Effective from: 30 July 2021
This Privacy Notice and its Addendum(s) (“Notice”) describe how Beblu Pte Ltd, its respective subsidiaries, affiliates, or associated companies (collectively “Beblu”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of Beblu’s mobile application and website (respectively “App” and “Website”), as well as products, features and other services globally, operated or represented by Beblu (collectively, “Services”).
This Notice applies to our users, agents, vendors, suppliers, partners (such as gym & wellness trainers), contractors and service providers (collectively “you”, “your” or “yours”).
“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information.
I. COLLECTION OF PERSONAL DATA
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 to facilitate your use of our facilities and 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 obtain services (such as season parking slots) as a registered member of Beblu (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 App, Website and Services. Some examples are:
your location of services (to detect location of the venue which you have opted for gym/wellness class or EV charging);
feedback, ratings and compliments;
transaction information (such as payment method);
personal data you enter in messages when you use our in-app communication features
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:
our business partners, such as fleet partners and payment providers;
publicly available sources of data;
governmental sources of data;
when our users add you as an emergency contact oe as a registered member/licensee of a designated office unit
when you use our in-app chat; 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 will 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 Beblu. In the event that such Personal Data of a minor is disclosed to Beblu, 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, friends, employees) to us. For example, you may add them as;
your emergency contact
a registered member/licensee of the designated office unit
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 Policy.
II. USE OF PERSONAL DATA
Beblu 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 App, Website and Services. This includes using your Personal Data to:
provide you with Services listed in our App;
create, administer and update your account;
verify your identity;
validate your purchases and process payments;
enable features that personalise your App, such as listing of your favourite trainer;
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 and Beblu;
process, manage or verify your eligibility for or application of season car parking slots with Beblu;
engage you to provide Services;
conduct due diligence checks and risk assessments/analysis;
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 Beblu 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:
verifying your identity when you log in to Beblu’s App;
using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
detecting, preventing and prosecuting crime.
Issues and Concerns
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 & 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.
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.
Marketing and Promotions
We may use your Personal Data to market Beblu and Beblu’s partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:
send you notice 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, you may also update your preferences in our App settings or write to us at email@example.com.
III. DISCLOSURE OF PERSONAL DATA
We need to share Personal Data with various parties for the Purposes. These parties include:
With Beblu partners at your request
For example, if you requested a service through a Beblu partner or used a promotion provided by a Beblu partner, Beblu may share your Personal Data with that Beblu partner. Our partners include partners that integrate with our App or our App integrates with business partners which Beblu collaborates with to deliver a promotion, competition or other specialised service.
With Beblu’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;
marketing partners and marketing platform providers;
data analytics providers;
research partners, including those performing surveys or research projects in partnership with Beblu or on Beblu’s behalf;
fleet and merchant partners
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).
IV. RETENTION OF PERSONAL DATA
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 deactivate, 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.
VI. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS
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.
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 website
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.
VII. PROTECTION OF PERSONAL DATA
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.
VIII. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
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 (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.
IX. AMENDMENTS AND UPDATES
Beblu 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 seven (07) business days before the effective date. The updated version will be posted on the website http://www.beblu.com and our App. It is your responsibility to review the Privacy Notice regularly. Your continued use of the App, Website or Services, purchase products from Beblu or continuing to communicate or engage with Beblu 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.
X. CONTACT US
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:
Beblu Data Protection Officer
c/o Beblu Pte Ltd
7 Harvey Road,
The original of this Notice is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.
ADDENDUM 1: Registered Members for Office Spaces
This Addendum forms part of Beblu’s Privacy Notice. In the event of any inconsistency between Beblu’s Privacy Notice and this Addendum, this Addendum shall prevail.
II. BEBLU’S RELATIONSHIP WITH USERS AND CLIENTS
When an organisation (“Client”) endorses a tenancy or license agreement for use of Beblu’s designated office space, the Super Admin user shall provide a list of Admin users to Beblu for user account creation for the App prior to commencement of occupancy of the office unit. A Super Admin is referred to in Beblu’s Privacy Notice as the authorised representative of the Client.
For ease of reference, Super Admin users and Admin users will each be referred to as a “User” and collectively as “Users” in this Addendum.
Beblu 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), Beblu acts as a data controller. For further information on how Beblu collects, uses and discloses Users’ Personal Data, please refer to the Beblu Privacy Notice .
Beblu does not process any Personal Data for and on behalf of the Client. Accordingly, Beblu 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 Services and features of the App and Website.
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 Beblu.
III. WHAT PERSONAL DATA IS COLLECTED, PROCESSED AND DISCLOSED
What Beblu collects from Clients
Prior to commencement of license agreement usage of the designated office unit, the Client or the Super Admin user will be required to provide the following information of Admin user to Beblu:
business email address; and
other identifying information about the user as reasonably requested by Beblu.
Beblu will use this information for the purposes of:
authenticating the User;
Setting the access rights for user entry to designated location(s) of the building;
where applicable, sending of Corporate Billing invoices to the Client or the Super Admin User from time to time; and
contacting the User in accordance with the purposes set out in the Beblu Privacy Notice .
Upon onboarding such a User to the App, Beblu will process the Personal Data of the User in accordance with the Beblu Privacy Notice and this Addendum.
What Beblu discloses to its Clients
Beblu will disclose the tax invoices incurred for the month to the Client or the Super Admin user for Corporate Billing.
What Beblu discloses to its individual user
Admin users may have certain restricted access depending on the settings and access rights selected by the Super Admin user.
IV. PARTIES’ OBLIGATIONS
The Client and Beblu 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 Super Admin Users;
obtain the necessary consents (if applicable) to facilitate the provision of the Beblu App Account; 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”)