Zen Innovate  Pte. Ltd, its respective subsidiaries, affiliates, associated companies, and jointly controlled entities (collectively “we”, “us”, “our”) recognize its responsibilities in relation to the protection of the Personal Data under the Personal Data Protection Act (“PDPA”). 

This Privacy Policy (“Policy”), applies to all users of the ParrotSg Application (“App”) and /or our Websites. It describes how we, collect, store, use, transfer, process, share, disclose, retain and protect your Personal Data under the Personal Data Protection Act (“PDPA”).

The Policy applies to the protection of the Personal Data collected, used, disclosed, processed, transferred, shared, retained, or stored by us.

By browsing our website, downloading our App, interacting with us, submitting information to us, or signing up for any products and services offered by us, you agree and consent to us, as well as our respective representatives, authorised service providers, and/or agents, to collect, store, use, transfer, process, share, disclose, retain and protect your Personal Data.

Personal Data:

Personal Data is defined as information about an individual, whether true or not, who can be identified from that data; or from that data and other information to which the Company has or is likely to have access directly or indirectly, means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, including data in our records as may be updated from time to time.

Examples of Personal Data could include but are not limited to your name, NRIC, FIN, passport or other identification number(s), identification detail(s), driving experience, telephone number(s), mailing address, email address, and any other personal information provided by you or possessed by us.

We collect your Personal Data mentioned when you:

• complete user profile or registration forms (such as your full name, contact information, driving record, vehicle registration number, and other identification information where needed or when you complete a user profile by retrieving data from Singpass);
• interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
• verify your identity through various means (such as independently verified payment card information, license information, vehicle information, background check results (as legally permissible)or images of yourself);
• participate in contests, competitions, or events organised by us (where you submit pictures, audio files, and/or videos, which may include images of yourself);
• fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation);
• make an enquiry via e-mail, telephone, mobile phone, or text message or “contact” on our website or “Support” on our App;
• disclose your Personal Data to any of our partners, affiliates, subsidiaries, associated companies, and jointly controlled entities that may have jointly organised competitions or any services with us.

When we collect Personal Data, including but not limited to your name, contact information, and other identification information where needed from other sources, such sources may include:

• referral programs, surveys;
• our business partners such as fleet partners, payment providers;
• insurance providers;
• publicly available sources of data;
• governmental sources;
• when you are emergency contact of our user; 
• marketing services providers.

Additionally we also collect the following data:

• telematics data (speed, acceleration, braking data);
• device, sensors, location data (such as accelerometer data, GPS location, your IMEI number and the names of apps you have installed on your device, hardware model and serial number, IP address, file names, versions, and advertising identifiers or any information that may provide an indication of device or app modification, biometric identifiers and/ or data); whenever you use the Application through your mobile device, we will track and collect your geo-location information in real-time;
• transaction information when a payment is made through the Application (such as payment method, type of card, the name on the card, the number of that card, and the amount of money paid);
• your vehicle details and Personal Data that may be captured through your interaction with us, our agents;
• in-vehicle Recording Devices. We do not mandate the installation or use of in-vehicle recording devices (“IVRDs”) in any Vehicles.

Minors Data:

We do not collect any personal information of any minor deliberately. We are however not able to distinguish the age of persons accessing our Website. As a parent or legal guardian, please do not allow minors to submit Personal Data to us. In the event that such Personal Data of a minor is disclosed to us, you hereby 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.

We may collect, use, retain, disclose, transfer, process, and/or store your Personal Data for:

