TodaMax Privacy Policy

This Privacy Policy and its Addendum(s) ("Policy") outlines how TodaMax (collectively "TodaMax", "we", "us" or "our"), associated companies, affiliates, and jointly managed entities utilize, process, collect, and disclose your Personal Data through the use of TodaMax's mobile applications and websites services (such as "Apps" and "Websites"), as well as products, features, and other services operated by TodaMax.

This Policy applies to our users, merchants, customers, passengers, agents, suppliers, drivers, vendors, contractors, service providers, and other various partners (collectively "you," "your" or "yours").

"Personal Data" is any information that can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, email address, race, date of birth, marital status, religion, personal interests,  picture, bank and credit card details, government-issued identification numbers, biometric data, health information, vehicle, and insurance information, employment information and financial information.

 

I. COLLECTION OF PERSONAL DATA

TodaMax collects Personal Data in various ways indicated below. TodaMax may also fuse the collected Personal Data with other Personal Data in our database. In the situation that you have or are a member to multiple relationships with us (such as, you use our Services across our various features, or if you are both a driver-partner/delivery partner as well as a passenger on our transport services or a customer on our other business verticals), TodaMax will link your Personal Data collected across your various capacities to facilitate your use of our Services and for the purposes described below.

1.1 You provide your Personal Data to us

TodaMax collects your Personal Data when you voluntarily provide it to us. For example, you may provide your Data to us when you:

1. Account data, including your name, email address, password, telephone number, country, user ID, language, communication, and other profile settings complete a user profile or registration forms (such as your name, contact information, and other identification information where needed);
2. Order and delivery data, including delivery details (e.g., delivery address, date and time of the delivery, type of collection), order IDs, order history, product names and quantities
3. Location data, including address, postcode, city, country, longitude and latitude
4. Device information , including device ID, IP address, session information, device configuration settings, operating system, platform interactions such as items added to the cart, and other data obtained through web-trackers (e.g. cookies, SDKs, pixels)
5. Payment data , including bank account details, credit card data, tax ID, payment method data, payment amount, payment recipient details, refund details, and bank receipts
6. Customer support data, including content of your customer support requests, response from our customer care teams and images attached
7. provide information to assess your eligibility to provide services as a TodaMax Delivery Partner (such as your driver's license information, vehicle information, and background check results (as legally permissible));
8. interact with our social media pages (such as your social media account ID, profile photo, and any other publicly available data);
9. participate in contests or events organized by us (such as the pictures, audio files, or videos you may submit, which may include images of yourself);
10. verify your identity through various means (such as social media logins, submission of  selfie images, or independently verified payment card information); 
11. fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation, and income information);

1.1.1 In certain circumstances, you may need to provide your Personal Data to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstance, 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.

1.2 When our services are used

Personal Data may be collected through the regular operation of our Apps, Websites, and Services. Some examples are:

1. your location (to detect pick-up locations and abnormal route variations);
2. feedback, ratings, and compliments;
3. transaction information (such as payment method and distance traveled);
4. information about how you interacted with our Apps, Website, or Services (such as features used and content viewed);
5. device information (such as hardware model and serial number, IP address, file names and versions and advertising identifiers or any information that may indicate device or app modification);
6. personal data you enter in messages when you use our in-app communication features; and
7. personal data that may be captured through your interaction with us, our agents, in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).

1.3 From other sources

When we collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include:

1. referral programs;
2. our business partners, such as fleet partners, payment providers, ride-hailing partners and transport partners;
3. insurance and financial providers;
4. credit bureaus and other credit reporting agencies;
5. publicly available sources of data;
6. governmental authorities of data;
7. when our users add you as an emergency contact; and
8. marketing services providers or partners.

1.4 Personal Data about driver-partners

If you are a driver-partner, we may collect:

1. telematics data (such as your speed, acceleration, and braking data);
2. device data (such as accelerometer data, GPS location, your IMEI number and the names of apps you have installed on your device);
3. your vehicle registration data; and
4. personal data that may be captured through your interaction with us, our agents, our in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).

1.5 Sensitive Personal Data

Some of the Personal Data that we collect is sensitive in nature. This includes Personal Data pertaining to your race, national ID information, religious beliefs, background information (including financial and criminal records, where legally permissible), health data, disability, marital status, and biometric data, as applicable. We collect this information only with your consent and/or in strict compliance with applicable laws.

1.6 In-vehicle recording

1.7 TodaMax's applications or devices

TodaMax may install in-vehicle audio and/or video recording applications or devices to promote TodaMax driver-partners, delivery partners, and passengers' safety and security. 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.

