(a) the kinds of information wecollect and why we collect it;
(b) how we use that information;
(c) how we protect that information;and
(d) how you can update thatinformation or limit or control how it is used.
1.3 Authority. For the purposes of this Policy, "you" and "your"mean you as the user of our Services and/or Platforms. If you use our Servicesand/or access our Platforms on behalf of a company, organisation or otherentity, then:
(a) "you" includes you and that entity;
(b) you represent and warrant that youare an authorised representative of the entity with the authority to bind theentity to this Policy, and that you agree to this Policy on the entity's behalf;and
(c) your entity is legally andfinancially responsible for your use of our Services as well as for the use ofyour account by others affiliated with your entity, including any employees,agents or contractors.
1.4 Acknowledgement andConsent. Byinteracting with us, visiting our Platforms, or accessing our Services, youacknowledge and agree that you accept the practices, requirements, and/orpolicies outlined in this Policy (as updated from time to time), and you herebyconsent to us collecting, using, disclosing and/or processing your personaldata as described herein.
1.5 Policy Updates. Our Policy may be revised from time to time to reflect changes in the law or technology, orchanges in our practices regarding information collection and use. If we makematerial revisions to the way we collect or use your personal data so that weare using it for purposes or sharing data with third parties that you have notconsented to, we will provide you with notice of those changes and may do so byannouncing the change through ourPlatforms. You agree that we may notify you aboutmaterial changes in the way we treat personal data by placing a notice on the Eigen Energy Platforms.You should check our Platforms frequently for updates.
2. INFORMATIONTHAT EIGEN ENERGY COLLECTS
2.1 Personal Data. For the purposes of this Policy, "Personal Data",otherwise known as "Personal Information", shall be deemed to include data,whether true or not, about an individual who can be identified (a) from suchdata; or (b) from that data and other information to which the organisation hasor is likely to have access.
2.2 Information We Collect. We collect information directly from users of our Platforms,automatically when you use or interact with our Platforms and/or when you useour Services and/or access our Platforms. We may collect, store and processyour Personal Data, including but not limited to:
(a) Personal Data Given by You. The Personal Data provided by you when you create an account, purchaseany Services and/or interact with our Platforms
(b) Personal Data Collected from Your Use of our Platforms. Personal Data is generatedfrom information that we collect from your interaction with the Platforms, suchas the services you use and your activity on our Platforms. This information thatwe may collect, includes but is not limited to:
(i) Device Information. We maycollect device-specific information (such as your electric vehicle model, operatingsystem version, unique device identifiers, and mobile network information).
(ii) Log Information. When you use ourPlatforms, we automatically collect and store certain information in serverlogs, which automatically record certain information when you use ourPlatforms, including the following:
(A) details about how you have used our Platforms, such asduration of the sessions, device, capability, bandwidth;
(B) your internet protocol (IP) address, which is thenumber assigned to an internet-connected device such as a tablet or smartphoneand used to identify the geographic location of that device; and
(C) cookies that may uniquely identify your browser andcollect information about howour visitors interact with our Platforms, as well as help us identify problems such as error messages from certain pages;
(D) information about your usage of and interaction withour website and/or services including statistics on page views, and traffic toand from our website.
(iii) Payment Information. Wemay collect and generate payment information andtransaction information (such as records of services purchased on our Platforms).
(iv) Customer Service. Werecord information that you have submitted through forms or other documentsrelating to any of our products or service.
(v) Location Information. Wemay collect and use real-time geolocation information when you interact withour Platforms for certain location-enabled services. As Eigen Energy is constantly innovating anddeveloping ways to improve our Platforms and Services such as but not limitedto introducing new features, we may create new ways to collect and useinformation. In such cases, we will, as soon as practicable, inform our usersof these functionalities by updating our Policy. You may decline to provide us with your Personal Data; however, this will limit your ability to use our Platforms and Services.