• verifying your identity.
• reviewing, considering, assessing, and processing your application for insurance.
• underwriting and pricing your application and any policy changes or renewals.
• requesting and collecting premiums or payments.
• administering and/or managing your relationship, account, and/or policy;
• providing you with periodic review on your insurance portfolio;
• carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that may have been put in place by the Company;
• conducting market and actuarial research and analysis to help us improve the products or services offered by us or to develop new products or services;
• monitoring, detecting and prevention of fraud, unlawful, undesirable sales practices, or improper activities;
• investigating fraud, misconduct, any unlawful action or omission, whether relating to your application, your claims or any other matter relating to your policy, and whether or not there is any suspicion of the aforementioned; sending you marketing, advertising, and promotional information;
• managing and preparing reports on incidents and accidents;
• resolving complaints, and handling requests and queries;
• sending you information by what’s app, SMS/Text, Email, Call, and/or Postal Mail on your rewards program and special offers in relation to products and/or services offered by us and our partners;
• processing and managing your rewards and discounts earned and/or verifying your eligibility for promotions and to make the experience more seamless.
• providing marketing services products, and benefits to you, including promotions, loyalty and reward programs via various platforms or outreach initiatives;
• contacting you via Call, whats app,SMS/Text, Email, and/or Postal Mail of purposes in relation to particular products or services that you have indicated your interest in or in your interactions with us;
• matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision, or offering of products, services, marketing, or promotions, whether by us or other third parties;
• reaching out to you on customer relationship management;
• managing and notifying about competitions, events, and other activities;
• evaluating, processing, facilitating or administering your request for referral services;
• storing, hosting, backing up (whether for disaster recovery or otherwise via cloud services);
• tracking  the progress of your trip and detecting abnormal trip variations;
• performing 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;
• making your experience more seamless, such as automatically filling in your registration information (such as your name or phone number);
• fulfilling any purposes relating to the applications and/or registrations you have submitted for any of our products and/or services;
• provide you with ongoing services and respond to your inquiries or instructions;
• maintaining the safety, security and integrity of our products and services;
• using device, location, profile, usage, and other Personal Data to identify unsafe driving behaviour such as speeding, harsh braking and acceleration, and providing personalised feedback to driver;
• sharing drivers location and details when the emergency button or the “Share” feature is activated;
• accounting, auditing, legal, regulatory and compliance purposes;
• attending to regulatory enquiries;
• assisting in regulatory investigations or law enforcement;
• legal purposes to legal advisors, law enforcement officials, government authorities,foreign legal authorities and other third parties to fulfill the legal obligations;
• responding 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).

We may also :

• share your Personal Data with an employer under initiatives undertaken by the employer like employer training programs or as a part of team building activities or such similar initiatives undertaken by the employer or if he is a fleet owner and needs to monitor his fleet movement;
• share your Personal Data with our subsidiaries, associated companies, jointly controlled entities, affiliates, solutions partners, vendors, or vehicle suppliersfor providing seamless services;
• use your Personal Data in connection with Initial public offering, mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by or of another company (even if the transaction is eventually not proceeded with);
• under some circumstances we anonymize your Personal Data so that it no longer identifies you, in which case we are entitled to retain and use such anonymized data without restriction, including for data analytics purposes;
• collect your geo-location information when the Application is running in the foreground (i.e., the Application is open and on-screen) and in the background (i.e., the Application is open but not on screen), so long as you are signed into the Application. You can always choose to disable the geo-location tracking information on your mobile device temporarily. However, this may affect the functionalities available on the Application. 
• collect your Personal Data to facilitate or enable any checks as we may in our discretion consider necessary before or after we register you as a User, including any know-your-customer (“KYC”) processes;
• engage with our agents, vendors, suppliers, contractors, partners, and any others who provide services to us, perform functions on our behalf, for or in connection with the purposes for which such third parties are engaged, and to perform certain disclosure to the relevant third parties which are technically required to process your transaction, which may include allowing such third parties to introduce or offer products or services to you, or other conducting activities including marketing, research, analysis, checks (including background and verification checks), and product development.

Other relationships:

If you are applying to us to fill any job vacancy as our  staff, consultant, agent, representative of us, we will collect, store, use, transfer, process, share, disclose, and retain your Personal Data for the purposes of administering, processing and managing your application, which include  but not limited to the following:

• Conducting pre-recruitment due diligence checks such as verifying your credit standing, qualifications and obtaining reference check from your ex-employers;
• Conduct background screening/ verifications;
• Facilitating and conducting interviews;
• Assessing your job suitability;
• Any other purposes relating to the aforesaid.

Consent :

By completing the user profile, registering with us, interacting with us, submitting information to us, participating in competitions or signing up for any products and services offered by us, you agree and consent to us, as well as to our respective representatives, agents, vendors, suppliers, contractors, partners, and any others who provide services to us, to collect, store, use, transfer, process, share, disclose, and retain your Personal Data, in the manner set forth in this Policy.

