Privacy and Data Safety (last update 08-Aug-2023)

This Privacy Notice (“Privacy Notice”) describe about how PassApp Technologies Co., Ltd (collectively “PassApp”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of PassApp’s mobile applications (respectively “App”, “Apps”).

This Privacy Notice applies to our customers, partners (such as drivers) (collectively “you”, “your” or “yours”).

The service offers by our partner drivers (respectively “service”, “services”).

“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, telephone number, bank and credit card details, email, address, your image.

We typically collect, use, disclose or otherwise process your Personal Data in accordance with this Privacy Notice with your consent, or in compliance with applicable laws, such as where:

• it is required for us to comply with legal requirements
• it is required for us to enter into or perform a contract with you

1. COLLECTION OF PERSONAL DATA

We collect (and may combine) Personal Data about you in the ways listed below:

1. 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 forms (such as your name, contact information and other identification information where needed)
• provide information to assess your eligibility to provide services as a driver (such as your driver’s license information, vehicle information and background check results)

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2. When Services are used

Personal Data may be collected through the normal operation or use the service from our Apps which is offer from our driver. Some examples are:

• your location information
• feedback, ratings and compliments
• transaction information (such as payment method
• device information (such as hardware model and serial number, IP addresses), file and app names and versions, GPS location, IMEI number, or any information that may indicate device or app modification)
• personal data you enter in messages when you use our in-app communication features

Do note that some drivers may install personal in-vehicle applications or devices in their vehicles for their own purposes, which may result in your Personal Data being captured by them during on ride with the driver. This practice is not endorsed nor prohibited by PassApp, and the collection, use and disclosure of Personal Data obtained from personal in-vehicle applications or devices is the responsibility of the relevant driver. Please check with the relevant driver if you have any quires about their use of personal in-vehicle applications or devices.

Sensitive Personal Data

Some of the Personal Data that we collect may be sensitive in nature. This may include Personal Data pertaining to your race, national ID information. We collect sensitive Personal Data only with your consent and/or in strict compliance with applicable laws. In the event that you are required to furnish any documentation or information to us for any Purpose which may contain such sensitive Personal Data (which is not required for that Purpose), you agree to redact such sensitive Personal Data before providing such documentation or information to us.

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2. 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 Privacy Notice.

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2. Personal Data of minors

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to PassApp. In the event that such Personal Data of a minor is disclosed to PassApp, 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.

2. USE OF PERSONAL DATA

PassApp may use your Personal Data for the following purposes set out in the list below (“Purposes”) described below:      

Get service

Your Personal Data will be used to get the service:

• During Booking the service:
  • Customer’s GPS location will be shared to the driver in order to pick the customer
  • Customer’s name, phone, photo will be share to the driver for communication
  • Driver’s GPS will be share to customer to know the progress of the driver to reach the pickup location
  • track the progress of your trip and detect abnormal trip variations
• enable communications between our users

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• Safety and security

We use your data to ensure the safety and security of our Services and all users. This includes:

• Verifying the drivers before allow the drivers to accept the service from the customer.
• verifying your identity before using our app
• using device, location, profile, usage and other Personal Data to prevent fraud or unsafe activities
• sharing the location of drivers and passengers and details when the emergency

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• User support

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
• inform you about steps taken to resolve user support issues

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• 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 analyze your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services.

1. Legal purposes

We may use the Personal Data we collect for legal purposes, such as to investigate and resolve claims or disputes, detect/prevent/prosecute crime, or as allowed or required by applicable law.

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
• 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 products or services, such as:

• send you special offers that may be of interest or relevance to you across all of PassApp’s service offerings
• send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings
• notify, invite and manage your participation in our events or activities

We may communicate such marketing to you by various means, where applicable (including by SMS, chat applications), push notification, call, and by email).

If you wish to unsubscribe to the receiving of such marketing communications, you can go to setting to disable receive marketing information.

3. DISCLOSURE OF PERSONAL DATA

We need to share Personal Data with other users in our system as below:

• If you are a passenger, we may share your username, pick-up and drop-off locations with our driver partner fulfilling your Service request
• If you are a driver partner, we may share your Personal Data with your passenger including your name and photo, your vehicle make, model, number plate, location and average rating

4. 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 getting lost, or used or accessed in an unauthorized way. We limit access to your Personal Data to our employees. Those processing your Personal Data will only do so in an authorized 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.

5. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA    

In accordance with applicable laws and regulations, you may be entitled to:

• inquire about the processing of your Personal Data and be provided with a copy of it
• in some cases, request the correction and/or deletion of your Personal Data
• in some cases, request the restriction of or object to the processing of your Personal Data
• complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment 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, withdrawing your consent to our use of it or to your agreement with our Privacy Notice could mean that we are unable to perform the actions necessary to achieve to use our Apps or the Services provide by our partner.

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.

We will screen and verify all requests beforehand. In order to verify your identity and/or 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 base on your request.

6. AMENDMENTS AND UPDATES

PassApp may modify, update or amend the terms in this Privacy Notice at any time. Such amendments shall be notified to you through the Apps and/ or other appropriate means  at least five (15) business days before the effective date. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Apps or continuing to communicate or engage with PassApp following the effective date of the modifications, updates or amendments to this Privacy Notice , whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.

7. HOW TO CONTACT US

If you have any queries about this Notice or would like to exercise your rights set out in this Notice, please contact us with the below information

Address: #09 Str. 572, Sangkat Boeng Kak II, Khan Tuol Kork, Phnom Penh
Email: info@passapptaxis.com
Phone: +85516789123

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.