Privacy Policy

Last Modified: 08 Jan 2020

This Privacy Policy and its Addendum(s) (“Policy”) describe how Cctvkingdom, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “Cctvkingdom”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of Cctvkingdom’s Apps and Websites (including all mobile applications and websites operated by Cctvkingdom (respectively “Apps” and “Websites”), products, features and other services globally (collectively, “Services”).

This Policy applies to our customers, passengers, agents, vendors, suppliers, partners (such as driver 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.


I. 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 Cctvkingdom 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 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 traveled);
  • 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); 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 programs;
  • 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 race, and your health or religious beliefs. We only collect this information when this is necessary to comply with legal or regulatory requirements.

In-vehicle cameras

Some Cctvkingdom 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 Cctvkingdom. 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.

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 Cctvkingdom. In the event that such Personal Data of a minor is disclosed to Cctvkingdom, 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 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 obtained their consent for their Personal Data to be collected, used, processed and disclosed as set out in this Policy.


IIUSE OF PERSONAL DATA

Cctvkingdom 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 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 favorite 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 Cctvkingdom and to provide you with subscribers’ benefits; and
  • 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 driver and delivery partners before enabling their use of our Services;
  • identifying unsafe driving behavior such as speeding, harsh braking and acceleration, and providing personalized feedback to driver partners;
  • verifying your identity when you log in to Cctvkingdom;
  • using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
  • sharing drivers and passengers’ location and details when the emergency button or the “Share My Ride” feature is activated;
  • 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 analyze 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 advisers 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 Cctvkingdom and Cctvkingdom’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 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.


III. DISCLOSURE OF PERSONAL DATA

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 makes, model, number plate, location and average rating.

With third parties in connection with a ride

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 Cctvkingdom partners at your request

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

With the owner of Cctvkingdom accounts that you may use

For example, your employer may receive trip data when you use your employer’s Cctvkingdom for Business account.

With subsidiaries and affiliates

We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.

With Cctvkingdom’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 Cctvkingdom or on Cctvkingdom’s behalf;
  • fleet and merchant partners;
  • insurance and financing partners; and
  • vehicle solutions partners, vendors or third-party vehicle suppliers.

With our legal advisers and governmental authorities

We may share your Personal Data with our legal advisers, law enforcement officials, government authorities and other relevant third parties.


IV. RETENTION OF PERSONAL DATA

We retain your Personal Data for as long you maintain your Cctvkingdom 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 destroy or permanently delete such Personal Data for any purpose other than compliance with law, this privacy policy, or for purposes of safety, security, fraud prevention and detection.


V. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Your Personal Data may be transferred from country, state and city in which you are present while using our Services (“Home Country”) to another country, state and city (“Alternate Country”). You understand and consent to the transfer of your Personal Data from your Home Country to the Alternate Country.


VI. COOKIES

Cctvkingdom, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML 5 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.

Cctvkingdom may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes Cctvkingdom 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. You may also be able to limit our sharing of some of this Personal Data through your mobile device settings, or by submitting your details.


VII. AMENDMENTS AND UPDATES

Cctvkingdom 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 Cctvkingdom or continuing to communicate or engage with Cctvkingdom following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.


VIII. CONTACT

If you have any queries or complaints relating to your Personal Data, wish to make a request for access or correction of your Personal Data, or would like to withdraw your consent in respect of the Personal Data being processed by us, please contact: Cctvkingdom Data Protection Officer, email: dataprotection@cctvkingdom.com.

The original of this Privacy Statement is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.


ADDENDUM 1: CCTVKINGDOM FOR BUSINESS

I. INTERPRETATION

All capitalized terms but undefined terms used herein shall bear the same meaning as those defined in the Terms of Use and the Cctvkingdom Privacy Policy (accessible at https://www.cctvkingdom.com/privacy-policy/).

This Addendum forms part of the Cctvkingdom Privacy Policy. In the event of any inconsistency between the Cctvkingdom Privacy Policy and this Addendum, this Addendum shall prevail.


