Effective date : 15 April2026
This Privacy Policy (“Policy”)specific for carsharing service sets forth how BlueSG Pte. Ltd. (operatingunder the trading name “Flexar”), its affiliates and associated companies (“BlueSG,”, “Flexar”, “We,” “Us,” or “Our”) collect, use, process and discloseYour Personal Data (as defined below) through the use of Our application andwebsites (respectively “App” and “Websites”), global positioning service(“GPS”) technology, Flexar cars (“Flexar Car”), the Flexar Customer ExperienceCentre (“Flexar CX”) or the Flexar Claims Department (“Flexar Claims”)(collectively, the “Services”).
The App and/or Websites maycontain links to or information about other websites operated by third partiesthat are outside Our control and/or custody (“Third Party Websites”). When Youuse the Services and/or when You click on the link to these Third PartyWebsites in the App and/or Websites, You may be re-directed to these ThirdParty Websites and Your personal data may be collected and thereafter, used,disclosed and/or processed by parties that own/operate these Third PartyWebsites (the “Third Parties”) (further details for which is provided below).These Third Party Websites may contain their own privacy policies and Youshould review the privacy policies of each of those Third Party Websites tounderstand how Your Personal Data is collected, used, disclosed and/orprocessed by the Third Parties. We are not responsible for the privacypractices of any third party (including any Third Party), external website(including any Third Party Website) or mobile application.
Please read this Policycarefully. By accessing the App and Websites and/or using the Services, Youacknowledge that You have read and understood this Policy, and consent to Ourcollection, use, processing disclosure of Your Personal Data in accordance withand for the purposes set out in this Policy.
This Policy applies to Ourcustomers, partners, suppliers, contractors and service providers (collectively“You”, “Your” or “Yours”).
This Privacy Policy applies toall users of the Services, regardless of which version of the Terms &Conditions governs Your membership.
· “Data Protection Laws” means all applicable laws andregulations in any jurisdiction which relate to the collection, disclosure, useor processing of Personal Data, including without limitation to the SingaporePersonal Data Protection Act 2012 (“PDPA”), including all amendments theretoand subsidiary legislation enacted thereunder, whether now or in the future.
· “Personal Data” refers to any data, whether true ornot, about an individual who can be identified, (a) from that data, or (b),from that data and other information to which an organisation has or is likelyto have access, and includes, without limitation, Your name, nationality,identification numbers, age, telephone numbers, mailing address and date ofbirth.
· “Data Intermediary” refers to a data intermediary thatprocesses Personal Data on behalf of and for the purposes of Flexar.
Where Your Personal Data iscollected and/or processed by one of Our affiliate entity or a parent company,any subcontractor or third party, that entity, acting as a Data Intermediarywill act as a subcontractor of BlueSG and will collect and process YourPersonal Data strictly within the scope of providing the carsharing andancillary services to You and other Flexar members.
When You register as a memberof the Services and use the Services, the following Personal Data may becollected, used, processed and disclosed in accordance with this Policy:
· information stated on Your NRIC forSingaporeans and Permanent Residents (“PRs”) such as Your name, address, dateof birth and NRIC number;
· information stated on Your driver’slicence such as class, validity, issue date and driver’s licence number;
· information stated on Your employmentpass or work permit for non-Singapore citizens and PRs such as Your name, dateof birth and passport or; employment pass or work permit number
· information stated on Your internationaldriver’s licence such as class, validity, issue date and driver’s licencenumber for non-Singapore citizens and PRs;
· Your phone number;
· Your email address;
· Your postal mailing address;
· Your payment card information andtransaction history;
· Your PIN code registered to access theServices;
· any information provided by You when Youcontact the Flexar CX or otherwise share with Our staff members on Our In-Appmessaging system, before, during or after the termination of Your membership tothe Services (“Membership”); and
· any additional Personal Data that isreasonably necessary for the purposes described in this Policy, and which willbe notified to You at the time of collection.
