This Privacy Policy and its Addenda (“Privacy Policy”) explain how the AIZEN group of companies, each of its subsidiaries, affiliates, related companies, and jointly controlled entities, collectively referred to as “AIZEN,” “we,” “us,” or “our,” collect, use, process, and disclose your Personal Data through your use of AIZEN’s mobile applications and websites, respectively referred to as the “Application” and “Website,” as well as other products, features, and services operated by AIZEN, collectively referred to as the “Services.”
This Privacy Policy applies to our consumers and partners, such as dealer partners, acquisition affiliate partners, vehicle owner partners, and vehicle manufacturer partners, collectively referred to as “you” or “your.”
“Personal Data” means any information that can be used to identify you or from which you can be identified. This includes, but is not limited to, your name, phone number, email address, image, government-issued identification number, biometric data, date of birth, marital status, employment information, and financial information.
We specifically collect, use, disclose, or process your Personal Data in accordance with this Privacy Policy with your consent, or in accordance with applicable law, such as where:
We are required to comply with legal requirements;
We are required to enter into or perform a contract with you; and/or
For our legitimate interests or the legitimate interests of others, including but not limited to the purposes set out in this Privacy Policy.
I. Collection of Personal Data
We collect, and may combine, Personal Data about you in the ways listed below:
You provide your Personal Data to us
We collect your Personal Data when you provide it to us. For example, when you:
Complete a user profile or registration form, such as your name, contact information, and other identification information where required;
Provide information to assess your eligibility to provide services as a dealer partner, acquisition affiliate, lender, or vehicle manufacturer, such as business legality information, organizational structure, and financial information;
Interact with our social media pages, such as your social media account ID, profile photo, and other publicly available data;
Participate in contests or events organized by us, such as images, audio, or videos that you submit, which may include your image;
Verify your identity through various means, such as social media login, submission of your image, or independently verified payment card information;
Fill in demographic information in surveys, such as age, gender, and other information that you may voluntarily provide, including marital status, occupation, and income information; and
When our Services are used
Personal Data may be collected through the normal operation or use of our Application, Website, and Services. Some examples include:
Your location information;
Feedback, ratings, and rewards;
Transaction information, such as payment methods;
Information about how you interact with our Application, Website, or Services, such as features used and content viewed;
Device information, such as hardware model and serial number, IP address, file and application names and versions, GPS location, IMEI number, advertising identifiers, or any information that may indicate modifications to the device or application;
Telematics data, such as mileage, battery replacement, engine ignition, speed, acceleration, and braking;
We work with partners to install telematics devices in rental vehicles for the following purposes:
To ensure that vehicles are properly maintained and serviced on time;
To help maintain your safety and the security of the vehicle;
To improve and enhance our Services; and
For internal vehicle tracking, analysis, and administrative purposes.
These partners own and share such telematics data with us.
Our partners are also contractually obligated to protect this data.
Personal data that you enter in messages when you use the communication features in our application; and
Personal data that may be obtained through your interactions with us or our agents.
From other sourcese
We may collect Personal Data, including but not limited to your name, contact information, and other identification information where required, from other sources. These sources include:
Credit bureaus, alternative credit scoring agencies, and other credit reporting organizations;
Referral programs;
Our business partners, such as payment providers, identity verification providers, digital signature providers, and insurance providers;
Publicly available or government data sources;
When our users add you as an emergency contact;
When you use our in-app chat; and
Marketing service providers or partners.
Sensitive Personal Data
Some Personal Data that we collect may be sensitive. This may include Personal Data relating to national identity information, religious beliefs, background information, including financial and criminal records where legally permitted, marital status, and biometric data, as applicable. We collect sensitive Personal Data only with your consent and/or in accordance with applicable law. If you are requested to provide any documentation or information to us for any Purpose that may contain such sensitive Personal Data, which is not required for that Purpose, you agree to redact such sensitive Personal Data before providing the documentation or information to us.
When you provide us with the Personal Data of another individual
In some situations, you may provide us with the Personal Data of other people, such as your spouse, family members, or friends. For example, you may add them as your emergency contact, or when you use in-app chat. If you provide their Personal Data to us, 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 Privacy Policy.
II. Use of Personal Data
AIZEN may use your Personal Data for the following purposes set out in the list below (“Purposes”). In addition, if you use AIZEN in multiple capacities, for example if you use several AIZEN Services, we may link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below.
