Privacy policy

Last updated September 27th, 2021

 

1. Introduction

 

1.1 This Privacy Policy applies in respect of EasyVan (SG) Pte. Ltd under the name “Lalamove” (and all our subsidiaries, our parent companies, and subsidiaries of our parent companies (jointly referred to as “we”, “our” and “us”). 

 

1.2 This Privacy Policy explains how we collect, hold, process, transfer and use the personal data provided to us when using or accessing our web applications, mobile applications (jointly referred to as “Applications”) and website. We only collect personal data from minors (i.e. persons who have not attained the age of 18 years) with the prior consent from a relevant person (i.e. a person who has parental responsibility for the minor). In the event that you as the relevant person disclose such personal data of a minor under your parental responsibility to us, you hereby consent to the collection and processing of such minor’s personal data and accept and agree to be bound by this Privacy Policy. If we are informed of any collection of personal data from a minor without the consent of a person with parental responsibility over such minor, we will delete such personal data upon requests.

 

1.3 We operate Applications and website to act as a platform to connect users of our platform to drivers, including individuals using other modes of transportation, and to help facilitate and manage such drivers to provide on-demand delivery services and purchasing services (“Services”). 

 

1.4 This Privacy Policy applies to personal data of (jointly referred as “you” or “your”):

  1. a.Visitors: individuals who visit our website;

  2. b. Users: individuals who: (i) use, request or receive Services; (ii) contact us through our website, Applications or by phone; (iii) enter into our contests or competitions; or (iv) subscribe to our updates or blog; 

  3. Agents: representatives of businesses who: (i) use, request or receive our Services; (ii) contact us through our website, Applications or by phone; (iii) enter into our contests or competitions; or (iv) subscribe to our updates or blog; and

  4. Drivers: individuals who provide or submit applications to us to provide Services through our Applications individually or through partner companies. 

 

1.5 This Privacy Policy applies to Singapore. If you are accessing, operating or using our website, Services or Applications in the following countries or regions, you must also read the relevant rider to this Privacy Policy that applies to you as follows:

 

Country/Region

Rider to Privacy Policy

Brazil

https://www.lalamove.com/pt-br/politica-de-privacidade 

Hong Kong

https://www.lalamove.com/en-hk/privacy-policy

Indonesia

https://www.lalamove.com/en-id/privacy-policy 

Malaysia

https://www.lalamove.com/en-my/privacy-policy 

Mexico

https://www.lalamove.com/es-mx/politica-privacidad 

Philippines

https://www.lalamove.com/en-ph/privacy-policy 

Taiwan

https://www.lalamove.com/en-tw/privacy-policy 

Thailand

https://www.lalamove.com/en-th/privacy-policy 

Vietnam

https://www.lalamove.com/en-vn/privacy-policy 

 

1.6 This Privacy Policy forms an integral part of our Terms and Conditions.

 

1.7 Please read this Privacy Policy and understand it before using our website, Services or Applications. 

 

1.8 By agreeing to this Privacy Policy, you agree and consent to the collection, holding, processing, accuracy, use, transfer and data access and correction of your personal data as set out in this Privacy Policy.

 

 

2. Sources of personal data

 

2.1 When visiting our website, using our Services or registering through our Applications, we will collect personal data that personally identifies you. 

 

2.2 We collect personal data:

 

  1. provided by Visitors visiting our website;

  2. provided by Users, Agents and Drivers such as during account creation through our Applications;

  3. created during use of our Services such as geolocation, transaction information, app or website usage and device data, and communications data; and

  4. via the use of the Lalamove application programming interface, if you choose to utilize it.

 

2.3 We may also collect personal data through software development kits (“SDKs”) used in providing the Services, your entry into our competitions, contests subscribing to our blog or updates, or sending us correspondence through our website, Applications or by phone. 

 

2.4 We may also collect personal data for Drivers who participate in our Driver Referral Program and Driver Campaign (“Drivers’ Programs”) to the extent relevant in processing Drivers’ request to enter or participate in the Drivers’ Programs.

