Last Updated On 13 September 2021
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INTRODUCTION

When you use FLUX, you trust us with your personal information. We are committed to keeping that trust. That starts with helping you understand our privacy practices. This privacy policy (“Policy”) describes how we use, share and protect the information you provide us and the information that we collect.
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SCOPE

This Policy describes how FLUX and its affiliates (collectively “FLUX”) collect and use your personal information to provide our services. This Policy applies to all users of our website, app, features or other services anywhere in the world. This Policy specifically applies to:

- Member: Users who subscribe to the FLUX Car Subscription Service

- Inventory Providers: Users who provide vehicles to be listed and subscribed to on the FLUX app 

- Users: Those who provide information to FLUX in connection with an application to use our services, or whose information FLUX otherwise receives in connection with its services. 

The practices described in this Policy are subject to and comply with the Malaysian Personal Data Protection Act 2010 and other applicable privacy and data protection laws in force in the countries in which we operate in. 
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THE INFORMATION WE COLLECT

Information you provide

This may include:
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⁠ - User profile: We collect information when you create or update your FLUX account. This may include but is not limited to your name, address, email address, phone number(s), login name and password, payment or banking information (including related payment verification information), government identification numbers, driving licence or passport, date of birth, photos and signature. This also includes the driver, vehicle or insurance information.

- Background check information: We may collect background check information. This may include but is not limited to your driving history, credit score or criminal records (where permitted by law). This information may be collected by a vendor on FLUX’s behalf.

- Demographic data: We may collect demographic information about you, including through user surveys. We may also receive demographic information about you from third parties.

- User content: We may collect information that you submit when you contact FLUX customer support, provide ratings or reviews for other users, or otherwise contact FLUX.

INFORMATION CREATED WHEN YOU USE OUR SERVICES

This may include:
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Location information

- We may collect the precise or approximate location information of the FLUX vehicle you use as determined through a telematics device installed in your vehicle.

- We collect location information of FLUX vehicles throughout the entire usage of our services, that is from the start of the vehicle delivery to the time we pick up the vehicle during the return. The location information is tracked in real-time and is up-to-date 24/7.

- The location information includes secondary data which helps define where the vehicle is parked, left idle with the engine on, which roads the vehicle travels on and which locations it tends to be driven to.

Telematics information

We collect telematics information related to your use of our vehicles, including the driving speed of the vehicle, the magnitude of acceleration, braking and cornering forces of the vehicle, distance travelled and driving time.

Transaction Information

We collect transaction details related to your use of our services, including the type of services you requested or provided, your order details, delivery/return information, date and time the service was provided, amount charged, distance travelled, and payment method. Also, if someone uses a promotion code assigned to you, we may associate your name with that person.

Usage information

We collect information about how you interact with our services. This includes information such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services you were using before interacting with our services. In some cases, we collect this information through cookies, pixel tags and similar technologies that create and maintain unique identifiers. 

Device information

We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

Information from other sources

This may include:

- User feedback, such as ratings.

- Users providing your information in connection with referral programmes.

- Users requesting services for you or on your behalf.

- Users or others providing information in connection with claims or disputes.

- FLUX business partners through which you create or access your FLUX account, such as payment providers, social media services, or app who use FLUX's Application Programming Interfaces (APIs) or whose APIs FLUX uses.

- Insurance providers.

- Financial services providers.

- Partner transport companies.

- Publicly available sources.

- Marketing service providers.

⁠FLUX may combine the information collected from these sources with other information in its possession.
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HOW WE USE YOUR INFORMATION

FLUX uses the information it collects for purposes including: 

Providing services and features

FLUX uses your information that we collect to provide, personalise, maintain and improve our products and services. This includes using the information to:

- Create and update your account.

- Verify your identity.

- Enable transport, deliveries and other services. 

- Process or facilitate payments for those services.

- Offer, obtain, provide or facilitate insurance or financing solutions in connection with our services.

- Track the usage and performance of our services.

- Enable features that allow you to share information with other people.

- Enable features to personalise your FLUX subscription and account.

- Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing and research, and to monitor and analyse usage and activity trends.

Safety and security

We use your personal information to help maintain the safety, security and integrity of our services and users. This includes, for example:

- Screening users and partners prior to enabling their use of our services and at subsequent intervals, including through reviews of background checks where permitted by law, to prevent the use of our services by unsafe users.

- Using information from telematic devices to identify unsafe driving behaviour such as speeding or harsh braking and acceleration, and to raise awareness among users regarding such behaviour.

- Checking government issued identification before handing over the vehicle. This helps ensure that the user using the platform matches the FLUX account we have on file, preventing fraud and helping to protect against vehicle theft.

- Using device, location, profile, usage and other information to prevent, detect and combat fraud or unsafe activities. This includes processing of such information, to identify practices or patterns that indicate fraud or risk of safety incidents. This may also include information from third parties. In certain cases, such incidents may lead to deactivation by means of an automated decision-making process. 

- Using user ratings to encourage improvement by affected users, and as grounds for deactivating users with ratings below a certain minimum as may be required in their region. Calculation and deactivation may be done using an automated decision-making process.