Providing Services and features
Your Personal Data will be used to provide, personalize, maintain, and improve our Application, Website, and Services. This includes using your Personal Data to:
Process, manage, or verify your eligibility for or application to Services, promotions, rewards, and subscriptions with AIZEN;
Verify your identity;
Conduct due diligence checks and risk assessments/analysis;
Offer, obtain, provide, facilitate, or maintain insurance, financial, and payment solutions;
Engage with you to provide Services to you across our various business verticals;
Create, manage, and update your account;
Process payments;
Detect abnormal trip variations;
Personalize your Application experience, such as recommending relevant products and services to you, identifying your preferences, or personalizing your experience with AIZEN;
Make your experience smoother, such as automatically filling in your registration information, such as your name or phone number, from one Service to another or when you participate in our surveys;
Carry out internal operations necessary to provide our Services, including troubleshooting software bugs and operational issues, conducting data analysis, testing and research, and monitoring and analyzing usage and activity trends;
Protect the security or integrity of the Services and any facilities or equipment used to provide the Services;
Enable communication between our users;
Invite you to participate in our surveys and studies;
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 AIZEN;
Using device, location, profile, usage, and other Personal Data to prevent, detect, and combat fraud or unsafe activities;
Identifying unsafe driving behavior, such as speeding, harsh braking, and harsh acceleration, and providing personalized responses;
Monitoring compliance with our terms and conditions and policies.
User Support
We use Personal Data to resolve user support issues. For example, we may:
Investigate and address issues;
Monitor and improve our user support responses;
Respond to questions, comments, and feedback; and
Notify you of the steps taken to resolve user support issues.
Research and development and security
We may use the Personal Data that we collect for testing, research, analysis, and product development. This enables us to understand and analyze your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, and develop new features, products, and services.
Legal purposes
We may use the Personal Data that we collect for legal purposes, such as to investigate and resolve claims or disputes, detect/prevent/prosecute criminal acts, or as permitted or required by applicable law. We may also use your Personal Data when we are requested, advised, recommended, expected, or required to do so by our legal advisors or by legal, regulatory, governmental, or other local or foreign authorities.
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.
Marketing and promotions
We may use your Personal Data to send you marketing communications relating to customized products or services, which may be interesting or relevant based on your profile, or products, services, events, or promotions from partners, sponsors, and advertisers. For example, we may:
Send you special offers that may be interesting or relevant to you;
Send you alerts, newsletters, updates, letters, promotional materials, privileges, and holiday greetings; and
Notify, invite, and manage your participation in our events or activities.
We may communicate such marketing to you in various ways, where applicable, including through SMS, chat applications such as WhatsApp, Telegram, and LINE, in-app notifications, phone calls, and email.
If you wish to unsubscribe from receiving such marketing communications, please click the unsubscribe link in the relevant email or message. Please note that even if you opt out of marketing or promotional communications, AIZEN may still send you service-related messages, such as information about your transactions, rewards, and so on.
User-Published Content
If you publish content, such as reviews or comments, on the AIZEN platform, that content will be displayed publicly together with your personal data, such as your profile name and uploaded photo(s), as well as other information that you choose to include in your content.
We use vehicle telematics data, including mileage, battery usage, and charging records, to calculate, verify, and register Environmental Credits generated from your use of the leased vehicle, and to support AIZEN's registration of such credits with the relevant domestic or international registry.
III. Disclosure of Personal Data
We need to share Personal Data with various parties for the Purposes. These parties include:
With AIZEN service providers and partners
We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:
Credit bureaus, alternative credit scoring agencies, and other credit reporting organizations;
Service providers that perform identity verification and digital signature services;
Payment processors and facilitators;
Dealer partners and acquisition affiliate partners;
Vehicle owner partners;
Insurance partners;
Debt collectors;
Background check and anti-money laundering service providers;
Cloud storage providers;
Advertising and marketing partners and platform providers;
Vehicle solution partners, vendors, or third-party vehicle suppliers;
Data analytics providers;
Research partners, including those conducting surveys or research projects in partnership with AIZEN or on behalf of AIZEN.
With subsidiaries and affiliates
We share Personal Data with our subsidiaries, related companies, jointly controlled entities, and affiliates. Companies within the AIZEN group share resources, such as infrastructure and technology, with one another to provide you with a consistent, relevant, and secure experience when you use our Services, and for the Purposes set out in this Privacy Policy.
For example, we do this to make your experience smoother, such as by automatically completing your registration information from your use of one AIZEN Service when you register for a new AIZEN Service.
With our legal advisors and government authorities
We may share your Personal Data with our legal advisors, law enforcement officials, government authorities, and other third parties. This may occur to fulfill legal purposes, as mentioned above, or in any of the following circumstances:
If required to respond to an emergency that threatens a person’s life, health, or safety; or
If required in the public interest, for example during a public health crisis, for contact tracing purposes and to protect our community.
Business transfers
We may share your Personal Data with other parties in connection with an acquisition, sale, merger, joint venture, consolidation, restructuring, financing, or other type of business transaction. However, your Personal Data will remain subject to our obligations under the pre-existing Privacy Policy that you have agreed to.
