We collect Personal Data about you in the ways listed 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 or any details during registration of any User (such as your name, contact information and other identification information where needed);∙ 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); and

  ∙ Making any purchase or subscribe any products by using our Website and/or Services.

  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.

• When our services are used
  Personal Data may be collected through the normal operation of our Website, 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 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 website communication features; and

  ∙ personal data that may be captured through your interaction with us or our agents, (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, payment providers and merchant;

  ∙ insurance and financial providers;

  ∙ credit bureaus and other credit reporting agencies;

  ∙ publicly available sources of data;

  ∙ governmental sources of data;

  ∙ when our users add you as an emergency contact; and

  ∙ marketing services providers or partners.

• 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.
• When you provide Personal Data of other individuals to us
  In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may add them as your emergency contact. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Policy.
• Personal Data of minors
  As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to Startrick. In the event that such Personal Data of a minor is disclosed to Startrick, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Policy and take responsibility for his or her actions.
• When you provide Personal Data of other individuals to us
  In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may add them as your emergency contact. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Policy.

Startrick 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 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;

  ∙ verify your identity;

  ∙ verify your age (where necessary);

  ∙ validate your purchase and process payments;

  ∙ offer, obtain, provide, facilitate or maintain insurance or financing solutions; ∙ track the progress of your order and delivery;

  ∙ 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 (if any);

  ∙ enable communications between our users;

  ∙ process, manage or verify your application of promotions, rewards and subscriptions with us; 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 we provide 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:∙ verifying your identity when you log in to the Application;∙ 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 and policies; and ∙ detecting, preventing and prosecuting crime.

• Customer support
  We use Personal Data to resolve customer support issues. For example, we may:∙ investigate and address concerns;∙ monitor and improve our customer support responses;

  ∙ respond to questions, comments and feedback; and

  ∙ inform you about steps taken to resolve customer support issues.

• Research and development and security
  We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and 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 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 Startrick and Startrick’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 use our in-app chat service, we may share your mobile number and registered name with the other parties to your chat.
• With Startrick partners at your request
  For example, if you requested a service through a Startrick partner or used a promotion provided by an Startrick partner, we may share your Personal Data with that Startrick partner. Our partners include partners that integrate with our App or our App integrates with, vehicle services partners, or business partners which we collaborate 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 Startrick’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 and other credit reporting agencies;

  ∙ 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 us or on our behalf;

  ∙ 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

  ∙ delivery partners or vendors.

• 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:where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or
  where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).
• Retention of Personal Data
  We retain your Personal Data for the period necessary to fulfil 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, anonymise 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.
• International Transfers of Personal Data
  Your Personal Data may be transferred from country, state and city (“Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”).When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

  Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.

• Cookies and Advertising on Third Party Platforms
  Startrick, 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 Website. 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.Startrick may allow third parties to use Cookies on the Websites and Website to collect the same type of Personal Data for the same purposes Startrick 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 on third party platforms.

  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.