At Envy Motors we recognize that privacy is important. This Privacy Policy (“Privacy Policy”) explains to you how Envy Motors Pte Ltd (“Envy Motors,” “us” or “we”) manages your personal data. Please read through this Privacy Policy carefully so that you know and understand the purposes for which we collect, use and disclose your personal data.

By using the Applications (defined as any and all mobile software applications developed by Envy Motors, including all updates, releases and versions thereof), the website(s) owned or operated by Envy Motors and through which the Applications may be downloaded or accessed, including the website at www.envy motors.com.sg) (“Site”), and any of the features, content, services and applications offered by us to you through the Site and/or Applications or otherwise (“Envy Motors Services”) you consent to us collecting, using, disclosing and processing your data in accordance with this Privacy Policy. If you do not agree to any of the terms in this Privacy Policy, you must not use or access the Applications, Site or Envy Motors Services.

In this Privacy Policy, “include” (and its derivatives, such as “including” and “includes”) means to include without limitation, and every occurrence of this term shall be construed as defined aforesaid, whether or not capitalised.
We reserve the right, at our sole discretion, to change, modify or otherwise alter this Privacy Policy at any time. Should you have any questions regarding this Privacy Policy, please contact us at the contact information listed at the end of this Privacy Policy.

This Privacy Policy covers our collection, use and disclosure of your information through the Applications, the Envy Motors Services and the Site. It does not cover any collection, use or disclosure by third parties of your information or personal data through any applications, websites, software, products or services that we do not control or own, such as Facebook, or any third party features or services made available via an Application, the Envy Motors Services or the Site.

1. WHAT KIND OF INFORMATION WE COLLECT

We collect the following types of information below through your use of the Applications, the Envy Motors Services and/or the Site.
Personal Information. “Personal Information” is information that identifies you or another person, and includes your name, phone number, email address, IC number and vehicle license number. Personal Information may be transmitted or received when you access, use or register for an account on an Application, the Envy Motors Services and/or the Site.

We collect Personal Information if you provide it directly to us via website, email or through the Applications, the Envy Motors Services or the Site. We may also collect Personal Information when you send us messages, comments, questions or suggestions or if you participate in blogs, forums, message boards, chat rooms, profile pages and other communication channels and services within which you are able to post information, if any, through the Application, Envy Motors Services and/or on the Site. We may also collect Personal Information through certain features of one or more Applications or the Envy Motors Services.

Non-Personal Information. “Non-Personal Information” is information that does not identify you or any other individual, and includes Session and Usage Data, Log Data and Aggregate Information, each as described below.
Session and Usage Data. “Session and Usage Data” is information about your use of an Application, the Envy Motors Services and/or the Site and includes, without limitation, connection and service-related data submitted to us through your use of an Application, the Envy Motors Services or the Site. Session and Usage Data includes information relating to the connection request, server communication and data sharing, including network measurements, quality of service, and date, time and location of usage. We also may aggregate Session and Usage data as described in Aggregate Information below. Please note that Session and Usage Data does not include any Personal Information.

Log Data. When you interact with us or use an Application, the Envy Motors Services or our Site, our systems may automatically collect your unique User Device number, the IP address, type of browser or operating system you use, and the dates and times of your use (“Log Data”).

Aggregate Information. “Aggregate Information” is data we collect about a group or category of services or users from which individual user identities have been removed. In other words, information on how you use the Applications, the Envy Motors Services and the Site may be collected and combined with information about how others use the Applications, the Envy Motors Services and the Site, but no personally identifiable information will be included in the resulting Aggregate Information. Aggregate Information helps us understand trends in our users’ needs so that we can better consider new features or otherwise refine or tailor the Applications, the Envy Motors Services and the Site to our users’ needs.

2. HOW WE USE YOUR INFORMATION

Personal Information. You agree that we can use Personal Information for the following purposes:
providing you with the use of the Applications, the Site and the Envy Motors Services;

to respond to your inquiries, fulfil your requests, provide services, or complete transactions you have requested and generally for administering and/or managing our relationship with you;

to send you information regarding an Application, the Envy Motors Services and the Site, including keeping you informed of new features, updates or releases,

sending you information on any updates or changes to our terms and conditions, guidelines, policies and/or other administrative information.

to resolve problems with an Application, the Envy Motors Services or the Site.

to create an individual profile and provide personalized services, or to customize your user experience of an Application, the Envy Motors Services and the Site;

sending you updates and publications, where you have requested or consented to be on our mailing list;
to create and inform you of new products and services from us;

to suggest that you use or take advantage of certain features within Applications, Site or Envy Motors Services;
to perform internal audit or comply with other internal financial, accounting or other policies; to better determine your location in order to provide location or map based services within the Applications;

any purposes which we notify you of at the time your personal data is collected from you or disclosed to us; and
as we believe to be necessary or appropriate:

in any manner permitted under applicable law, including laws outside your country of residence;
to comply with legal process;

to respond to requests from public and government authorities, including public and government authorities outside your country of residence;

to enforce our terms and conditions;

to protect our operations or those of any of our affiliates;

to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and

to allow us to pursue available remedies or limit the damages that we may sustain.