 1.8 Personal In-vehicle cameras

Some TodaMax 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 TodaMax. The collection, use, and disclosure of Personal Data obtained from personal in-vehicle cameras is the relevant partner's responsibility. Please check with a suitable partner if you have any queries about their use of personal in-vehicle cameras.

1.9 Telematics devices

TodaMax works with some partners to install telematics devices in selected rental vehicles for the following purposes:

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

1.9.1 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 on board one of our vehicles fitted with these devices, your location data (i.e. the position of the car) will be incidentally collected as well.

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

1.10 Personal Data of minors

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to TodaMax. If such Personal Data of a minor is disclosed to TodaMax, you hereby consent to the minor's Personal Data processing and accept and agree to be bound by this Policy and take responsibility for his or her actions.                

1.11 When you provide Personal Data of other individuals to us

You may provide Personal Data of other individuals (such as your spouse, family members or friends) to us in some situations. 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 and disclosed as set out in this Policy.

 

II.    USE OF PERSONAL DATA

TodaMax may use, combine and process your Personal Data for the following purposes ("Purposes" ):    

2.1 Providing services and features

Your Personal Data will be used to provide, personalize, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:

1. provide you with Services across our various business verticals;
2. engage you to provide Services;
3. create, administer and update your account;
4. conduct due diligence checks;
5. verify your identity;
6. verify your age (where necessary);
7. validate your ride and process payments;
8. offer, obtain, provide, facilitate or maintain insurance or financing solutions;
9. track the progress of your trip and detect abnormal trip variations;
10. enable features that personalize your App, such as lists of your favorite places and previous destinations;
11. make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;    
12. 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;
13. protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
14. process and manage your rewards;
15. enable communications between our users;
16. process, manage or verify your application of promotions, rewards, and subscriptions with TodaMax;    
17. enable our partners to manage and allocate fleet resources; and
18. fulfill the services to you as a data processor, where you have provided consent to the data controller (i.e. the organization you had purchased goods or services from, and for whom TodaMax is providing services on behalf of) for such services to be rendered.    

2.2 Safety and security

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

1. screening driver and delivery partners before enabling their use of our Services;
2. identifying unsafe driving behavior such as speeding, harsh braking and acceleration, and providing personalized feedback to driver-partners;
3. verifying your identity when you log in to TodaMax;
4. using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
5. sharing drivers and passengers' location and details when the emergency button or the "Share My Ride" feature is activated;
6. monitoring compliance with our terms and conditions, policies and Driver's Code of Conduct; and
7. detecting, preventing and prosecuting crime.

2.3 Customer support

We use Personal Data to resolve customer support issues. For example, we may:

1. investigate and address concerns;
2. monitor and improve our customer support responses;
3. respond to questions, comments and feedback; and
4. inform you about steps taken to resolve customer support issues.

2.4 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 our Services' safety and security, develop new features, products and services, and facilitate insurance and finance solutions.

2.5 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.

2.5.1 We may also use your Personal Data when we are needed, 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:

1. comply with court orders or other legal, governmental or regulatory requirements;
2. enforce our Terms of Service or other agreements; and
3. protect our rights or property in the event of a claim or dispute.

2.5.2 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.

2.6 Marketing and promotions

We may use your Personal Data to market TodaMax and TodaMax's partners', sponsors' and advertisers' products, services, events or promotions. For example, we may:

1. send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
2. notify, invite and manage your participation in our events or activities.

2.6.2 We may communicate such marketing to you by post, telephone call, short message service, online messaging Service, push notification by hand and by email.

2.6.3 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.

 

III.    Disclosure of personal data

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

3.1 Other users

For example: 

1. If you are a passenger, we may share your pick-up and drop-off locations with our driver-partner fulfilling your service request.
2. If you are a driver-partner, we may share your Personal Data with your passenger, including your name and photo; your vehicle make, model, number plate, location and the average rating.
3. If you are a delivery partner, we may share your Personal Data with your selected merchant and user, including your name and photo; your vehicle make, model, location and average rating.
4. If you are using our TodaMax Delivery service, we may share your Personal Data with the recipient of your parcel, and vice versa, as well as the delivery partner in charge of fulfilling your service request.
5. If you use our in-app chat service, we may share your mobile number and TodaMax-registered name with the other parties to your chat.  