Customer support

FLUX uses the information we collect (including recordings of customer support calls after notice to you and with your consent) to assist you when you contact our customer support services, including:

- Direct your questions to the appropriate customer support personnel;

- Investigate and address your concerns;

- Monitor and improve our customer support responses.

Research and development

We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products, and facilitate insurance and finance solutions in connection with our services. 

Communications from FLUX

FLUX may use the information we collect to communicate with you about products, services, promotions, studies, surveys, news, updates and events.

FLUX may also use the information to promote and process competitions and sweepstakes, fulfil any related awards, and serve you relevant ads and content about our services and those of our business partners. You may receive some of these communications based on your profile as a FLUX user. 

Legal proceedings and requirements

We may use the information we collect to investigate or address claims or disputes relating to your use of FLUX’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, court order or official enquiries.

In any and all usage of customer information in this section, FLUX shall keep customer information confidential and use all reasonable means to prevent the disclosure and to protect the confidentiality thereof.

Cookies and Third-Party Technologies

Cookies are small text files that are stored on your browser or device by websites, apps, online media and advertisements. FLUX uses cookies and similar technologies for purposes such as:

- Authenticating users.

- Remembering user preferences and settings.

- Determining the popularity of content.

- Delivering and measuring the effectiveness of advertising campaigns.

- Analysing site traffic and trends, and generally understanding the online behaviour and interests of people who interact with our services. We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, Software Development Kits (SDKs) and other technologies to identify your device when you visit our site and use our services, as well as when you visit other online sites and services. 

INFORMATION SHARING AND DISCLOSURE

FLUX may share the information we collect:

With other users

- For example, if you are a member, we may share your full legal name, mobile number, and pick-up and/or drop-off addresses with our inventory provider. 

- If you are an inventory provider or partner, we may share information with members who subscribe to your vehicle(s) including your name and address(es); average rating provided by other users; total number of vehicles; for how long you have been using the FLUX service; contact information. If you accept FLUX’s Terms of Use and/or Head Lease Agreement, we may also share any information associated with that profile, including information that you submit and reviews that past members have submitted about your inventory.  

At your request

This includes sharing your information with our business partners. For example, if you requested a service through a partnership or promotional offering made by a third party, FLUX may share your information with those third parties. This may include, for example, other apps or websites that integrate with our APIs, vehicle suppliers or services, or those with an API or service with which we integrate, or business partners with whom FLUX may partner to deliver a promotion, competition or specialised service.

With the general public when you submit content to a public forum

We love hearing from our users, including through public forums such as blogs, social media and certain features on our network. When you communicate with us via these channels, your communications may be viewable by the public.

With the owner of FLUX accounts that you may use

If you use a profile associated with another party, we may share your subscription information with the owner of that profile. This occurs, for example, if you are:

- A member using your employer’s FLUX for Business profile.

- A member who is an additional driver to a FLUX subscription.  

With FLUX subsidiaries and affiliates

We share information with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.  

With FLUX service providers and business partners

FLUX may provide information to its vendors, consultants, marketing partners, research firms, and other service providers or business partners. This may include but is not limited to:

- Payment processors and facilitators.

- Background check providers.

- Cloud storage providers.

- Marketing partners and marketing platform providers.

- Data analytics providers.

- Research partners. 

- Vendors that assist FLUX to enhance the safety and security of its app.

- Consultants, auditors, lawyers, accountants and other professional service providers.

- Inventory Providers.

- Insurance and financing partners.

- Vehicle solution vendors or third-party vehicle suppliers.

For legal reasons or in the event of a dispute

FLUX may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing your information with law enforcement officials, government authorities or other third parties as necessary to enforce our Terms of Use, user agreements or other policies, to protect FLUX’s rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to your use of our services. If you use another person’s credit card, we may be required by law to share information with that credit card holder, including subscription information.

This also includes sharing your information with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

With your consent

FLUX may share your information other than as described in this Policy if we notify you and you consent to the sharing.

To the public

FLUX may share anonymous aggregated customer data with the public for a variety of purposes, including but not limited to general information provision, education, industry development, policy establishment and national growth among others.

INFORMATION RETENTION AND DELETION

FLUX requires user profile information in order to provide its services. It retains such information for as long as you maintain your FLUX account.

FLUX retains certain information, including transaction, location, device and usage information for a minimum of 7 years in connection with regulatory, tax, insurance and other requirements in the places in which it operates. Once such information is no longer necessary to provide FLUX’s services, enable customer support, to enhance the user experience or for other operational purposes, FLUX takes steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.

FLUX may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, if FLUX shuts down a user's account because of unsafe behaviour or security incidents, FLUX may retain certain information about that account to prevent that user from opening a new FLUX account in the future.
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UPDATE TO THIS POLICY

We reserve the right to amend and/or update this Policy from time to time. If we make significant changes, we will notify you of the changes through the FLUX platform or through other means, such as email. To the extent permitted under applicable law, by using our services after such notice, you consent to our amendments and/or updates to this Policy.

In the event of any conflict between the English version and other language versions, the English version shall prevail.