2.3 Personal Data of Minors and Children. Except where otherwise indicated,we do not knowingly collect or store any Personal Data from children under theage of eighteen (18). If a parent or guardian becomes aware that his or herchild under the age of eighteen (18) has provided us with information withouthis or her consent, he or she should contact our Data Protection Officer.Subject to the applicable laws, we will delete such information from our fileswithin a reasonable period of time. We may, using our discretion, also deletePersonal Data from our Platforms from users we believe are under the age ofeighteen (18).
3. HOW WE USE PERSONAL DATA THAT WE COLLECT
3.1 Collection of PersonalData. Generally, we collect Personal Data in thefollowing ways:
(a) when you use our Platforms and/orServices;
(b) when you request that we contactyou, be included in an email or other mailing list and when you are contactedby, and respond to, our marketing representatives and customer serviceofficers;
(c) when you submit any form relatingto any of the Services; and/or
(d) when you submit your Personal Datato us for any other reasons, including but not limited to when you express yourinterest in any of the Services. You should ensure that all Personal Datasubmitted to us is complete, accurate, true and correct. Failure on your partto do so may result in our inability to provide you with the Products andServices you have requested.
3.2 Purpose. We use the information and PersonalData that we collect from users of our Platforms in order to improve youroverall experience as a user as well as the quality of our Services. We willuse your Personal Data for legitimate purposes in connection with our business,including but not limited to:
(a) ensuring that youridentity is verified, including distinguishing you from another person with thesame or similar details as yourself;
(b) handling, processing andresponding to any queries, requests, applications, complaints, or feedback fromyou;
(c) executing our systemadministration and reporting aggregate information to third party serviceproviders and potential business partners. This relates to statistical dataabout our user's browsing actions and patterns, and does not specify anyindividual;
(d) carrying out ourServices and any reasonable business activities such as audits, risk managementor business reporting;
(e) complying with anypolicies (including the policies of charging station owners and operators),applicable laws, regulations, or to assist with any law enforcement orinvestigations conducted by any governmental and/or regulatory authority;
(f) ensuring that contentfrom our Platforms is presented in the most effective manner for you and foryour device;
(g) providing you withinformation, products or services that you request from us or which we feel mayinterest you, where you have consented to be contacted for such purposes;
(h) carrying out ourobligations arising from any contracts entered into between you and us;
(i) administering anydispute resolution processes or to enforce or defend our rights, contractual orotherwise, including investigations and participating in potential or actuallitigation, arbitration, or other legal processes;
(j) notifying you aboutchanges to our Services and/or our Platforms;
(k) processing any paymentor credit transactions and/or performing our Services;
(l) maintaining theintegrity of our Services and promoting safety and security on and off thePlatforms;
(m) conducting market research for statistical, profilingand statistical analysis for the improvement of services provided to you;
(n) promoting and marketing EigenEnergy, our Services and Platforms; and
(o) drawing inferences aboutyour preferences to help us provide you with personalised content and to helpus improve our services. By providing such information, you herebyacknowledge and consent that your Personal Data can be used by Eigen Energy, our partners and other service providers where permitted by the applicable law.
3.3 Non-Exhaustive List. You acknowledge, agree and consent to the processing of your PersonalData and understand that the list provided above is not exhaustive. 3.4 Aggregate Data. We may provide our business associates, partners,potential partners or advertisers with aggregate information about our users.We may also use such aggregate information to help advertisers reach the kindof audience they want to target. We may make use of the Personal Data we havecollected from you to enable us to comply with our business associates',partners' or advertisers' wishes by displaying their advertisement to thattarget audience.
3.5 Continuation. We may continue to use your Personal Data even in a situation where theuse of Services, our Platforms or any contractual obligations you may have withus may have ceased, been terminated or altered in any way, for a reasonableperiod thereafter.
4. WHEREWE STORE THE INFORMATION
4.1 Singapore or Elsewhere. Your Personal Data may be stored andtransferred across our systems operating in Singapore or in a jurisdictionoutside of Singapore. The use of this global infrastructure is necessary andessential to provide our Services.
