Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CLICKING OR CHECKING "SIGN UP", "I AGREE TO VROOM'S PRIVACY POLICY", "I AGREE AND CONSENT TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND/OR PROCESSING OF MY PERSONAL DATA FOR THE PURPOSE STATED IN, AND UNDER THE TERMS OF, VROOM'S PRIVACY POLICY" OR SIMILAR STATEMENTS AVAILABLE AT THE VROOM REGISTRATION PAGE OR IN THE COURSE OF PROVIDING YOU WITH THE SERVICES OR ACCESS TO THE WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THE TERMS OF THIS PRIVACY POLICY AND THAT YOU HAVE AGREED AND CONSENTED TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND/OR PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED AND UNDER THE TERMS HEREIN.

1. Introduction to this Privacy Policy

1.1. Vroom and its affiliates (collectively or individually, "Vroom", "we" or "us") take your privacy seriously.

1.2. In the course of providing you with the Services or access to the Website (as defined in the Terms of Use), we will be collecting, using, disclosing, storing and/or processing data, including your personal data.

1.3. This Privacy Policy exists to keep you in the know about how we collect, use, disclose, store and/or process the data we collect and receive during the course of providing the Services or access to the Website to you, our user, whether you are using our Website as a buyer or a seller. We will only collect, use, disclose, store and/or process your personal data in accordance with this Privacy Policy.

1.4. It is important that you read this Privacy Policy together with any other applicable notices we may provide on specific occasions when we are collecting, using, disclosing and/or processing personal data about you, so that you are fully aware of how and why we are using your personal data.

1.5. We may update this Privacy Policy from time to time. Any changes we make to this Privacy Policy in the future will be reflected on this page and material changes will be notified to you. Where permissible under local laws, your continued use of the Services, access to the Website or use of the Services (as defined in the Terms of Use) on the Website, or express consent thereto, shall constitute your acknowledgment and acceptance of the changes we make to this Privacy Policy. You agree that it is your responsibility to check back frequently to see any updates or changes to this Privacy Policy.

1.6. This Privacy Policy applies in conjunction with other notices, contractual clauses and consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override them unless we state expressly otherwise.

1.7. All of these terms apply to Vroom's users, unless stated specifically.

2. The Personal Data We Collect From You

2.1. Personal data means any information about an individual, whether recorded in a material form or not and whether true or not, who can be identified from that data (whether directly or indirectly), or from that data and other data to which we have or are likely to have access.

2.2. During the course of your use of the Website and the provision of the Services, we may collect personal data about you, as follows:

(i) Identity data, such as your name, gender, and date of birth;

(ii) Contact data, such as billing address, delivery address, email address and phone numbers;

(iii) Account data, such as bank account details, bank statements, credit card details and payment details (such account data may also be collected directly by our affiliates and/or third party payment service providers);

(iv) Transaction data, such as details about quotations and payments, and other details of products and Services related to you;

(v) Technical data, such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, cookies (where applicable) and other information and technology on the devices you use to access the Website;

(vi) Profile data, such as your username and password, your interests, preferences, feedback and survey responses;

(vii) Usage data, such as information on how you use the Website, products and Services or view any content on the Website, including the time spent on the Website, items and data searched for on the Website, access times and dates, as well as websites you were visiting before you came to the Website and other similar statistics;

(viii) Location data, such as when you capture and share your location with us in the form of photographs or videos and upload such content to the Website;

(ix) Marketing and communications data, such as your preferences in receiving marketing from us and our third parties, your communication preferences and your chat, email or call history on the Website or with third party customer service providers; and

(x) Additional information we may request you to submit for loan application or due diligence checks as required for identity verification (such as copies of government issued identification, e.g. passport, ID cards, company registration documents etc.) or if we believe you are violating our Privacy Policy or our Terms of Use.