The software used in theprovision of the Services may automatically collect the following informationfrom You that may alone or in connection with other information, constitutePersonal Data:
· Your Internet Protocol (“IP”) address;
· Your device ID numbers such as AppleAdvertising ID;
· to the maximum extent permitted by law,Your location in accordance with the privacy settings of the device used toaccess the Services;
· information about Your browsing activitysuch as Your browser type, Internet service provider, referring/exit pages, thefiles viewed on the Websites (e.g., HTML pages, graphics, etc.), operatingsystem, date/time stamp, and/or clickstream data; and
· in order to use some of the functionsprovided by the App (such as locating a carsharing station), We use anapplication program interface which uses GPS, WIFI and mobile networkinformation technology to determine Your current location when using the App.When You first open the App, We will ask You for Your consent to use Yourlocation data for this purpose. When You are not using the App, We do notcollect location data. You can withdraw Your consent at any time by changingYour location data settings in the App or on Your mobile device, but this willaffect Your ability to use the Services.
Flexar Cars include technologythat enables Us to effectively service Memberships. Included within suchtechnology is a technology that allows Us to collect certain information andGPS data to identify the location of Flexar Cars in real-time (collectively,“Car and Positioning Data”).
Flexar Cars contain in-vehiclerecording devices (“IVRDs”) including audio recorders, which may capture thevoices of individuals within the Flexar Cars, for the purpose of ensuring thesafety and security of drivers and passengers, processing of insurance andaccident claims, as well as for investigations and law enforcement purposes.
By using the Services, Youauthorize and expressly consent to Our use of the technology included in theFlexar Car to the maximum extent permitted by law.
We may also collect PersonalData through the use of common information-gathering tools known as cookies. Acookie helps the Websites to remember You and customize Your visit. You havethe option to delete or decline cookies by changing Your browser’s settings.
We may also use single-pixelimages on the Websites or in Our emails to You. This technology tells Us moreabout browsing, click-tracking, viewing, and buying activity.
Finally, Google Analytics is anelement of the Websites. By using cookies, Google Analytics collects and storesdata such as time of visit, pages visited, time spent on each page of theWebsites, the IP address, and the type of operating system used in the devicesused to access the Websites. By using a browser plugin provided by Google, Youcan opt-out of Google Analytics.
We do not market and do notknowingly collect any Personal Data from or about any individual under the ageof 18 without the consent of such individual’s parent or legal guardian. If Wediscover that We have inadvertently collected Personal Data from an individualunder 18 years of age, We will promptly take all reasonable measures to deletesuch Personal Data from Our systems.
Direct Marketing: We may use Personal Data to generateand send marketing communications to You directly for products and servicesavailable for purchase on the Services and/or Our affiliate websites, coupons,or other marketing opportunities. If You do not wish to receive marketingcommunications directly from Us, You may unsubscribe from the marketing emailor communication sent to You by following the instructions in thatcommunication.
Improving Your Experience: We track Your visits to the Websitesthrough the use of cookies and identify You upon subsequent visits to improveYour experience while browing the Websites.
We may also use Your PersonalData for the following purposes:
· to communicate with You;
· to verify Your identity;
· to manage Your membership;
· to process Your payments;
· to prevent and investigate fraud andother misuses;
· to offer additional transportationservices with other transportation providers;
· to comply with a request for informationfrom, or assist in investigations or law enforcement conducted by governmentand/or authorities whether in Singapore or abroad (including without limitationto the Land Transport Authority of Singapore, Singapore Police Force, TrafficPolice, Urban Redevelopment Authority) or as otherwise required by anyapplicable laws, regulations, codes of practices, guidelines or rules;
· to protect Our rights and/or Ourproperty;
· to operate Our products and Services;
· to manage the Services and/or theWebsites and/or App;
· to enable You to obtain access toproducts and services and engage in offered activities;
· to provide You with information aboutnew and upgraded products and Services, and other information where You haveconsented to be contacted for such purposes;
· to aggregate data;
· to improve Our products and Services andYour experience interacting with Us;
· to audit and analyze the Websites; and
· to ensure the technical functionalityand security of the Websites.
Telematics system: The Flexar Cars are equipped with GPSor other “electronic surveillance technology” (collectively, “TelematicsSystem”) that utilizes wireless technology to transmit data. While wirelesstransmission involves inherent security risks, we implement reasonableadministrative, technical and physical safeguards in accordance with applicableData Protection Laws to protect Personal Data. You consent to and expresslyauthorize Us to monitor the Flexar Cars through such Telematics System to the extentpermitted by law. Further, You acknowledge and agree that:
We, the operators of theTelematics System, or third parties may have access to the information suppliedby the Telematics System including:
· Location of the Flexar Car before,during and at the time of the conclusion of Your rental period, including thereal-time location of any Flexar Car at any given time;
· date and time of departure and return ofthe Flexar Car;
· Your driving behaviour and habits;
· total mileage driven;
· recorded driving information;
· the fuel or charge level of the FlexarCar; and
· other diagnostic, safety, andperformance information to identify and/or repair any technological defectsdisclosed thereby.
