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 LimoLight driver-partner;
• interact with our social media pages;
• participate in contests or events organized by us;
• use biometric features to identity yourself; and
• Fill up demographic information in surveys.

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 (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 Apps, Website or 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); and
• 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; and
• marketing services providers or partners.

Personal Data about driver-partners

If you are a 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); and
• your vehicle registration data.

Sensitive Personal Data

Some of the information that we collect is sensitive in nature. This includes information such as national ID numbers, race, marital status, and your health or religious beliefs. We only collect this information when this is necessary to comply with legal or regulatory requirements.

In-vehicle recording

Limolight’s applications or devices

Limolight may install in-vehicle audio and/or video recording applications or devices to promote the safety and security of Limolight driver partners, delivery partners and passengers. Your Personal Data may be captured in these audio and/or video recordings. Where in-vehicle audio and/or video recordings are made, such recordings are collected, processed, used and stored in a manner that is compliant with applicable laws.

Personal In-vehicle cameras

Some Limolight partners may install personal in-vehicle cameras in their vehicles for their own purposes (including safety and security). The use of such in-vehicle cameras is not endorsed or prohibited by Limolight. The collection, use and disclosure of Personal Data obtained from personal in-vehicle cameras is the responsibility of the relevant partner. Please check with the relevant partner if you have any queries about their use of personal in-vehicle cameras.

Telematics devices

Limolight works with some partners (including, but not limited to, Honda, Kia, Toyota and Hyundai) to install telematics devices in selected rental vehicles for the following purposes:

• To ensure that the vehicle is maintained appropriately and serviced in a timely fashion;
• To help maintain the safety, security and integrity of our products and services;
• To improve and enhance our products and services; and
• For internal tracking of the vehicle, analysis and administrative purposes.

If you are a driver partner, these devices will collect telematics data (such as your speed, acceleration, and braking data) and your location information. If you are a passenger onboard one of our vehicles fitted with these devices, your location data (i.e. the position of the car) will be incidentally collected as well.

The data collected by these devices are owned by these partners who have entered into appropriate contractual undertakings with Limolight to safeguard this data. While these partners share such telematics data with us (to enable us to fulfil the purposes stated above), we do not share any personally identifying information about our driver partners or passengers with these partners.

Personal Data of minors

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to LimoLight. In the event that such Personal Data of a minor is disclosed to LimoLight, 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.

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. If you provide us with their Personal Data, you represent and warrant that you have and you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Policy.

LimoLight 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, personalize, maintain and improve our products and 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 ride 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 personalize 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 analyzing 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 LimoLight and to provide you with subscribers’ benefits; and
• enable our partners to manage and allocate fleet resources.

Safety and security

We use your data to ensure the safety and security of our services and all users. This includes:

• screening driver and delivery partners before enabling their use of our Services;
• identifying unsafe driving behaviour such as speeding, harsh braking and acceleration, and providing personalised feedback to driver partners;
• verifying your identity when you log in to LimoLight;
• 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.

Customer support

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 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.

Legal purposes

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 for marketing of LimoLight and LimoLight ‘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; 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, online messaging service, push notification by hand and by email.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings.

We need to share Personal Data with various parties for the Purposes. These parties include:

Other users

For example, if you are a passenger, we may share your pick-up and drop-off locations with drivers.

If you are a driver, we may share your Personal Data with your passenger including your name and photo; your vehicle make, model, number plate, location and average rating.

With third parties

For example, we may share a driver’s location and name with third parties when a passenger uses the “Share My Ride” feature or activates the Emergency Button.

With LimoLight partners at your request

For example, if you requested a service through a LimoLight partner or used a promotion provided by a LimoLight partner, LimoLight may share your Personal Data with that LimoLight partners. Our partners include partners that integrate with our App or our App integrates with, vehicle services partners, or business partners which LimoLight collaborate with to deliver a promotion, competition or other specialised service.

With LimoLight ‘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 LimoLight or on LimoLight ‘s behalf;
• fleet and merchant partners;
• insurance and financing partners; 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.

We retain your Personal Data for as long you maintain your LimoLight account. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to prevent access or use of such Personal Data for any purpose other than compliance with this privacy policy, or for purposes of safety, security, fraud prevention and detection.

LimoLight, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of the Websites and Apps. 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.

LimoLight may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes LimoLight does for itself. 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.

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.

LimoLight 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 Apps, Websites or Services, purchase products from LimoLight or continuing to communicate or engage with LimoLight following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.