3.2 With third parties

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

3.3 With TodaMax partners at your request

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

3.4 With the owner of TodaMax accounts that you may use

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

3.5 With subsidiaries and affiliates

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

3.6 With TodaMax'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:

1. payment processors and facilitators;
2. debt collectors;
3. credit bureaus and other credit reporting agencies;
4. background check and anti-money laundering service providers;
5. cloud storage providers;
6. marketing partners and marketing platform providers;
7. data analytics providers;
8. research partners, including those performing surveys or research projects in partnership with TodaMax or on TodaMax's behalf;
9. fleet and merchant partners;
10. insurance and financing partners;
11. third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
12. service providers who perform identity verification services; and
13. vehicle solutions partners, vendors or third-party vehicle suppliers.

3.7 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. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:

1. where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or    
2. where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).

 

IV.    RETENTION OF PERSONAL DATA

We retain your Personal Data for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or allowed by law. 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 erase, destroy, anonymize or 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.    

 

V.    COOKIES AND ADVERTISING ON THIRD-PARTY PLATFORMS

6.1.1 TodaMax, 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.

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

6.1.3 Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a joint account identifier (such as an email address), to facilitate the display of targeted advertising on third-party platforms.

6.1.4 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 limit our sharing of some of this Personal Data through your App (Settings > Privacy > Ads) and mobile device settings.

 

VI.    PROTECTION OF PERSONAL DATA

7.1.1 We will take reasonable legal, organizational and technical measures to ensure that your Personal Data is protected. This includes efforts to prevent Personal Data from getting lost, or used or accessed in an unauthorized way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorized manner and are required to treat your information with confidentiality.

7.1.2 Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means; therefore, any transmission remains at your own risk.

 

VII.      YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA    

In accordance with applicable laws and regulations, you may be entitled to:

1. ask us about the processing of your Personal Data, including to be provided with a copy of your Personal Data;    
2. request the correction and/or (in some cases) deletion of your Personal Data;
3. in some cases, request the restriction of the processing of your Personal Data, or object to that processing;
4. withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
5. request receipt or transmission to another organization, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and 
6. complain to the relevant data privacy authority if your data privacy rights are violated or if you have suffered as a result of unlawful processing of your Personal Data.

8.1.1 Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to process and later decide to withdraw it, we will respect that choice according to our legal obligations.

8.1.2 However, choosing not to share your Personal Data with us or withdraw your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of the Services. After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

8.1.3 We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request.

8.1.4 Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

 

VIII. AMENDMENTS AND UPDATES

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

 

ADDENDUM 1: TodaMax FOR BUSINESS

I.    INTERPRETATION

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

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

 

II.    TodaMax'S RELATIONSHIP WITH USERS AND CLIENTS

How TodaMax for Business works

2.1.1.a TodaMax for Business is provided as an add-on feature to facilitate corporate billing for the Authorised Users' use of TodaMax's Services in the course of work.

2.1.2.b When an organization ("Client") chooses to utilise TodaMax for Business, the Authorised 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 Authorised User is referred to in the TodaMax Privacy Policy as a passenger.

2.1.3.c As part of this feature, TodaMax will disclose detailed trip and booking information that Authorised Users have tagged as being for business purposes to the 2.1.4.d Client. Apart from this, TodaMax does not disclose other Personal Data of its Authorised Users to the Client.

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

2.1.6.f For ease of reference, Authorised Users and individual users will each be referred to as a "User" and collectively as "Users" in this Addendum.

2.1.1 TodaMax is a data controller, so are our Clients

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

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

2.1.4 As independent controllers, TodaMax 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. TodaMax 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 TodaMax collects as part of TodaMax for Business

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

1. full name;
2. business email address; and
3. other identifying information about the Authorised User as reasonably requested by TodaMax.

3.1.1.a  TodaMax will use this information for the purposes of:

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

3.1.2.b Upon onboarding such User to the App, TodaMax will process the User's Personal Data in accordance with the TodaMax Privacy Policy and this Addendum.

3.1.1 What TodaMax discloses to its Clients

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

3.1.2 What TodaMax discloses to its individual user

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

 

IV.    PARTIES' OBLIGATIONS

The Client and TodaMax shall each:

1. 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;
2. 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 Authorised Users;
3. obtain the necessary consents (if applicable) to facilitate the provision of the TodaMax for Business feature; and
4. 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").

 

V.  ACCOUNT DATA ON CLOSURE 

1. Except as otherwise required by law, if a User’s Account is closed for any reason, a User will no longer have access to data, messages, files, or other materials a User keeps on the Platform and that any closure of a User’s Account may involve deletion of any content stored in such User’s Account for which TodaMax will have no liability whatsoever. TodaMax, in its sole discretion and as permitted or required by law, may retain some or all of such User’s Account information.