IV. Retention of Personal Data
We retain your Personal Data for the period necessary to fulfill the Purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Once your Personal Data is no longer required for the Services or Purposes, or we no longer have a legal or business purpose to retain your Personal Data, we take steps to delete, destroy, anonymize, or prevent access to or use of such Personal Data for any purpose other than in accordance with compliance with this Privacy Policy, or for safety, security, fraud prevention, and fraud detection purposes, in accordance with applicable legal requirements.
V. Cookies and advertisements on third-party platforms
Cookies
AIZEN, and third parties that partner with us, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers, and similar technologies, collectively referred to as “Cookies,” in connection with your use of the Website and Application, which may persist or may only be stored during an individual session in your browser or device.
Cookies may have unique identifiers and may be located, among other places, on your computer or mobile device, in emails that we send to you, and on our web pages. Cookies may be used for various purposes, such as:
Providing basic and essential functions for the use of our Website, Services, or Application;
Authenticating you, or remembering your user preferences and settings;
Delivering and measuring the effectiveness of advertising campaigns, such as by measuring the number of views or click-throughs;
Analyzing site traffic and trends;
Serving relevant advertisements to you on other applications and websites owned by other companies, whether by us or other advertisers; and
Improving the user interface and experience by generally understanding the online behavior and interests of users who interact with our Website, Services, or Application.
Disabling the collection of cookies on our website
You have the right to choose to disable, block, or deactivate cookies. Please note that refusing or deleting certain cookies may affect the availability, functionality, or use of our Website, Services, or Application.
You may adjust your internet browser settings to disable, block, or deactivate cookies, delete your browsing history, or clear your internet browser cache. The settings may be located in the “History,” “Preferences,” “Settings,” or “Privacy” sections of your internet browser, or you may consult your internet browser’s help section for more information.
Disabling the display of targeted advertisements on other platforms
We may facilitate the display of targeted advertisements on other platforms, such as other online platforms that you may use.
You may be able to limit our use of your Personal Data to display targeted advertisements on behalf of our advertisers by adjusting your preferences through the Application. Depending on the type of phone and operating software you use, you may be given the option to disable our use of mobile identifiers, such as Apple’s IDFA or Google’s GAID, and the ability to track you across applications and websites owned by other companies by adjusting the settings available on your mobile device. By adjusting the settings on your device, you can generally reset, delete, limit, and/or restrict the use of such mobile identifiers.
Although we will not use your Personal Data to display such targeted advertisements on other platforms, you may still see general advertisements that appear relevant to you. This may be because we have engaged third-party advertisers/platforms to display advertisements to users with certain attributes or demographic compositions who may find them relevant. You may be able to limit your viewing of these advertisements by managing your preferences on those platforms.
VI. Protection of Personal Data
We will take reasonable legal, organizational, and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from being lost, or used or accessed in an unauthorized manner. We limit access to your Personal Data only to our employees on a need-to-know basis. Those who process your Personal Data will only do so in an authorized manner and are required to maintain the confidentiality of your information.
Nevertheless, please understand that the transmission of information through 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 Regarding Your Personal Data
In accordance with applicable laws and regulations, you may have the right to:
Inquire about the processing of your Personal Data and be provided with a copy of it;
In certain cases, request the correction and/or deletion of your Personal Data;
In certain cases, request the restriction of or object to the processing of your Personal Data;
Withdraw your consent to the processing of your Personal Data, where we process your Personal Data based on your consent;
Request the receipt or transmission to another organization, in a machine-readable format, of the Personal Data that you have provided to us where we use your Personal Data based on consent or the performance of a contract; and
File a complaint with the relevant data privacy authority if your data privacy rights are violated, or if you suffer loss as a result of the unlawful processing of your Personal Data.
If you are given the option to share your Personal Data with us, you may always choose not to do so. If we have requested your consent to process your Personal Data 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, withdrawing your consent for our use of such data, or your agreement to our Privacy Policy may mean that we are unable to take the actions necessary to achieve the processing purposes described in Section II, “Use of Personal Data,” or that you are unable to use the Application or Services.
After you choose to withdraw your consent, we may continue to process your Personal Data to the extent necessary or permitted by applicable laws and regulations.
We will screen and verify all requests beforehand. To verify your identity and/or authority to make a request, we may ask you to provide supporting information or documentation to substantiate the request. Once verified, we will implement your request within the timeframe specified by applicable law.
VIII. Changes and Updates
AIZEN may modify, update, or change the terms of this Privacy Policy at any time. Such changes will be notified to you through the Application and/or other appropriate means at least five (5) business days before the effective date. The latest version will be posted on the website https://www.aizenmobility.com. You are responsible for reviewing the Privacy Policy regularly. If you continue to use the Application, Website, or Services or continue to communicate or engage with AIZEN after the effective date of any modification, update, or change to this Privacy Policy, whether reviewed by you or not, this constitutes your agreement to be bound by the amendment.