4.2 Third Party Providers. Some of the Personal Data you provide to usmay also be stored or processed on our behalf by third party suppliers and dataprocessors which may be located in Singapore or jurisdictions outside ofSingapore.
4.3 Transfers of Personal Data. ThePersonal Data we collect from you may be transferred to a destination inSingapore or a country outside of Singapore for the purpose of providing ourServices to you when you are in those countries. Whether to third parties or internally, we willtake all steps reasonably necessary to ensure that all your Personal Data istreated securely and in accordance with this Policy through contractual clausesand/or ensure that such jurisdictions have equivalent data transfer regulationsto protect the security and confidentiality of your Personal Data.
4.4 Consent to Transfers ofPersonal Data. Byinteracting with our Platforms and/or using our Services, you agree to thetransfer, storage or processing of Personal Data described above.
4.5 Duration of Retention. We may retain your Personal Data for as long as it is necessary tofulfil the purpose for which it was collected, desirable for our business or asrequired or permitted by applicable laws. We will put in place measures suchthat your Personal Data in our possession or under our control is destroyedand/or anonymised as soon as it is reasonable to assume that: (a) the purposefor which that personal data was collected is no longer being served by theretention of such personal data; and (b) retention is no longer necessary forany other legal or business purposes.
5. YOUR RIGHTS AND LIMITATIONS
5.1 Request for Access. In accordance with the applicable laws, you have the right to requestfor access to, request for a copy of, request to update or correct, yourPersonal Data held by us. Please note that a reasonable fee may be charged foran access request and if so, we will inform you of the fee before processingyour request. You may contact our Data Protection Officer. As a note, access toyour Personal Data may be denied on certain grounds, for example: it isunlawful; it may have an unreasonable impact upon the privacy of otherindividuals; or your request is frivolous or vexatious. If we deny you access,we will provide our reason for doing so at the time of your request.
5.2 Withdrawal of Consent. You have the right, by notice in writing to inform us of your withdrawal(in full or in part) of your consent previously given to use your PersonalData, subject to any applicable legal restrictions, contractual conditions anda reasonable duration of time for the withdrawal of consent to be effected.However, depending on the extent of your withdrawal of consent for us toprocess your Personal Data, you may not be able to access our Services and/oruse our Platforms.
5.3 Scope of our Policy.
(a) Please read the privacy policiesof our partners, the charging service operators and/or owners where you areusing our Services in conjunction with the charging stations provided by ourpartners. By accessing, interacting and using our Platforms and Services, youhereby agree to the privacy policies of our charging service operators and/orowners as well
(b) Subject to the foregoing, ourPlatforms may, from time to time, contain links to and from the platforms ofour partner networks, advertisers and affiliates. If you follow a link to anyof these platforms, please note that these platforms have their own privacypolicies and that we do not accept any responsibility or liability for thesepolicies. Please check these policies before you submit any Personal Data tothese platforms. Please be reminded that we do not control theprivacy practices of these third-party services and we encourage you to readthe privacy policies of all third party organisations.
6. DISCLOSUREOF INFORMATION
6.1 Information We Share. We will take reasonable steps to protect your PersonalData against unauthorised disclosure. Subject to the provisions of anyapplicable law, this Personal Data may be disclosed, for the purposes listedbelow (where applicable), to the following third parties, whether they arelocated overseas or in Singapore: We may share your PersonalData with companies, organisations and individuals outside of Eigen Energy, including but not limited to:
(a) Eigen Energy affliates
(b) Service Providers. Service providers, located in Singapore, act as data processors on ourbehalf and provide data hosting facilities, email services, IT and systemadministration services that support our Platforms and Services. We may share yourPersonal Data with service providers (including but not limited to paymentprocessors, fraud detection vendors, service-related technology providers, andsurvey administrators) that provide services to you and us, including to helpus maintain our databases and Platforms, administer emails, display content,and analyse the usage activity of our Platforms.
