and guidelines issued by the Land Transport Authority (“LTA”) and the Personal Data Protection Commission) in respect of the same. Without limitation, you must:

ensure that LTA’s approval has been obtained to install any inward-facing IVRD in your Vehicle;
ensure that any inward-facing IVRD in your Vehicle has been installed at an LTA-authorised installation centre;
notify us within 24 hours of an inward-facing IVRD being installed in your Vehicle; and
affix signs or decals on your Vehicle to notify Users of the use of such devices in your Vehicle.

Where you are a User, we will notify you via the User application if a Service Provider has installed an authorised inward-facing IVRD in his or her Vehicle, where such inward-facing IVRD has been notified to us. If you have any objection to the use of an inward-facing IVRD within the Vehicle of any Service Provider, it is your responsibility to cancel your order immediately. If you become aware of the use of an inward-facing IVRD in any Vehicle, that was not notified to you via the User applications, please inform us via the User application so that we can investigate accordingly.

National Identification Numbers
Where you are a User, we do not collect, use or disclose your National Registration Identity Card (“NRIC”) or other national identification numbers for the purposes of your use of the Application. Where you are a Transportation Provider, please note that we are entitled to collect, use, and disclose your NRIC number or Foreign Identification Number (“FIN”) to comply with our obligations under Applicable Law and to prevent, detect and investigate any fraudulent activity over the applications.

Language
This Privacy Notice may be translated into one or more other languages. If there is any inconsistency between the English version of this Privacy Notice and other language versions, the English version shall prevail.
Miscellaneous
For avoidance of doubt, Service Provider shall also include the reference of Transportation Provider as provided in the Terms of Use of Singapore.