 

 

3. What personal data do we collect about you?

 

3.1 The personal data collected by us will include:

 

  1. from Visitors:
    1. IP address or other unique device identifiers;

  2. from Users:
    1. name*;
    2. email address*;
    3. phone number*; 
    4. address;
    5. correspondence with us;
    6. IP address or other unique device identifiers;
    7. payment and banking information;
    8. geolocation;
    9. User profile information, including login details and passwords, profile picture, saved routes, language preference, beloved drivers’ details, feedback, ratings, compliments, order details, type of service used and referrer and referee information of a referral program participated by the User; 
    10. Applications usage or other relevant data; and
    11. personal data voluntarily entered by the User in free text box when using our Services;

  3. c. from Agents:
    1. name*;
    2. email address*; 
    3. company name*;
    4. job title*;
    5. phone number*; 
    6. business industry*;
    7. company address;
    8. correspondence with us;
    9. IP address or other unique device identifiers;
    10. payment and banking information;
    11. geolocation;
    12. Agent profile information; and
    13. Applications usage or other relevant personal data;

    d. from Drivers:
    1. name*;
    2. phone number*; 
    3. email address; 
    4. home address;
    5. correspondence with us;
    6. IP address or other unique device identifiers;
    7. payment and banking information*;
    8. geolocation*;
    9. Driver profile information, including login details and passwords, profile picture, vehicle picture, language preference, feedback, ratings, compliments and referrer and referee information of a referral program participated by the Driver; 
    10. Applications usage or other relevant data;
    11. driving licence identification number and expiry date*;
    12. information required to collect and pay any fees;
    13. vehicle information and picture*;
    14. vehicle insurance information*;
    15. national identification number and expiry date*; and
    16. date of birth.
  1.  

*mandatory personal data 

 

3.2 If the collection and provision of certain personal data is mandatory, we will indicate as appropriate. If you do not provide us with the mandatory personal data or agree to this Privacy Policy, we will not be able to provide you access to the Applications or provide our Services to you. 

 

3.3 We only collect personal data that we reasonably need for use in connection with the purposes stated in paragraph 4 of this Privacy Policy. We do not collect personal data that is unnecessary or excessive.

 

3.4 In respect of voluntary personal data provided to us, we: 

  1. will only use the personal data provided for the purposes stated in paragraph 4 of this Privacy Policy;

  2. will disregard any personal data provided that is irrelevant for the purposes stated in paragraph 4 of this Privacy Policy; and

  3. will not use the personal data for any other purposes unless you have given your prescribed consent to the use for the relevant other purposes.

 

 

4. How do we use your personal data?

 

4.1 We may collect, compile and collate your personal data in the form of:

 

  1. for Visitors, Users and Agents:
    1. records of profile information;

    2. remarks, records and reports of usage of our Services, including records of interaction with Customer Service;

    3. records of payment in respect of our Services;

    4. records and reports of usage of our Applications, including bug reports, competitions or contests and login sessions;

    5. records of your live chat history and feedback and rating to Drivers;

  1. for Drivers:
    1. records of profile information;

    2. records and reports of usage of our Services, including records of interaction with Customer Service, Driver Operations, field agents and third-party service providers;

    3. iii. records of payment in respect of our Services;

    4. records and reports of usage of our Applications, including bug reports, competitions or contests and login sessions; 

    5. reports of live chat history and feedback from Users and Agents; 

    6. records of your deliveries and performance; and

    7. records of your vehicles, driving permit, vehicle insurance and vehicle license.

 

4.2 We collect your personal data exclusively to carry out our Services and for the purposes of our website and Applications. 

 

4.3 Any of the personal data we collect from you may be used by us:

 

  1. Visitors, Users and Agents:
    1. to provide our Services such as to:

    2. create and update your account registered with us;

    3. enable transportation and deliveries;

    4. track deliveries; and

    5. offer, process or facilitate payment for deliveries or our Services. 