We, the operators of theTelematics System, or third parties may use or disclose such information tothird parties to:
· to provide navigation assistance to You;
· to provide additional services for Yousuch as personalized insurance and other services tailored for Your needs;
· determine the date and time the FlexarCar departs from and is returned to a carsharing station, and the total mileagedriven and the fuel or charge level of the returned vehicle;
· locate a stolen, abandoned or missingFlexar Car;
· allow for remote locking and unlockingof the Flexar Car;
· respond to an accident or otheremergency or otherwise to ensure Your safety;
· respond to a specific request from lawenforcement;
· respond, process, pay for or transferliability for any ticket, citation, fine or penalty issued by any respectiveauthority;
· establish or prove the validity ofcharges We impose to Your account; and
· at Your request, provide You withroadside assistance, such as towing, changing a flat tire, refueling orcharging services, and otherwise, to the extent permitted by law.
We may disclose or transferPersonal Data about You to the following categories of third parties:
· Our parent companies, affiliates, andsubcontractors: Youagree to allow Us, our parent and affiliated companies, and Our and theirsubcontractors, some of whom may be located outside of Singapore, including,without limitation, in Germany and in the US, to collect, use, process anddisclose the data collected by Us from You for the purposes set out in thisPolicy. Those companies, including Our providers and subcontractors, arecontractually bound to ensure adequate protection for Your Personal Data aremaintained while Your Personal Data is in Our possession or under Our control.
· Service Providers: These entities assist Us in fulfillingorders from Our members, providing marketing and advertising services, billing,delivering packages, sending mail, providing search results and links, orsimilar services.
· Regulatory Bodies: If You apply for Membership, some ofthe Personal Data about You may be shared with regulatory bodies (whether inSingapore or abroad) to obtain Your driving record or to comply with any legal,regulatory or contractual obligation We may have.
· Law Enforcement and other authorities: Personal Data about You may be sharedwith law enforcement officials (whether in Singapore or abroad) if it relatesto a criminal investigation or alleged illegal activity or breach of anyapplicable laws and regulations, including but not limited to any traffic orparking laws or regulations.
· Necessary for Safety, Security orProtection Reasons: Wemay also disclose Personal Data about You if required or permitted to do so bylaw, for fraud protection and credit risk reduction purposes, or in thegood-faith belief that such action is necessary to protect and defend Ourrights or property, that of Our members, or of the users of the App andWebsites.
· Claims, Recover, Fraud and RiskManagement: You agreeto allow Us to collect and disclose the Personal Data about You to a creditreference agency, debt recovery agency and legal representative, and that suchparties may lawfully process, use and keep a record of Your Personal Data forthe purpose of conducting identity verification, preventing fraud, recoveringclaims or debts, and taking legal action.
· Reorganization / Business Transfer: We may also transfer Your Personal Datain connection with any sale, merger, demerger, divestment, consolidation,restructuring and/or acquisition of all or a portion of Our assets, businessand/or share capital by or into another entity or any similar transaction orcombination thereof. Any such successor entity, assignee and/or purchaser mayuse Personal Data pursuant to its own privacy policies, and those policies maydiffer from this Policy. For such transfer of Your Personal Data, Your consentwill be requested. If You do not agree with the transfer of your Personal Data,the transfer will not be carried out. Consequently, Your Membership with Uswill terminate on the date of Your refusal and You will then have a period of30 calendar days to proceed with the recovery of Your Personal Data. If Youwish to recover Your Personal Data, You shall address Your request at thefollowing email address: privacy@flexar.com.sg. If You do not address Us withYour wish to recover Your Personal Data within this period, We may delete YourPersonal Data from Our servers. Notwithstanding the foregoing, We shall beauthorized to retain Your Personal Data only as long as necessary to fulfillthe purposes for which it was collected, or as required by applicable laws,such as keeping financial records for at least 5 years, retaining telematicsand incident data for the duration of any insurance, regulatory or legal claimperiod, and retaining records necessary for regulatory compliance. PersonalData that is no longer required is securely deleted or anonymized.