You may give your consent expressly or implied. You are deemed to provide your consent, to collect, store, use, transfer, process, share, disclose, and retain your Personal Data if you voluntarily provide your Personal Data to us, albeit without actually expressly providing your consent.

In circumstances where you provide us with information relating to third parties (which may include Personal Information relating to your spouse, family members, or friends), you represent and warrant that you have obtained such third party's consent for, and hereby consent on behalf of such third party to, collect, store, use, transfer, process, share, disclose, and retain such information by us.

Amendments :

We reserve the right to modify, update or amend the terms of this policy at any time. The updated version will be posted on the website http://www.joinparrot.com. It is your responsibility to review the Policy regularly. Your use of the Apps, Websites, or Services, purchase of products from us or continuing to communicate or engage with us following the modifications, updates or amendments to this policy, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.

Unless you withdraw your consent by any of the actions stated below your consent remains valid.

 Consent Withdrawal :

• By giving reasonable notice in writing, you may withdraw your consent given or deemed to be given in respect to collect, store, use, transfer, process, share, disclose, and retain your Personal Data by us.
• You may submit the withdrawal of consent by submitting your request in writing to our Data Protection Officer: dpo@zensung.com
• Depending on the nature and extent of your withdrawal of consent in relation to your Personal Data, we might have to discontinue your relationship with us. Our legal rights and remedies are expressly reserved in such an event.
• We will process your request within a reasonable time from such a request for withdrawal of consent being made in writing, and will thereafter cease to collect, use and/or disclose the Personal Data for the purposes as stated in your request or anonymize such data, unless such collection, use or disclosure, as the case may be, without the consent of the individual is required or authorized under the PDPA or other written law.

Data Accuracy and Security :

You need to provide your complete, accurate, true, and correct Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. You should ensure the completeness and factual accuracy of your Personal Data provided to us.

Failure to provide such Personal Data, may constitute a failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.

We will take reasonable steps to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example, no harmful code will enter our websites, applications, and digital services (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites, applications, and digital services.

While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, when you browse our Websites, or use our applications and/or digital services, and the method of electronic storage. We urge you to take every precaution to protect your Personal Data when you are on the Internet, when you browse our websites, or use our applications and/or digital services. We recommend that you change your passwords often, use a combination of letters, numbers and symbols, and ensure that you use a secure browser.

Use of Cookies:

This policy describes how we and our affiliates use cookies and tracking technologies on our websites and applications. We may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (“Cookies”) in connection with your use of the Websites and Apps. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Apple’s IDFA). 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 transmit Personal Data about you and your use of the service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

We may share identifiable Personal Data with third parties, such as but not limited to 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. Use of any information by such third parties is subject to their own privacy and/or cookie policies. Please note that we do not endorse any cookie, web tag/ pixel placed or created by such third parties and we are not responsible for the access or use of your information by such third parties.

You can disable cookies by changing the setting within your browser or phone. However, some parts of website or the app may not function properly or might not be accessible.

Correction and Retention:

For a request to correct your Personal Data, make a request in writing to dpo@zensung.com. we will correct your Personal Data as soon as practicable after the request has been made.

Please note that we may charge you a reasonable fee to offset the administrative costs of processing your request.

We will retain your Personal Data only for as long as it is needed for the purposes and for which it was collected and as required for business or legal purposes or we have a legitimate interest in the further storage, in particular for reasons of troubleshooting. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or legitimate purpose for retaining your Personal Data we take steps to erase, destroy, anonymise your data and prevent access or use of such Personal Data for any purpose other than compliance with this policy or for purposes of safety, security, fraud prevention, and detection, in accordance with the requirements of applicable laws. We may also for quality control, training and compliance monitoring purposes, record all our inbound and outbound calls.

Your Personal Data may be transferred, stored, and processed in a jurisdiction other than your country (“Home Country”), in which you are present while using our services to companies under our group which are located outside of your Home Country and/or where our group’s servers and/or service providers and partners are located outside of your Home Country. You understand and consent to the transfer of your Personal Data out of your Home Country as described herein.

Anonymised Data:

We may use, license, disclose, Personal Data, provided, however, (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) that has been combined with similar data such that the original data forms a part of a larger data set.

Contacting us:

If you have any questions regarding this Policy or you would like to make corrections to your Personal Data, please contact our Data Protection Officer at dpo@zensung.com.