How we receive your personal data

2.3. During the course of your use of the Website and our provision of the Services, we may receive personal data from you in the situations, as follows:

(a) When you browse our website;

(b) When you create an account with us;

(c) When you apply for, subscribe to or otherwise use any of the Services;

(d) When you generate a quotation regarding the Vehicles available on the Website;

(e) When you activate or use any payment-related functions available on the Website or provided by our third party service providers;

(f) When you use any of the features, functions available on the Website or Services;

(g) When you use the WhatsApp chat function on the Website;

(h) When you subscribe to our publications or marketing collaterals;

(i) When you enter a competition, promotion or survey;

(j) When you participate in any activity or campaign on the Website; and

(k) When you log in to your account on the Website or otherwise interact with us via an external service or application, such as Facebook or Google;

2.4. We may collect personal data from you, third parties (including but not limited to agents, vendors, contractors, partners and any others who provide services to us, who collect your personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial providers, credit bureaus, delivery, marketing and other service partners), our affiliates, or such data may be collected automatically when you use the Website or the Services, as set out in this section. See also Section 10 below on the collection of computer data.

2.5. Where we collect personal data from third parties and/or our affiliates, we will only collect your personal data, where permitted by law, for or in connection with the purposes for which those third parties or our affiliates are engaged, for the purposes of our collaboration with the third parties or affiliates, or for the requirement to carry out verification or due diligence checks. During the course of your use of the Website and our provision of the Services, you agree that you have provided your consent (whether to us, the third party or our affiliates) to the transfer of your personal data from third parties and/or our affiliates to Vroom for the purposes set out in this Privacy Policy or any other terms.

2.6. You must only submit personal data which is accurate and not misleading and you must keep it up to date and inform us of any changes to the personal data you have provided to us. We shall have the right to request for documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law.

2.7. We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to us or as otherwise provided for under this Privacy Policy. If you choose not to provide your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with certain features or functionality on the Services or access to the Website.

2.8. If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent, license and permissions from that third party to share and transfer his/her personal data to us, and for us to collect, store, use and disclose that data in accordance with this Privacy Policy.

2.9. If you sign up to be a user on our Website using your social media account or link your Vroom account to your social media account or use certain other Vroom social media features, we may access personal data about you which you have voluntarily provided to your social media provider in accordance with the provider's policies and we will manage your personal data in accordance with this Privacy Policy.

3. Use and Disclosure of Your Personal Data

Purpose of Use

3.1. The personal data we collect from you or via third parties may be used for certain purposes, as follows:

(i) Processing your order for Vehicles

(ii) Providing Services

(iii) Marketing and advertising

(iv) Legal and operational purposes

(v) Analytics, research, business and development

(vi) Other

3.2. We may share (or permit the sharing of) your personal data with and/or transfer your personal data to third parties and/or our affiliates for the above-mentioned purposes. These third parties and affiliates, which may be located inside or outside your jurisdiction, include but are not limited to:

(i) Service providers (such as agents, vendors, contractors and partners) in areas such as payment services, logistics and shipping, marketing, data analytics, market or consumer research, survey, social media, customer service, installation services, information technology and website hosting;

(ii) Their service providers and related companies; and

(iii) Other users of the Website or Services.

3.3. In disclosing your personal data to them, we endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed to achieve the above-mentioned purposes.

3.4. We may also share personal data in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we satisfy the requirements of applicable data protection law when disclosing your personal data.

International data transfer

3.5. We may transfer or permit the transfer of your personal data outside of your jurisdiction for any of the purposes set out in this Privacy Policy. However, we will not transfer or permit any of your personal data to be transferred outside of such jurisdiction unless the transfer is in compliance with applicable laws.

Third party services

3.6. We may share your personal data with our third party service providers or affiliates (e.g. payment service providers) in order for them to offer services to you other than those related to your use of the Website or our Services. Your acceptance and use of the third party service provider's or our affiliate's services shall be subject to terms and conditions as may be agreed between you and the third party service provider or our affiliate. Upon your acceptance of the third party service provider's or our affiliate's service offering, the collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any data disclosed by us to such third party service provider or affiliate) shall be subject to the applicable privacy policy of the third party service provider or our affiliate, which shall be the data controller of such data. You agree that any queries or complaints relating to your acceptance or use of the third party service provider's or our affiliate's services shall be directed to the party named in the applicable privacy policy.

4. Withdrawal of Consent to Continued Use, Disclosure, Storing and/or Processing of Personal Data

4.1. You may communicate the withdrawal of your consent to the continued use, disclosure, storing and/or processing of your personal data by contacting us using the contact details below, subject to the conditions and/or limitations imposed by applicable laws or regulations.