    6. to monitor the use of our website, Services or Applications;

    7. iii. to help maintain the safety, security and integrity of our Services; 

    8. to personalise your experience on our Applications: identifying your preferences and behaviour help us to better respond to your individual needs;

    9. to improve our website, Services and Applications: we continually strive to improve our Services and offerings based on the information and feedback we receive from you;

    10. for customer service: your personal data helps us to more effectively respond to your customer service requests, receive feedback and support needs;

    11. for research and development: your personal data will help us test, research, analyse, assist with product development and machine learning to improve your experience;

    12. to compile aggregate statistics about you and to analyse your Services and Applications usage;

    13. for non-marketing communications related to our Services such as notifications of changes to our Applications or our Services; 

    14. for legal proceedings or as required by regulators, government entities and official enquiries; 

    15. for other directly related matters in respect of our website, Services or Applications; and

    16. for direct marketing (see paragraph 14 of this Privacy Policy).

    b. Drivers:
    1. to provide our Services such as to:

    2. create and update your account registered with us;

    3. enable and notify transportation, orders and deliveries;

    4. track deliveries; and

    5. offer, process or facilitate payment for deliveries or our Services. 

    6. to monitor the use of our Services, Applications and website;

    7. to help maintain the safety, security and integrity of our Services and users such as to screen Drivers;

    8. to personalise your experience on our Applications: identifying your preferences and behaviour help us to better respond to your individual needs;

    9. to improve our website, Services and Applications: we continually strive to improve our Services and offerings based on the information and feedback we receive from you;

    10. for customer service: your personal data helps us to more effectively respond to your customer service requests, receive feedback and support needs;

    11. for research and development: your personal data will help us test, research, analyse, assist with product development and machine learning to improve your experience;

    12. to compile aggregate statistics about you and to analyse your Services and Applications usage and deliveries, including performance metrics of services provided by the Driver;

    13. for non-marketing communications related to our Services such as notifications of changes to our Applications or our Services; 

    14. for legal proceedings or as required by regulators, government entities and official enquiries; 

    15. for other directly related matters in respect of our Services, Applications or website; 

    16. for direct marketing (see paragraph 14 of this Privacy Policy); and

    17. for providing benefits to the Drivers, including the purchase of insurance.

4.4 Personal data collected by us may not be used for other purposes, unless:

 

  1. have expressly given your prescribed consent to the use for the relevant other purposes; 

  2. the purpose is directly related to the purpose for which the personal data was collected; or

  3. we are permitted to use the personal data for other purposes arising from an exemption or otherwise in accordance with applicable law and regulation.

 

4.5 Your personal data collected by us will not be sold, exchanged, shared, transferred or given to a third party for their direct marketing without your prior consent. 

 

 

5. Personal data sharing and disclosure

 

5.1 Our Services require that we share your personal data with other users. This includes:

    1. sharing Users’ or Agents’ full name, phone number, personal data contained in free text box voluntarily entered by a User, and pick up or drop off locations with Drivers after a delivery has been initiated for the purposes of completing a delivery; and

    2. sharing the Driver’s name, phone number, driver profile information, vehicle information, vehicle picture and geolocation with Users or Agents after a delivery has been initiated for the purposes of completing a delivery;

 

5.2 We may also share your personal data to provide our website, Services, Applications or for legal reasons with:

 

  1. our employees, officers or independent consultants;

  2. our auditors and external legal and financial advisors;

  3. our suppliers, business partners, data processors and sub-contractors including:
    1. IT service and software suppliers;

    2. payment processors and facilitators;

    3. cloud platform service providers;

    4. cloud storage providers;

    5. data analytics providers;

    6. research partners;

    7. marketing and advertising agencies who create our advertisements and promotions;

    8. background check and identity verification providers; 

    9. vendors that assist us to enhance the safety and security of our website and Applications; and

    10. customer service providers;


    d. our insurers and bankers;
  1.  
  2. e. any regulator or government body to whom we are under an obligation or otherwise required to make disclosure under the requirements of any applicable law or regulation;
  3.  
  4. f. subsidiaries and parent companies: we share personal data with our subsidiaries and parent companies to help us provide our Services or conduct data processing on our behalf;
  5.  
  6. g. all applicable persons if we believe it is required by applicable law, regulation, legal process, governmental request or where the disclosure is appropriate due to safety concerns. This includes exchanging your personal data with other companies or organisations for the purposes of fraud protection and prevention; or
  7.  
  8. h. another company with connection in or during negotiations of any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into that other company.
  9.  

