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. If you have or are a party to multiple relationships with us (for example if you use our Services across our various business verticals, or if you are a delivery partner as well as a consumer to our Apps or on our other business verticals), we will link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below.

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:

– Complete a user profile or registration forms (such as your name, contact information and other identification information where needed);

– Provide information to assess your eligibility to provide services as a delivery partner (such as your driver’s license information, vehicle information and background check results (as legally permissible));

– Interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);

– Participate in contests or events organised by us (such as the pictures, audio files, or videos you may submit, which may include images of yourself);

– Verify your identity through various means (such as social media logins, submission of  selfie images or independently verified payment card information);

– 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)

In certain circumstances, you may need to provide your Personal Data in order 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 failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.

For purposes such as detection and prevention of fraud, we may also collect your Personal Data without consent, by relying on Legitimate Interests or other exemptions provided by the applicable data privacy laws.

When our services are used

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

– Your location (to detect pick-up locations and abnormal route variations);

– Feedback, ratings and compliments;

– Transaction information (such as payment method and distance travelled);

– Information about how you interacted with our Apps, Website or Services (such as features used and content viewed);

– Device information (such as hardware model and serial number, IP address, file names and versions, and advertising identifiers or any information that may provide indication of device or app modification);    

– Personal data you enter in messages when you use our in-app communication features; and

– 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).

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:

– Referral programmes;

– Our business partners, such as payment providers and transport partners;

– Insurance and financial providers;

– Credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;    

– Publicly available sources of data;

– Governmental sources of data;

– When our users add you as an emergency contact; 

– When you use our in-app chat; 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);    

– Your vehicle registration data; and

– 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).

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.

Personal Data of minors

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to Odaring. In the event that such Personal Data of a minor is disclosed to Odaring, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Notice 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 or when you use the in-app chat. 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 Notice.

Odaring 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, personalise, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:

– provide you with Services across our various business verticals;
– engage you to provide Services;
– create, administer and update your account;
– conduct due diligence checks and risk assessments / analysis;
– verify your identity;
– verify your age (where necessary);
– validate your ride and process payments;
– offer, obtain, provide, facilitate or maintain insurance or financing solutions;
– track the progress of your trip and detect abnormal trip variations;
– enable features that personalise your App, such as lists of your favourite places and previous destinations;
– 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;
– perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing 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 eligibility for or application of promotions, rewards and subscriptions with Odaring;
– enable our partners to manage and allocate fleet resources; and
– fulfil the services to you as a data processor, where you have provided consent to the data controller (i.e. the organisation you had purchased goods or services from, and for whom Odaring is providing services on behalf of) for such services to be rendered.

Safety and security

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

– screening delivery partners before enabling their use of our Services;
– identifying unsafe driving behaviour such as speeding, harsh braking and acceleration, and providing personalised feedback to driver partners;
– verifying your identity when you log in to Odaring;
– using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
– monitoring compliance with our terms and conditions, policies and Delivery partner’s Code of Conduct; and
– detecting, preventing and prosecuting crime.

Odaring support

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

– investigate and address concerns;
– monitor and improve our user support responses;
– respond to questions, comments and feedback; and
– inform you about steps taken to resolve user support issues.

Research and development and security

We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our      Services, develop new features, products and services, and facilitate insurance and finance solutions.

Legal purposes

We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law. We may also use Personal Data without consent, by relying on Legitimate Interests or other exemptions provided by the applicable data privacy laws, for purposes such as detection and prevention of fraud. 

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

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

We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.

Marketing and promotions

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

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

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

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

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

Other users

For example: 

– If you are a 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.
– If you use our in-app chat service, we may share your mobile number and Odaring-registered name with the other parties to your chat.

With third parties

We may share your Personal Data with the following parties:

– If you are a delivery-partner, we may rely on Legitimate Interests or other exemptions provided by the applicable data privacy laws to disclose your vehicle plate number or other personal data to the insurance company and/or to your passenger for the purpose of submission of insurance claim.

 With Odaring partners at your request

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

With subsidiaries and affiliates

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

With Odaring’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;
– debt collectors;
– credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
– 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 Odaring or on Odaring’s behalf;
– fleet and merchant partners;
– insurance and financing partners;
– third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
– service providers who perform identity verification services; and
– vehicle solutions partners, vendors or third-party vehicle suppliers.