Non-Personal Information. We may use Non-Personal Information for any purpose, including for:
our own internal purposes;

to measure traffic patterns;

to understand demographics, customer interest, and other trends among our Users;

to provide, improve and modify the Applications, Envy Motors Services and the Site; and
for promotion and marketing purposes.

In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your unique User Device number). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it contains personal identifiable information.

We may display targeted advertisements based on Personal Information. Advertisers (including ad serving companies) may assume that people who interact with, view, or click targeted ads meet certain targeting criteria, such as drivers between 18-24 years of age from a particular geographic area. We do not provide any Personal Information to the advertiser when you interact with or view a targeted ad. However, by interacting with or viewing an ad you are consenting to the possibility that the advertiser will assume that you meet the targeting criteria used to display the ad.

3. HOW YOUR INFORMATION MAY BE DISCLOSED

• Personal Information. In general, we use Session and Usage Data internally to serve our users and enable them to take maximum advantage of the Applications, the Envy Motors Services and the Site. We also store Personal Information to improve the functionality of the Applications, the Envy Motors Services and the Site. All Personal Information collected is stored in our database and may be archived elsewhere.
We may disclose your Personal Information:

• to our affiliates, agents, service partners and third party providers, to facilitate or enable our provision of services to you and the development, support, maintenance and operation of the Applications, the Envy Motors Services or the Site;

• to our third party service providers who provide services such as website hosting, maintenance, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other similar services, or to which we may outsource one or more aspects of our business, but only to the extent necessary for them to carry out their services for us;

• to identify you to anyone to whom you send messages through an Application, the Envy Motors Services or the Site;
• to identify you to other users of an Application to suggest you or they take advantage of certain features within Applications or the Envy Motors Services;

• to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);

• to potential partners, investors and other parties with a view to a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business; and

• as we believe to be necessary or appropriate:
in any manner permitted under applicable law, including laws outside your country of residence;
to comply with legal process, whether originating in the Republic of Singapore or other territory;
to respond to requests from public and government authorities, including public and government authorities outside your country of residence;

to enforce our terms and conditions;

to protect our operations or those of any of our affiliates;

to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others;

to allow us to pursue available remedies or limit the damages that we may sustain; and
if we reasonably believe that an emergency exists involving immediate danger of death or serious physical injury to any person that requires immediate disclosure of communications or your Personal Information.

No Disclosure to Third Parties for Marketing Purposes Without Your Consent. We do not disclose your Personal Information to third parties for the third parties’ direct marketing purposes, unless you first affirmatively agree to such disclosure.

Non-Personal Information. We may disclose Non-Personal Information for any purpose.