5.3 We will ensure third parties are under confidentiality obligations before we share your personal data with the third parties set out in paragraph 5.2 of this Privacy Policy. Some persons to whom we transfer your personal data may be located outside Singapore, in locations that may not have in place data protection laws which are substantially similar to Singapore, and this may mean your personal data may not be protected to the same or similar level as that in Singapore.   

 

5.4 We may share your personal data with anyone other than as described in paragraph 5.2 of this Privacy Policy if we notify you and receive your consent beforehand.

 

 

6. Security of personal data

 

6.1 Once we receive your personal data, we will use all reasonably practicable steps to ensure that your personal data is stored securely and protected by us and our data processors against unauthorised or accidental access, processing, erasure, loss or use. 

 

6.2 Your personal data will be kept confidential and secure except for the purposes and uses as set out in this Privacy Policy and will only be disclosed on a “need-to-know” basis.

 

6.3 If we outsource and entrust your personal data with data processors, we will use contractual and other means to monitor the data processors’ compliance with this Privacy Policy. 

 

6.4 Our security measures may include SSL certificate signing, TLS encryption and hashed password storage. 

 

6.5 You are responsible for keeping your Applications password confidential. We advise you that you must not share your Applications password with anyone.

 

6.6 The transmission of information through the internet is not completely secure. Although we use security measures to secure your personal data, we cannot guarantee the security of your personal data transmitted to the Applications and any transmission is at your own risk. 

 

 

7. Retention of personal data

 

7.1 We will keep your personal data for as long as your account registered with our Applications is being accessed.  

 

7.2 If your account registered with our Applications has not been accessed over a period of [three years] or we have closed your account upon your request (“End Date”), your personal data will be retained by us for seven years after the End Date. We may retain your personal data for a longer period if it is necessary for us to do so to comply with our contractual or legal obligations, or you have consented to our continued retention of it.  

 

7.3 At the end of the retention period, we will ensure that your personal data, all app-related data and account-related information will be deleted. For any physical documents containing your personal data, the documents will be shredded or otherwise destroyed by means that ensure the confidential and secure destruction of the documents.

 

7.4 We will ensure that our data processors only retain your personal data only for as long as is necessary for the fulfillment of the purposes stated in paragraph 4 of this Privacy Policy. Our data processors will delete personal data held if personal data is no longer required for the purposes stated in paragraph 4 of this Privacy Policy unless any deletion is prohibited under law or it is in the public interest for the personal data to not be deleted.

 

 

8. Personal data access requests

 

8.1 You are entitled to request a copy of your personal data held by us, unless we are exempted from complying with a data access request. 

 

8.2 We will establish tracking procedures to monitor the progress of compliance with data access requests.

 

8.3 Unless exempted from doing so, we will provide a copy of the requested data within 40 days after receiving a data access request.  If we are unable to provide the copy of the requested data within 40 days, then we will:

 

  1. notify you before the expiry of the 40 day period; and 

 

  1. provide the copy of the requested data as soon as practicable thereafter. 

 

8.4 We may charge a fee for the direct and necessary costs we have incurred in complying with the data access request.  This may include a time spent charge for compliance (though the persons used will be appropriate for the corresponding task).  Photocopying may be charged at HK$1.00 per page.  We will specify the fees to you as soon as practicable.

 

8.5 We will provide the relevant personal data in a form that is intelligible to you.

 

8.6 In responding to your data access request, we will not disclose any personal data identifying any other individual unless that other individual consents or we can redact the document by omitting the names or other identifying particulars so that we do not disclose the identities of others.

 

8.7 We must refuse to comply with a data access request if: 

 

  1. we are not supplied with information to be satisfied as to the identity of the person making the request or his authority;

 

  1. we cannot comply with the request without disclosing the personal data of a third party, or

 

  1. where compliance with the request is for the time being prohibited by applicable law.

 

8.8 We must refuse to comply with a data access request if:

 

  1. the request is not in writing in Chinese or English;

 

  1. we are not supplied with information to enable us to locate the requested personal data; 

 

  1. the request is not made in the form prescribed by law, which can be obtained here: https://www.pdpc.gov.sg/-/media/Files/PDPC/PDF-Files/Advisory-Guidelines/Advisory-Guidelines-on-Enforcement-of-DP-Provisions-1-Feb-2021.pdf?la=en .

