Privacy Policy

This Privacy Policy and its Addendum(s) (“Policy”) describe how ALBA Group Asia Ltd and, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “ALBA”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of ALBA’s Apps and Websites (including all mobile applications and websites operated by ALBA (respectively “Apps” and “Websites”), products, features and other services globally (collectively, “Services”).

This Policy applies to our customers, passengers, agents, vendors, suppliers, partners (such as driver 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, address, bank and credit card details, Utility Account numbers, 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.


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.

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:

• fill up a user profile or registration forms;
• provide information to assess your eligibility to provide services as a ALBA recycling & waste collection partner or redeem partner;
• interact with our social media pages;
• participate in contests or events organised by us;
• fill up demographic information in surveys and forms.

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 nearest recycling bin locations and sustainability event location);
• feedback, ratings and compliments;
• transaction information (such as payment method and voucher redeemed);
• 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); and
• personal data you enter in messages when you use our in-app communication features.

From other sources
When we collect Personal Data 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 fleet partners, payment providers, ride-hailing partners and redeem partners;
• publicly available data;
• governmental sources of data;
• and marketing services providers or partners.

Sensitive Personal Data
Some of the information that we collect is sensitive in nature. This includes information such as national ID numbers, race, marital status, and your health or religious beliefs. We only collect this information when this is necessary to comply with legal or regulatory requirements.

Camera function of the App
Some ALBA partners and its app functionalities will record the pictures taken of the supposed recyclables to be disposed into the bins. These images will be used for sending feedback to the users as well as data analytics on waste generation pattern. The use of such in-built cameras in the app is not prohibited by ALBA. The collection, use and disclosure of Personal Data obtained from the app is the responsibility of the relevant partner.

Personal Data of minors
As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to ALBA. In the event that such Personal Data of a minor is disclosed to ALBA, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Policy 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 their email id for communication. If you provide us with their Personal Data, you represent and warrant that you have and 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
ALBA 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 products 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;
• verify your identity;
• validate your location and provide collection services;
• offer, obtain, provide or facilitate services;
• track the progress recycling actions and CO2 points collected through the app;
• enable features that personalise your App, such as lists of your favourite places and liked pictures and posts, visited programs and activites;
• 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 application of promotions, rewards and subscriptions with ALBA; and
• enable our partners to manage and allocate fleet resources.

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 ALBA;
• using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
• detecting, preventing and prosecuting crime.

Customer support
We use Personal Data to resolve customer support issues. For example, we may:

• investigate and address concerns;
• monitor and improve our customer support responses;
• respond to questions, comments and feedback; and
• inform you about steps taken to resolve customer 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.

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 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 ALBA and ALBA’s partners’ sponsors’ and advertisers’ products, services, events or promotions. For example, we may:
• send you alerts, notifications, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
• notify, invite and manage your participation in our events or activities;
• publish photos collected through Scanning QR code or through Instagram hashtag process to raise awareness on the correct/incorrect way of disposal of recyclables and on sustainability
• publish photos of users participating in environment campaigns and programs conducted for schools and communities for marketing and publicity purposes.
If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, you may write to us.


III. DISCLOSURE OF PERSONAL DATA
We need to share Personal Data with various parties for the Purposes. These parties include:

Other users
For example, if you request collection or other services, we may share your pick-up and drop-off locations with our collection drivers and maintenance crew.

With ALBA partners at your request
For example, if you requested a service through a ALBA partner or used a promotion provided by a ALBA partner, ALBA may share your Personal Data with that ALBA partners. Our partners include partners that integrate with our App or our App integrates with, redeem partners, or business partners which ALBA collaborate with to deliver a promotion, competition or other specialised service.

With the owner of “STEP UP Sustainability” accounts that you may use
For example, your employer/ School management may receive your recycling and performance data when you use your employer’s name for Business account.

With subsidiaries and affiliates
We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.

With ALBA’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;
• 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 ALBA or on ALBA’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 due 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 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 as long you maintain your STEP UP Sustainability account. 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 prevent access or use of such Personal Data for any purpose other than compliance with this privacy policy, or for purposes of safety, security, fraud prevention and detection.


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”). You understand and consent to the transfer of your Personal Data from your Home Country to the Alternate Country.


VI. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS
ALBA, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of the Websites and Apps. 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.

ALBA may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes ALBA 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 on third party platforms.

If you do not wish for your Personal Data to be collected via Cookies on the 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. You may also limit our sharing of some of this Personal Data through your App (Settings > Privacy > Ads) and mobile device settings.


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 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 data transmitted through any online means, therefore, any transmission remains at your own risk.


VIII. AMENDMENTS AND UPDATES
ALBA shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to use the Apps, Websites or Services, purchase products from ALBA or continuing to communicate or engage with ALBA following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.

If you have any queries about your Personal Data, please write to us at:
contact@alba-ewaste.sg

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