Effective from: 9 Jul 2023

This Privacy Policy and its Addendum(s) describe how Edenfarm Inc, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively "Edenfarm","EDEN HUB", "EDEN HUB S", "we", "us" or "our") collect, use, process and disclose your Personal Data through the use of Edenfarmâ€™s mobile applications and websites (respectively "Apps" and "Websites"), as well as products, features and other services globally, operated by Edenfarm (collectively, "Services").

This Notice applies to our consumers , agents, vendors, suppliers, partners (such as car owners, drivers and auto repair shops, and merchant partners), 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. If you have or are a party to multiple relationships with us (for example if you use our Services across our various business verticals, or if you are both a driver partner/auto repair shop partner as well as a consumer to our Apps or on our other business verticals), we will link your Personal Data collected across your various capacities to facilitate your use of our 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 provide services as a auto repair partner or car owner (such as 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 organized 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;

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.

When our services are used

Personal Data may be collected through the normal operation of our Apps, Websites and Services. Some examples are:

your location (to detect roadside issue locations and abnormal route variations);
feedback, ratings and compliments;
transaction information (such as payment method and distance from mechanic/helper to roadside location);
information about how you interacted with our Apps, Website or Services (such as features used and content viewed);
device information (such as hardware model and serial number, IP address, file names and versions, and advertising identifiers or any information that may provide indication of device or app modification);
personal data you enter in messages when you use our in-app communication features; and
personal data that may be captured through your interaction with us, in-vehicle audio and/or video recording during car repairing.

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:

referral programmes;
our business partners, such as auto repair partners, payment providers;
insurance and financial providers;
credit bureaus, alternative credit scoring agencies and any other credit reporting organizations;
publicly available sources of data;
governmental sources of data;
when our users add you as an emergency contact;
when you use our in-app chat; and
marketing services providers or partners.

II. USE OF PERSONAL DATA

Edenfarm 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, personalize, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:

provide you with Services across our various business verticals;
engage you to provide Services;
create, administer and update your account;
conduct due diligence checks and risk assessments / analysis;
validate your repairs and process payments;
offer, obtain, provide, facilitate or maintain insurance or financing solutions;
track the progress of your auto repairs and detect abnormal repair variations;
enable features that personalize your App, such as lists of your favourite auto repair shops;
make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;
perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analyzing 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;
process, manage or verify your eligibility for or application of promotions, rewards and subscriptions with Edenfarm;
enable our partners to manage and allocate fleet resources; and
fulfill the services to you as a data processor, where you have provided consent to the data controller for such services to be rendered.

Edenfarm 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; and
inform you about steps taken to resolve user support issues.

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, and facilitate insurance and finance solutions.

Legal purposes

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.

We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.

III. DISCLOSURE OF PERSONAL DATA

We need to share Personal Data with various parties for the Purposes. These parties include:

With other users

For example:

If you are a car owner who are requesting help, we may share your name and photo; your vehicle make, model, number plate, location with helpers and/or auto repair shops fulfilling your service request.
If you are helpers/mechanics, we may share your Personal Data with requesters including your name and photo; your vehicle, model, number, location and average rating.
If you use our in-app chat service, we may share your mobile number and your name with the other parties to your chat.

With Edenfarm partners at your request

For example, if you requested a service through a Edenfarm partner or used a promotion provided by a Edenfarm partner, Edenfarm may share your Personal Data with that Edenfarm partners. Our partners include partners that integrate with our App or our App integrates with, vehicle services partners, or business partners which Edenfarm collaborates with to deliver a promotion, competition or other specialized service.

With Edenfarmâ€™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;
debt collectors;
credit bureaus, alternative credit scoring agencies and any other credit reporting organizations;
background check and anti-money laundering service providers;
cloud storage providers;
marketing partners and marketing platform providers;
data analytics providers;
research partners, including those performing surveys or research projects in partnership with Edenfarm or one CarAidâ€™s behalf;
insurance and financing partners;
third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
service providers who perform identity verification services; and
vehicle solutions partners, vendors or third-party vehicle suppliers.

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 fulfill 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 Privacy Policy 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 erase, destroy, anonymize or prevent access or use of such Personal Data for any purpose other than compliance with this Policy , or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

V. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Your Personal Data may be transferred from country, state and city ("Home Country") in which you are present while using our Services to another country, state and city ("Alternate Country").

When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.

VI. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS

Edenfarm, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies ("Cookies") in connection with your use of the Websites and Apps. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Appleâ€™s IDFA). 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.

Edenfarm may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes Edenfarm does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

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 websites

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.

Disabling the display of Targeted Ads through our App

You may be able to limit our use of your personal data to display advertisements that may be of relevance to you, by adjusting your preference sharing of some of this Personal Data through our EDEN HUB & EDEN HUB Service Apps. You will still be seeing non targeted advertisements.

VII. 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 on a need to know basis. 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.

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 organization, 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 (How to 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

Edenfarm may modify, update or amend the terms in this Policy at any time. Such amendments shall be notified to you through the Application and/ or other appropriate means at least ten (10) business days before the effective date. The updated version will be posted on the Edenfarm website. It is your responsibility to review the Privacy Policy regularly. Your continued use of the Apps, Websites or Services from Edenfarm or continuing to communicate or engage with Edenfarm following the modifications, updates or amendments to this Policy , whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.

X. HOW TO CONTACT US

If you have any queries about this Policy or would like to exercise your rights set out in this Policy, please direct your mail to our offices:

For users in USA,
Address: 898 South 2nd Street (Unit C) San Jose, CA 95112

For users in Vietnam and other countries,
Address: 11A Hong Ha, Tan Binh Dist., Ho Chi Minh City, Vietnam

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.