 

  1. the request follows two or more similar requests, and it is unreasonable for us to comply with the request in the circumstances;

 

  1. another party controls the use of the requested data in a way that prohibits us from complying with the request (in which case we must inform the applicant of the name and address of the other party); and

 

  1. we are permitted by law to refuse the request, or may rely on an exemption from doing so.

 

8.9 If we refuse to comply with a data access request, we will give you written notice and provide reasons for refusal within 40 days from receiving the request.

 

8.10 We will keep a record of the particulars of the reasons for refusal of a data access request for at least four years from the date of refusal.

 

 

9. Personal data correction requests

 

9.1 You may request for us to make necessary corrections in respect of any personal data that you consider inaccurate, after we have fulfilled a data access request from you.

 

9.2 We will correct any inaccurate personal data notified in a data correction request without charge and within 40 days of receiving the request.

 

9.3 We may refuse to correct the personal data if we believe the personal data is accurate or an expression of opinion, or the proposed correction is inaccurate.  Then, we will inform you in writing of the refusal and the reasons for it.

 

9.4 We will keep a record of the particulars of the reasons for refusal of a data correction request for at least four years from the date of refusal.

 

 

10. Cookies

 

Please refer to our Cookie Policy which can be obtained here .

 

 

11. Third party links

 

11.1 Occasionally, at our discretion, we may include or offer links to third party products or services on our website or Applications. 

 

11.2 These third party websites have separate and independent privacy policies and you must refer to these third party privacy policies. 

 

11.3 We take no responsibility or liability for the content and activities of these third party linked websites or their products and services. 

 

11.4 We seek to protect the integrity of our website and Applications, and welcome any feedback on these third party links.

 

 

12. Changes to our Privacy Policy

 

12.1 We may occasionally change all or part of this Privacy Policy. 

 

12.2 Any changes will be effective immediately upon our posting of the updated Privacy Policy. 

 

12.3 If we make any changes to this Privacy Policy, we will notify you of the changes through our website, Applications or through other means such as e-mail. 

 

12.4 If we make changes to the type of personal data collected, the purposes for collecting your personal data, who we may share your personal data with or how we may use your personal data, we will notify you in advance of such changes through our Applications, website or through other means such as e-mail and request your consent.

 

12.5 If you wish to revoke your agreement to this Privacy Policy, please notify us through the contact details set out below. If your agreement is revoked or you do not consent to changes made to the Privacy Policy, we will not be able to provide you access to our Applications or provide our Services to you.

 

 

13. Contact

 

All comments, queries, data access requests or data correction requests relating to our use of your personal data are welcome and should be addressed to: https://www.lalamove.com/en-sg/data-protection-officer .

 

 

14. Direct Marketing

 

14.1 If we provide our Services or interact with you in the course of engagement with a company or business entity, we intend to directly market our website, Services or Applications to you in that capacity and for the use of that company or business entity.

 

14.2 a. If we provide our Services or interact with you in your personal capacity, we intend to use your personal data to directly market our website, Services or Applications to you.

b. The type of personal data we use for direct marketing purposes are:

 

□ your name

 

□ your email address

 

□ your phone number

 

□ your home address

 

c. The direct marketing activities we conduct using your personal data are:

 

□ newsletters and our blog updates 

 

□ promotions of our website, Services or Applications

 

□ competitions or contests held by us

 

□ updates in respect our website, Services or Applications

 

□ surveys in respect of our website, Services or Applications

 

□ event invitations

 

□ festive greetings

 

□ advertisements of our website, Services or Applications

 

□ loyalty program with gifts

 

  1. We will not use the types of personal data for the direct marketing activities described in this paragraph 14.2 of this Privacy Policy unless we have received your consent.

 

  1. You may request us to cease using your personal data for direct marketing purposes at any time by replying with the heading “unsubscribe” to any direct marketing communication from us.

 

 

15. Language Versions

 

In case of any discrepancy between the English version and any regional language version, the English version prevails.