With our legal advisors and governmental authorities

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

We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Notice 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, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Notice , or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

Odaring, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (“Cookies”) in connection with your use of the Websites and Apps. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Apple’s IDFA). 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.

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

Disabling the collection of cookies on our 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. 

Disabling the display of Targeted Ads through our App 

You may be able to limit our use of your personal data to display advertisements that may be of relevance to you, by adjusting your preference sharing of some of this Personal Data through our Odaring App (Settings > Privacy > Ads). You will still be seeing non targeted advertisements.

We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised 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 authorised manner and are required to treat your information with confidentiality.

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.

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

– ask us about the processing of your Personal Data, including to be provided with a copy of your Personal Data;
– request the correction and/or (in some cases) deletion of your Personal Data;
– in some cases, request the restriction of the processing of your Personal Data, or object to that processing;
– withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
– request receipt or transmission to another organisation, 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
– 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. 

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 processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your Personal Data with us or withdrawing 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.

If you wish to make a request to exercise your rights, you can contact us through our contact details set out in Section X (How to Contact Us) below.

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.

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

Odaring may modify, update or amend the terms in this Notice at any time. Such amendments shall be notified to you through the Application and/ or other appropriate means  at least five (05) business days before the effective date. The updated version will be posted on the website https://www.odaring.com. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Apps, Websites or Services, purchase products from Odaring or continuing to communicate or engage with Odaring following the modifications, updates or amendments to this Notice , whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.

If you have any queries about this Notice or would like to exercise your rights set out in this Notice , please contact our Data Protection Officer at:

Odaring Support Details: 

Evolf Technology Sdn Bhd

Tower 3, K03-3a-10, UOA Business Park, 

U1, Section, No. 1, Jalan Pengaturcara U1/51a, Kawasan Perindustrian Temasya 

40150 Shah Alam, Selangor Darul Ehsan, Malaysia

Email: enquiry@odaring.com

I. INTERPRETATION

All capitalised terms but undefined terms used herein shall bear the same meaning as those defined in the Terms of Use and the Odaring Privacy Notice (accessible at https://www.odaring.com/privacy/).

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

II. Odaring’S RELATIONSHIP WITH USERS AND CLIENTS

How Odaring for Business works

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

When an organisation (“Client”) chooses to utilise Odaring 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 Odaring Privacy Notice as a passenger of delivery partners.

As part of this feature, Odaring will disclose detailed trip and booking information that Authorised Users have tagged as being for business purposes to the Client. Apart from this, Odaring does not disclose other Personal Data of its Authorised 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, Authorised Users and individual users will each be referred to as a “User” and collectively as “Users” in this Addendum.

Odaring is a data controller, 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), Odaring acts as a data controller. For further information on how Odaring collects, uses and discloses Users’ Personal Data, please refer to the Odaring Privacy Notice .

Due to the way Odaring for Business works, Odaring does not process any Personal Data for and on behalf of the Client. Accordingly, Odaring 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 Odaring 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 Odaring.

As independent controllers, Odaring 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 Notice . Odaring 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 Odaring collects as part of Odaring for Business

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

– full name;

– business email address; and

– other identifying information about the Authorised User as reasonably requested by Odaring.

Odaring will use this information for the purposes of:

– authenticating the User;

– where applicable, linking the Authorised User’s account with the Client’s Odaring for Business account or tracking the Authorised User’s business profile bookings on the Apps, as the case may be;

– where applicable, verifying the Corporate Billing status of such Authorised User from time to time; and

– contacting the User in accordance with the purposes set out in the Odaring Privacy Notice .

Upon onboarding such User to the App, Odaring will process the Personal Data of the User in accordance with the Odaring Privacy Notice and this Addendum.

What Odaring discloses to its Clients

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

What Odaring 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 Odaring 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 Authorised Users;

– obtain the necessary consents (if applicable) to facilitate the provision of the Odaring for Business feature; and

– implement appropriate legal, technical and organisational measures to protect Personal Data against unauthorised or unlawful processing and against unauthorised loss, destruction, damage, alteration, or disclosure, as well as any breach or attempted breach of each party’s security measures (“Information Security Incident”).