Last Modified: 17 Dec 2019
This Policy applies to our customers, passengers, agents, vendors, suppliers, partners (such as driver/rider 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, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information.
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:
- fill up a user profile or registration forms
- provide information to assess your eligibility to provide services as a Vroom rider/driver-partner
- interact with our social media pages
- participate in contests or events organised by Vroom
- use biometric features to identity yourself
- fill up demographic information in Vroom’s surveys
When our Services are used
Personal Data may be collected through the normal operation of our Services. Some examples are:
- your location (to detect pick-up locations and abnormal route variations)
- feedback, ratings and compliments
- transaction information (such as payment method and distance travelled)
- information about how you interacted with our Services (such as features used and content viewed)
- device information (such as hardware model and serial number, IP address, file names and versions and advertising identifiers)
- personal data you enter in messages when you use our in-app communication features
From other sources
When we collect Personal Data from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include:
- referral programmes
- our business partners, such as fleet partners, payment providers, ride-hailing partners and transport partners
- insurance and financial providers
- publicly available data
- governmental sources of data
- when our users add you as an emergency contact
- marketing services providers or partners
Personal data about rider/driver-partners
If you are a rider/driver-partner, we may collect:
- telematics data (such as your speed, acceleration, and braking data)
- device data (such as accelerometer data, GPS location, your IMEI number and the names of apps you have installed on your device)
- your vehicle registration data
sensitive personal data
Some of the information that we collect is sensitive in nature. This includes information such as race, and your health or religious beliefs. We only collect this information when this is necessary to comply with legal or regulatory requirements.
Personal data of minors
As a parent or legal guardian, please do not allow minors (i.e. individuals under the age of 18 years) under your care to submit Personal Data to Vroom. In the event that such Personal Data of a minor is disclosed to Vroom, you hereby signify your consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Policy and take responsibility for his or her actions.
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, friends or customers) to us. For example, you may add them as pickup/dropoff contact details. 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, processed and disclosed as set out in this Policy.
use of personal data
Vroom may use, combine and process your Personal Data for the following purposes (“Purposes”).
providing services and features
Your Personal Data will be used to provide, personalise, maintain and improve our Services. This includes using your Personal Data to:
- provide you with Services across our various business verticals
- engage you to provide Services
- create, administer and update your account
- verify your identity
- validate your delivery and process payments
- offer, obtain, provide or facilitate insurance or financing solutions
- track the progress of your trip and detect abnormal trip variations
- enable features that personalise your App, such as lists of your favourite places and previous destinations
- perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends
- protect the security or integrity of the Services and any facilities or equipment used to make the Services available
- process and manage your rewards
- enable communications between our users
- process, manage or verify your application for subscription with Vroom and to provide you with subscribers’ benefits
- enable our partners to manage and allocate fleet resources.
safety and security
We use your Personal Data to ensure the safety and security of our Services and all users. This includes:
- screening rider/driver and delivery partners before enabling their use of our Services
- verifying your identity when you log in to Vroom
- 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 Rider/Driver’s Code of Conduct
- 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 feedbac
- inform you about steps taken to resolve customer support issues
research and development and security
We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our services, develop new features, products and services, and facilitate insurance and finance solutions.
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 Vroom and Vroom’s partners’ sponsors’ and advertisers’ products, services, events or promotions. For example, we may:
- send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings
- notify, invite and manage your participation in our events or activities
We may communicate such marketing to you by post, telephone call, short messaging service, in-car engagement, in-app engagement, online messaging service as well as push notification, by hand and by email.
If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, you may click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings.
The provision of your Personal Data to us is on a voluntary basis. However, if you do not provide your Personal Data or if insufficient Personal Data is supplied to us when requested, this may affect our ability to fulfil the purposes mentioned above and your ability to enjoy the full range of benefits provided by us under the Services.
disclosure of personal data
We need to share Personal Data with various parties for the Purposes. These parties include:
If you are a customer, we may share your pick-up and drop-off locations with riders/drivers.
If you are a driver, we may share your Personal Data with our customers including your name and photo; your vehicle make, model, number plate, location and average rating.
With vroom partners at your request
For example, if you requested a Service through a Vroom partner or used a promotion provided by a Vroom partner, Vroom may share your Personal Data with that Vroom partners. Our partners include partners that integrate with our App or our App integrates with, vehicle services partners, or business partners which Vroom collaborate with to deliver a promotion, competition or other specialised service.
with the owner of vroom accounts that you may use
For example, your employer may receive trip data when you use your employer’s Vroom for Business account.
with subsidiaries and affiliates
We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.
with vroom’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
- background check and anti-money laundering service providers
- cloud storage providers
- marketing partners and marketing platform providers
- data analytics providers
- research partners, including those performing surveys or research projects in partnership with Vroom or on Vroom’s behalf
- fleet and merchant partners
- insurance and financing partners
- 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 relevant third parties.
retention of personal data
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.
If you do not wish for your Personal Data to be collected via Cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.
amendments and updates
Vroom shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to use the Services, purchase products from Vroom or continuing to communicate or engage with Vroom following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.