(c) Our Partners. We may share your Personal Data and payment information with ourbusiness partners to perform Services and/or to execute a contract. If you donot want your Personal Data shared with these companies, you may contact us andour Data Protection Officer.
(d) Advertising Partners. We may share Personal Data that you provide and payment information withadvertising partners that use various technologies to send or serve relevantadvertisements to you as you browse the internet.
(e) Within Our Organisation. We may share any of your Personal Data with parent companies,subsidiaries, joint venture partners, and other entities under common controlsubject to this Policy.
(f) Business Transfers. In the event of a fundraising exercise, merger, acquisition, duediligence, reorganisation, bankruptcy, receivership, sale of company assets(whether by private sale, through the operation of law, as part of a divestitureplan, or otherwise) or such other similar transactions, your Personal Data andany other information that we have collected, may be disclosed to the personsand/or entities who have expressed interest in investing and/or acquiring therelevant business unit or as otherwise necessary to complete the transaction aspermitted by law or contract.
(g) Legal and SimilarDisclosures. We may disclose Personal Dataabout you with law enforcement, the courts, other government agencies, ouradvisors, attorneys, and others who participate in the legal process, ifnecessary to do so by law or based on our good faith belief that it isnecessary to enforce or apply our contracts, conform or comply with the law oris necessary to protect us, the users of the Platforms, or others. We may alsodisclose Personal Data about you in the event of a duty to disclose or sharesuch information to comply with any legal or regulatory obligation or requestor to investigate potential data breaches.
(h) Additional Disclosures. In addition to the sharing described in this Policy, we may shareinformation about you with third parties for legitimate purposes in connectionwith the running of our business.
7. PROTECTING YOUR PERSONAL DATA
7.1 Data Security. We work hard to protect the information provided by, or collected about,the users of our Platforms, from unauthorised access, alteration, disclosure ordestruction. In the event of a data breach, Eigen Energy will, as soon as reasonably practical, notify all affected parties ofsuch breach.
7.2 Internet Transmission ofInformation. Please note that the transmissionof information via mobile networks, the internet and the world wide web is notcompletely secure. Although we do our best to protect your Personal Data, wecannot guarantee the security of your data transmitted to our Platforms and anytransmission is made at your own risk.
7.3 Handling complaints from our users and regulatoryauthorities. We regularlyreview our compliance with this Policy and with any and allindustry-recommended best practices, as well as applicable laws andregulations. When we receive a formal written complaint, we will contact theperson who made the complaint to follow up. This is without prejudice to yourright to launch a claim with your local data protection supervisory authority.We work with the appropriate regulatory authorities, including local dataprotection authorities, to resolve any complaints regarding the transfer of PersonalData that we cannot resolve with the users of our Services directly.
8.1 Implementation of Cookies. We may from time to time implement cookies ("Cookies") or other features to allow us or third parties to collect orshare information that will help us improve our Platforms and the Services weoffer or help us offer new services and features.
8.2 What are Cookies. Cookies are small files that are placed on your computer when Platformsis accessed by you. Cookies help the user to navigate efficiently between pagesand the operator to track usage of the site. We may link Cookie information toPersonal Data.
8.3 Use for Cookies. Cookies allow us to recognise your device or computer and tell us howand when the Services or Platforms are used or visited, by how many people andto track activity within our Platforms. Cookies are also used to delivercontent specific to your interest and to monitor usage of the Platforms andServices.
8.5 Privacy and Choice. People have different concerns about privacy. Our goal is to be clearabout what information we collect, so that you can make meaningful choicesabout how that information is used. You may set your browser in its "options"or "preferences" feature to warn you before accepting Cookies or todisable Cookies entirely. However, it is important to understand that many ofthe Services we provide on our Platforms and to our users may not functionproperly if your Cookies are disabled.
(Updated as at 18 October 2022)