Effective from: 25 September 2021
This Privacy Notice and its Addendum(s) (“Notice”) describe how Dobby Walla Services, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “Dobby Walla”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of Dobby walla’s mobile applications and websites (respectively “Apps” and “Websites”), as well as products, features and other services globally, operated by Dobby Walla (collectively, “Services”).
This Notice applies to our laundromat 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 laundromat 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);
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); and
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 Apps, Websites and Services. Some examples are:
your location (to detect pick-up locations and abnormal route variations);
feedback, ratings and compliments;
transaction information (such as payment method and distance travelled);
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, our agents, in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).
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, payment providers, ride-hailing partners and transport partners;
insurance and financial providers;
credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
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.
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 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 Dobby Walla. In the event that such Personal Data of a minor is disclosed to Dobby walla, 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 or friends) to us. For example, you may add them as your emergency contact or 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 Notice.
II. USE OF PERSONAL DATA
Dobby walla 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 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;
verify your identity;
verify your age (where necessary);
validate your ride and process payments;
offer, obtain, provide, facilitate or maintain insurance or financing solutions;
track the progress of your trip and detect abnormal trip variations;
enable features that personalise your App, such as lists of your favourite places and previous destinations;
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 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;
process, manage or verify your eligibility for or application of promotions, rewards and subscriptions with Dobby Walla;
enable our partners to manage and allocate fleet resources; and
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 services from, and for whom Dobby Wallais providing services on behalf of) for such services to be rendered.
Dobby Walla 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 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, and facilitate insurance and finance solutions.
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.
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.
Marketing and promotions
We may use your Personal Data to market Dobby Walla and Dobby Walla partners’, sponsors’ and advertisers’ services, events or promotions. For example, we may:
send you 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, please click on the unsubscribe link in the relevant email or message.
Alternatively, you may also update your preferences in our App settings.
III. DISCLOSURE OF PERSONAL DATA
We need to share Personal Data with various parties for the Purposes. These parties include:
With Dobby Walla partners at your request
For example, if you requested a service through a Dobby Walla laundromat partner or used a promotion provided by a Dobby Walla partner, Dobby Wallamay share your Personal Data with that Dobby Walla partners.
Our partners include partners that integrate with our App or our App integrates with, vehicle services partners, or laundromat partners which Dobby Walla collaborates with to deliver a promotion, competition or other specialised service.
With the owner of Dobby Walla accounts that you may use
For example, your employer may receive trip data when you use your employer’s Dobby walla for Business account.
With subsidiaries and affiliates
We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.
With Dobby walla’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.
payment processors and facilitators;
credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
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 Dobby walla or on Dobby walla’s behalf;
fleet and merchant partners;
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 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 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.
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
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 Apple’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.
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 Dobby Walla App. You will still be seeing non targeted advertisements.
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.
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
Dobby Walla 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 five (05) business days before the effective date. The updated version will be posted on the website https://www.dobbywalla.com/. It is your responsibility to review the Privacy Noticeregularly. Your continued use of the Apps, Websites or Services, purchase products from Dobby Walla or continuing to communicate or engage with Dobby Walla 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. 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 our Data Protection Officer at:
Dobby Walla Data Protection Officer
TR 1-12-9, THE RESIDENCE 1,
The original of this Notice is written in the English language.