In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your unique User Device number). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it contains personal identifiable information.
4. THIRD-PARTY SITES
In general, the Applications, the Envy Motors Services and the Site access third party information (such as your Facebook account information) through application interfaces. We may provide links to third-party websites, such as Facebook or other applications, as a service to our users.
The Site may also carry advertisements from other companies. When you click on links of third parties in an Application, the Envy Motors Services or the Site, you may leave the Application, the Envy Motors Services or the Site. Some of these third party sites may be co-branded with our name/logo or our affiliated entity’s name/logo, even though they are not operated or maintained by us. This Privacy Policy does not address, and we are not responsible for, the privacy practices of websites operated by third parties, whether they are linked to or otherwise accessible from an Application, the Envy Motors Services or the Site. The inclusion of a link or accessibility of third party webites does not imply endorsement of such third party website by us.
5. CHOICES ABOUT YOUR PERSONAL INFORMATION
Opting Out of Marketing-Related Communications. You may opt out from receiving marketing-related emails, texts, phone messages or other communications from us on a going-forward basis by contacting us at info@envymotors.com.sg.
We will try to comply with your opt-out request as soon as reasonably practicable. Please note that if you opt out as described above, this will apply to marketing-related communications from us only. We will not be able to remove your Personal Information from the database of any other users with whom you have shared such information or from the databases of third parties which you previously authorized us to share such information with (i.e., to which we have already provided your Personal Information prior to your opt-out request). Please also note that if you do opt out of receiving marketing-related communications from us, we may still send you important administrative messages, and that you cannot opt out of receiving administrative messages.
Accessing, Changing or Suppressing Your Personal Information. If you would like to review, correct, update, suppress, delete or otherwise limit our use of your Personal Information that has been previously provided to us, you may email us at info@envymotors.com.sg with your request. In your request, please make clear what information you would like to have changed, or otherwise let us know what limitations you would like to put on our use of your Personal Information. We will try to comply with your request as soon as and to the extent reasonably practicable. As mentioned above, We will not be able to remove your Personal Information from the database of any other users with whom you have shared such information or from the databases of third parties which you previously authorized us to share such information with.
6. COOKIES
When you visit the Site, we may send one or more “cookies” to your computer hard drive through your Web browser. A cookie is a small file containing a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Any use of cookies by us will be solely for the purposes of improving the quality of access to and use of the Application, the Envy Motors Services or the Site. Purposes for which cookies will be used include:
storing user preferences and tracking user trends (such as how people use the Site, and their Site access preferences);
obtaining information on how and when pages in our Site are visited and by how many people; and
enabling you to enter your login information less frequently.
7. SECURITY
We use commercially reasonable physical, administrative, technical and electronic measures and safeguards to protect your information from unauthorized access. Please be aware that no security measures that we take to protect your information is absolutely guaranteed to avoid unauthorized access or use of your Personal Information or is impenetrable. We hereby disclaim all liability for, the security of your Personal Information, which may be compromised by unauthorised entry, use or disclosure, hardware or software failure, and other factors.
8. RETENTION PERIOD
We will retain your Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law. Your Personal Information may or may not be encrypted while stored or archived by us.
9. INTERNATIONAL USERS
We use third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to provide you with our services and enable you to use the Application, the Envy Motors Services or the Site. These third parties are located outside our offices and may also be located outside your country of residence. By submitting your Personal Information to us, you agree to our disclosure of your Personal Information to such third parties and their use of the same.
Your Personal Information may be stored and processed in any country where we have facilities, and by using an Application, the Envy Motors Services or the Site you consent to the transfer of your Personal Information to countries which may be outside of your country of residence and may provide for different and less stringent data protection rules than in your country. If you object to your Personal Information being transferred or used as described in this Privacy Policy, please do not use any Application, the Envy Motors Services or the Site and immediately delete all Applications from your mobile devices.
10. SENSITIVE INFORMATION
We ask that you do not send us, or disclose to us, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background or membership in past organizations, including trade union memberships) on or through an Application, the Envy Motors Services, the Site or otherwise.
11. CHANGES TO THE PRIVACY POLICY
We may modify this Privacy Policy at any time in the exercise of our sole discretion, and you agree to be bound by all such modifications or revisions. If you are a registered user of an Application, we may notify you of changes to this Privacy Policy by:
displaying the new terms on-screen when you next start or launch the Application and requiring you to read and accept them to continue your use of the Application;
email, via an online service or otherwise; or
any combination of the foregoing.
Notwithstanding the foregoing, and if you are not a current registered user of an Application, you agree to periodically review and keep yourself informed of the most up-to-date version of this Privacy Policy.
If you do not agree to any modification or revision to the Privacy Policy, you are to stop using the Applications, Envy Motors Services and Site immediately.
12. LEGAL AGE
The Applications, Envy Motors Services and Site are not intended for use by persons under 18 years of age. If you are under 18, you may use the Site only with the involvement and consent of a parent or guardian. We do not knowingly or intentionally collect or solicit personal data from anyone under the age of 13. If you are under 13, please do not attempt to register for the Applications, to use the Site, or use any of our services or products, or send us any personal data about yourself. If we learn that we have collected personal data from a child under age 13, we will permanently delete that information as quickly as reasonably possible. If you believe that a child under 13 may have provided us personal data, please contact us in writing at the email below.
13. CONTACTING US / REPORTING VIOLATIONS
Please contact us by email in writing at info@envymotors.com.sg if have any questions or feedback relating to your Personal Information or this Privacy Policy, or if you wish to report any violations or abuse of the Applications, Envy Motors Services or Site.
This Privacy Policy shall be governed by and construed in accordance with Singapore law.
Last updated: 09 September 2019