4.2. Please note that if you communicate your withdrawal of your consent to our use, disclosure, storing or processing of your personal data for the purposes and in the manner as stated above or exercise your other rights as available under applicable local laws, we may not be in a position to continue to provide the Services to you or perform any contract we have with you, and we will not be liable in the event that we do not continue to provide the Services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.

Marketing information

4.3. You may unsubscribe from receiving marketing information at any time in our mobile application settings or by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies.

5. Updating Your Personal Data

5.1. It is important that the personal data you provide to us is accurate and complete for you to continue using the Website and for us to provide the Services. You are responsible for informing us of changes to your personal data, or in the event you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of date.

5.2. You can update your personal data anytime by accessing your account on the Website.

5.3. We take steps to share the updates to your personal data with third parties and our affiliates with whom we have shared your personal data if your personal data is still necessary for the above-stated purposes.

6. Accessing and Correcting Your Personal Data

6.1. You may request information about your personal data which we have collected, or enquire about the ways in which your personal data may have been used, disclosed, stored or processed by us via the personal account information setting on our Website or by contacting us using the contact details below. You may also request correction of any error or omission in your personal data which we have collected in the same way. In order to facilitate processing of your request, it may be necessary for us to request further information relating to your request. Where permissible under law, we may refuse such correction requests if deemed vexatious or unreasonable.

6.2. Where permitted by applicable data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, we will inform you of the fee before processing your request.

7. Security of Your Personal Data

7.1. To safeguard your personal data from unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification or similar risks, we have introduced appropriate administrative, physical and technical measures such as:

(a) Restricting access to personal data to individuals who require access;

(b) Maintaining technology products to prevent unauthorised computer access;

(c) Using encryption technology when processing your financial details; and/or

(d) implementing other security measures as required by applicable law.

7.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

8. Retention of Personal Data

8.1. We will only retain your personal data for as long as we are either required or permitted to by law or as relevant for the purposes for which it was collected.

8.2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected, and is no longer necessary for any legal or business purpose.

9. Minors

9.1. Vroom does not sell to minors (which is to be determined based on the applicable law), nor does it intend to provide any of the Services or the use of the Website to minors. We do not knowingly collect any personal data relating to minors.

9.2. You hereby confirm and warrant that you are above the age of minority and you are capable of understanding and accepting the terms of this Privacy Policy. If you are a minor, you may use our Website only with the involvement of a parent or legal guardian.

9.3. As a parent or legal guardian, please do not allow minors under your care to submit personal data to Vroom. In the event that such personal data of a minor is disclosed to Vroom, you hereby consent to the processing of the minor's personal data and accept and agree to be bound by this Privacy Policy and take responsibility for his or her actions.

9.4. We will not be responsible for any unauthorised use of the Services on the Website by yourself, users who act on your behalf or any unauthorised users. It is your responsibility to make your own informed decisions about the use of the Services on the Website and take necessary steps to prevent any misuse of the Services on the Website.

10. Collection of Computer Data

10.1. We or our authorised service providers may use cookies, web beacons, and other similar technologies in connection with your use of the Services or access of the Website.

10.2. When you visit the Website through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website, such as the technical data and usage data outlined in Section 2 above.

10.3. This data is collected for analysis and evaluation in order to help us improve our website and the services and products we provide, as well as to help us to personalise the content to match your preferred interests more quickly. The data is also collected to make the Services and the Website more convenient and useful to you, and to provide more relevant advertising related to market products, services and features to you.

10.4. Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognise a particular device or browser. Web beacons are small graphic images that may be included on our Services and the Website. They allow us to count users who have viewed these pages so that we can better understand your preference and interests.

10.5. You may be able to manage and delete cookies through your browser or device settings. However, certain cookies are required to enable core functionality (such as adding items to your shopping basket), so please note that changing and deleting cookies may affect the functionality available on the Website or through our Services.

11. Third Party Sites

11.1. The Website may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.

12. Questions, Feedback, Concerns, Suggestions or Complaints

12.1. If you have any questions on personal data protection or data privacy, please write to us at "vroom email" or call "office number".