1.1. Vroom and its affiliates (collectively or individually, "Vroom", "we" or "us") take your privacy seriously.
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
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.
2.6. 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.
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
- To generate quotation you requested through the Website;
- To submit your application for loan facilities you have provided through the Website. We may pass you personal information on to a third party (e.g. financial institutions) in order to apply for a loan;
- To update you on the status;
- To provide customer support for your orders; and
- To verify and carry out payment transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to you and/or Services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers.
(ii) Providing Services
- To facilitate your use of the Services or access to the Website;
- To administer your account (if any) with us;
- To respond to your queries, feedback, claims or disputes, whether directly or through our third party service providers; and
- To assess your application for loan facilities and/or to perform credit risk assessments in relation to application for financing services (where applicable);
(iii) Marketing and advertising
- To provide you with information we think you may find useful or which you have requested from us (provided you have opted to receive such information);
- To send you marketing or promotional information about our or third-party sellers' products and service on our Website from time to time (provided you have opted to receive such information); and
- To help us conduct marketing and advertising.
(iv) Legal and operational purposes
- To ascertain your identity in connection with fraud detection purposes;
- To compare information, and verify with third parties in order to ensure that the information is accurate;
- To process any complaints, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Website;
- To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
- To store, host, back up your personal data;
- To perform due diligence checks;
- To comply with legal and regulatory requirements (including, where applicable, the display of your name contact details and company details), including any law enforcement requests, in connection with any legal proceedings, or otherwise deemed necessary by us; and
- Where necessary to prevent a threat to life, health or safety.
(v) Analytics, research, business and development
- To understand your user experience with the Services and the Website;
- To improve the layout or content of the pages of the Website and customise them for users;
- To identify visitors on the Website;
- To conduct surveys, including carrying out research on our users' demographics and behaviour;
- To improve our current technology (e.g. voice recognition tech, etc) via machine learning or other means;
- To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
- To conduct data analysis, testing and research, monitoring and analysing usage and activity trends;
- To further develop our products and services; and
- To know our buyers better.
- Any other purpose to which your consent has been obtained; and
- To conduct automated decision-making processes in accordance with any of the above purposes.
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
Third party services
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.
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.
9.1. 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.
9.4. 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
10.2. 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".