This Policy applies to our customers, passengers, agents, vendors, suppliers, partners (such as driver 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, gender, telephone number, bank and credit card details, personal interests, e-mail 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 Policy 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 Policy.
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.
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 or fill up a user profile or registration forms (such as your name, contact information, and other identification information where needed);
- interact with our social media pages (such as your social media account ID, profile photo and other publicly available data);
- participate in contests or events organized 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, Google or Apple ID logins, use biometric features, 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, profession and income information); and
- agree to take a ride in our COMET electric vehicles with in-vehicle audio and/or video recording features.
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 information (to detect nearby COMET EVs and relevant location data);
- feedback, ratings and compliments;
- transaction information (such as payment method and distance travelled);
- 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 the speed, acceleration and braking data of our COMET electric vehicles);
- 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) which are collected for the safety of all passengers.
Personal Data 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 programs;
- our business partners, such as fleet partners, payment providers and transport partners;
- insurance and financial providers;
- 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; 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 for that Purpose), you agree to redact such sensitive Personal Data before providing such documentation or information to us.
COMET electric vehicles operated by GET have in-vehicle cameras which are installed for safety and security and/or as may be required by government rules and regulations.
The collection, use and disclosure of Personal Data obtained from in-vehicle cameras is used only for ensuring the safety of all passengers and drivers.
Personal Data of minors
In order to submit Personal Data to GET for purposes such as signing up for a GETPASS account, minors must have explicit permission from a parent or legal guardian. The parent or legal guardian hereby consents to the processing of the minor’s Personal Data and accepts and agrees to be bound by this Policy and take responsibility for the actions of the minor.
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 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 Policy.
II. USE OF PERSONAL DATA
GET may use, combine and process your Personal Data for the following purposes set out in the list below. (“Purposes”).
Providing Services and Features
Your Personal Data will be used to provide, personalize, maintain and improve our products and services.
This includes using your Personal Data to:
- process, manage or verify your eligibility for or application for us to provide you with our Services, promotions, rewards and subscriptions with GET;
- engage you to provide you with Services across our various business verticals;
- create, administer and update your account;
- verify your identity and age (where necessary);
- validate your ride and process payments;
- track the progress of your trip and detect abnormal trip variations;
- enable features that personalize your Apps experience (such as to recommend products and services relevant to you, identify your preferences or otherwise personalize your experience with GET);
- 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;
- conduct due diligence checks and risk assessments/analysis;
- perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analyzing usage and activity trends;
- protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
- invite you to participate in our surveys and studies;
- enable communications between our users; and
- fulfill the services to you as a data processor, where you have provided consent to the data controller (i.e., the organization you had purchased goods and services from, and from whom GET is provided 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:
- verifying your identity when you log in to GETPASS;
- 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.
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 analyze 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.
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 GET and GET’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 your;
- 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, chat applications, online messaging service, push notification by hand and by email.
If you wish to unsubscribe to 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, GET may still send you service-related messages (such as information on your transactions, rewards, etc.)
III. DISCLOSURE OF PERSONAL DATA
We need to share Personal Data with various parties for the Purposes. These parties include:
With GET partners at your request
For example, if you requested a service through a GET partner or used a promotion provided by a GET partner, GET may share your Personal Data with that GET partner. Our partners include partners that integrate with our App or our App integrates with, vehicle services partners, or business partners which GET collaborates with to deliver a promotion, competition or other specialized service.
With the shuttle service clients of GET
For example, your employer or your ridership organization may receive trip data when you use GET Points and GET Tokens or its equivalent as part of the provision for exclusive or non-exclusive shuttle services.
With subsidiaries and affiliates
We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.
With GET’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 organizations;
- background check and anti-money laundering service providers;
- cloud storage providers;
- advertising and marketing partners and marketing platform providers;
- data analytics providers;
- research partners, including those performing surveys or research projects in partnership with GET or on GET’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 due 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
V. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Your Personal Data may be transferred from 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 the 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 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 permitted by laws.
VI. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS
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 essential, basic function 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;
- analyze 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.
Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising on third party platforms.
Disabling the collection of cookies on our websites
You have the right to choose to disable, block or deactivate cookies. Please note however that 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”, “Setting” or “Privacy” section of your internet browsers, or you may otherwise consult the help section of your internet browser for more information.
VII. PROTECTION OF PERSONAL DATA
We will take reasonable legal, organizational and technical measures to ensure that your personal data is protected. This includes measures to prevent data from getting lost, or used or accessed in an unauthorized 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 authorized manner and are required to treat your information with strict 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 (where we are processing your Personal Data based on your consent);
- request receipt or transmission to another organization, 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 the Apps 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 identity and/or 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