II. CCTVKINGDOM’S RELATIONSHIP WITH USERS AND CLIENTS

How Cctvkingdom for Business works

Cctvkingdom for Business is provided as an add-on feature to facilitate corporate billing for the Authorized Users’ use of Cctvkingdom’s Services in the course of work.

When an organization (“Client”) chooses to utilize Cctvkingdom for Business, the Authorized User is given the option of tagging his/her rides or other transactions to the Client or to tag it as a personal ride. An Authorized User is referred to in the Cctvkingdom Privacy Policy as a passenger.

As part of this feature, Cctvkingdom will disclose detailed trip and booking information that Authorized Users have tagged as being for business purposes to the Client. Apart from this, Cctvkingdom does not disclose other Personal Data of its Authorized Users to the Client.

Alternatively, an individual user may choose to set up a business profile within the App to facilitate the tagging of business-related rides and to generate consolidated trip reports to facilitate the submission of claims from his or her employer. When used in this mode, the claims process is user-driven and the user’s employer need not be a Client.

For ease of reference, Authorized Users and individual users will each be referred to as a “User” and collectively as “Users” in this Addendum.

Cctvkingdom is a data user, so are our Clients

In respect of any User and the processing of all their Personal Data (including but not limited to Linking Data and Portal Data), Cctvkingdom acts as a data user. For further information on how Cctvkingdom collects, uses and discloses Users’ Personal Data, please refer to the Cctvkingdom Privacy Policy.

Due to the way Cctvkingdom for Business works, Cctvkingdom does not process any Personal Data for and on behalf of the Client. Accordingly, Cctvkingdom is not the data processor of the Client, but an independent data user in respect of all Personal Data that it processes in the course of providing the Cctvkingdom for Business feature. Likewise, the Client is an independent data user of the Personal Data (e.g. the Linking Data and Portal Data) that it discloses to and/or receives from Cctvkingdom. 

As independent data users, Cctvkingdom and the Client individually determine the purposes and means of processing Personal Data, subject to the provisions set out in the Terms of Use and this Privacy Policy. Cctvkingdom and the Client are also individually responsible to ensure the protection of Personal Data under their charge. 


III. WHAT PERSONAL DATA IS COLLECTED, PROCESSED AND DISCLOSED

What Cctvkingdom collects as part of Cctvkingdom for Business

In order to provide the Cctvkingdom for Business feature, the individual user or the Client will be required to provide the following information about the Authorized User to Cctvkingdom:

  • full name;
  • business email address; and
  • other identifying information about the Authorized User as reasonably requested by Cctvkingdom.

Cctvkingdom will use this information for the purposes of:

  • authenticating the User;
  • where applicable, linking the Authorized User’s account with the Client’s Cctvkingdom for Business account or tracking the Authorized User’s business profile bookings on the Apps, as the case may be;
  • where applicable, verifying the Corporate Billing status of such Authorized User from time to time; and
  • contacting the User in accordance with the purposes set out in the Cctvkingdom Privacy Policy.

Upon on boarding such User to the App, Cctvkingdom will process the Personal Data of the User in accordance with the Cctvkingdom Privacy Policy and this Addendum.

What Cctvkingdom discloses to its Clients

Cctvkingdom will disclose relevant trip and booking information as determined by Cctvkingdom from time to time to the Client to facilitate Corporate Billing.

What Cctvkingdom discloses to its individual user

Depending on the business profile settings selected by the individual user, the user may retrieve and generate reports containing his/her relevant trip and booking information.


IV. PARTIES’ OBLIGATIONS

The Client and Cctvkingdom shall each:

  • individually inform their data subjects of how each processes Personal Data and allow their data subjects to exercise their rights under the local data protection/data privacy laws;
  • comply with the obligations applicable to each party under the applicable data protection/data privacy laws when processing any Personal Data of the Proposed or Authorized Users;
  • obtain the necessary consents (if applicable) to facilitate the provision of the Cctvkingdom for Business feature; and
  • implement appropriate legal, technical and organizational measures to protect Personal Data against unauthorized or unlawful processing and against unauthorized loss, destruction, damage, alteration, or disclosure, as well as any breach or attempted breach of each party’s security measures (“Information Security Incident”).