· General Marketing: We may share Personal Data with thirdparties for the purpose of marketing products or services to You in compliancewith applicable laws.
When accessing or using certainfunctions or features within the Services and/or when You click on the link tothese Third Party Websites in the App and/or Websites, Your Personal Data maybe collected directly by these Third Parties (such as payment serviceproviders). For example, When making payments through the App, Your PersonalData will be collected directly by Stripe Payments Singapore Pte. Ltd. and itssubsidiaries and related entities (collectively known as “Stripe”). Stripe willuse, process and/or disclose Your Personal Data as a data controller in themanner and for the purposes as set out in Stripe’s Privacy Statement, which maybe found here: https://stripe.com/en-sg/privacy.
By accessing or using suchfunctions or features, You acknowledge and agree that:
1. You have read and understood such ThirdParties’ privacy policies, and consent to the collection, use, disclosureand/or processing of Your Personal Data by such Third Parties pursuant to theirprivacy policies;
2. We do not control such Third Parties,and the manner in which and purposes for which Your Personal Data may becollected, used, processed and/or disclosed is determined solely by such ThirdParties as data controllers; and
3. to the maximum extent permissible bylaw, We shall not be liable for any liabilities, losses or damages that may beincurred by You as a result of the collection, use, disclosure and/orprocessing of Your Personal Data by any Third Party.
Unfortunately, no datatransmitted over or accessible through the Internet can be guaranteed to be100% secure. As a result, while We take reasonable measure to protect allPersonal Data in the manner detailed herein, We cannot ensure or warrant thatPersonal data will be completely secure from misappropriation by hcakers orfrom other nefarious or criminal activities, or in the event of a failure ofcomputer hardware, software, or a telecommunications network. We will notifyYou in the event We become aware of a security breach involving Personal Datain accordance with the requirements under applicable Data Protection Laws. Bydisclosing Your email address to Us for any reason, You expressly consent toreceiving electronic notices from Us in the event of such a security breach.
Some of the elements of theServices and/or Websites and/or App may be hosted on servers located incountries outside Singapore. The laws applicable to the protection of PersonalData in such countries may be different from those applicable in Singapore orYour country of residence. If We are required to transfer Your Personal Dataout of Singapore or Your country of residence, We will ensure that suchtransfers are compliant with the requirements under the applicable DataProtection Laws. In this regard, We will take such necessary measures to ensurethat such overseas recipients are bound by legally enforceable obligations(such as local laws, data transfer agreements or binding corporate rules whereapplicable) to ensure that these overseas recipients provide a standard ofprotection to the Personal Data so transferred that is comparable to theprotection under the applicable Data Protection Laws.
Subject to the exceptions asset out in the Personal Data Protection Act 2012, You are permitted to requestfor access to Your Personal Data that is in Our possession or under Our controland information about the ways in which such Personal Data has been used ordisclosed by Us within a year before the date of Your request. You may becharged a fee for requesting a copy of your personal data. If it is beyond ourreasonable ability to produce a copy of your personal data, we will provide youwith a reasonable opportunity to view your personal data at our premises. Wemay refuse your request for personal data if legally allowed to do so. Inaddition, You may request Us to correct any error or omission in Your PersonalData that is in Our possession or under Our control. If You would like to makesuch a request, please email Us at privacy@flexar.com.sg.
Do Not Call Registry. The main messages (SMS, MMS, WhatsAppmessages) that We may send to Your registered telephone number, or when You areusing Our App, are specifically linked to the proper information about anddelivery of the Services to You. Such messages are therefore not considered as“specified messages” under the PDPA.
We may send You from time totime marketing messages pursuant to a special product or service offer or avoucher to Your registered telephone number via SMS or WhatsApp if You havegiven Us Your clear and unambiguous consent to do so.
You may check when this Policywas last modified by viewing the “Last Updated” legend above. Subject toapplicable laws, we reserve the right to update this Policy from time to time,and You should check the Websites periodically for changes.
For any questions regardingthis Policy, You may contact Us via Our Websites or by email to Our DataProtection Officer at privacy@flexar.com.sg.