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Effective Date: 22nd October 2025
These Terms and Conditions (“Terms”) govern your access to and use of the LUGO mobile application, including any related websites, products, and services (collectively, the “App”), operated by Hugo Mobility Pte. Ltd. (UEN 201615566Z), a company incorporated in Singapore with its principal place of business at 3 Church Street, #17-02, Singapore 049483 (“Company,” “we,” “us,” or “our”).
By creating an account, accessing, or using the App, you acknowledge that you have read, understood, and agreed to be bound by these Terms and our Privacy Notice (https://lugo.com.my/privacy-policy/). If you do not agree to these Terms, you must not access or use the App.
These Terms take effect on the Effective Date stated above and shall apply to all users, including those who registered, accessed, or used the App before the Effective Date.
By continuing to access or use the App on or after the Effective Date, you acknowledge and agree that the updated Terms supersede and replace any prior versions of the Terms previously applicable to your use of the App.
1.1 LUGO provides:
(a) public transport information and journey planning (including routes, schedules, fares and estimated travel times);
(b) discovery and booking of on-demand transit services with participating operators;
(c) EV charger locator and related charger information (availability, types, operator details);
(d) sale and/or facilitation of bus tickets and attractions tickets and packages;
(e) sale and/or facilitation of ManjaSIM – SIM cards and related top-ups or add-ons;
(f) integrations and collaborations with Manjalink (stored value card) and Manjapay (e-wallet), including in-app balance display and top-ups;
(g) BAS.MY pass subscription, management and validation (including in-app check-in/check-out for participating bus services);
(h) processing of payments for transactions made via the App; and
(i) discovery and access to other third-party merchant products and services,
(collectively, “Third-Party Services”).
1.2 We are a technology platform that facilitates the connection between users and independent third-party service providers or merchants (“Merchants”) offering Third-Party Services. Where expressly stated, we may act as an agent for certain Merchants in arranging or facilitating such Third-Party Services.
1.3 Unless expressly stated otherwise, we do not ourselves provide any transport, charging, telecommunications, ticketing, financial, logistics, or other services to you. All Third-Party Services are provided directly by the respective Merchants, and your use of such services is subject to the applicable terms, conditions, and policies of the relevant Merchant.
1.4 We may, at any time and without prior notice, add, modify, suspend, or discontinue any feature, functionality, Merchant integration, or service available on the App for operational, security, legal, or business reasons.
2.1 You must be at least 18 years old to access or use the App. If you are below the age of majority in your jurisdiction, you represent and warrant that you have obtained the consent of your parent or legal guardian, and that such person has read and agreed to these Terms on your behalf.
2.2 You agree to provide and maintain accurate, complete, and up-to-date registration information, and to keep your account credentials secure at all times. You are solely responsible for all activities that occur under your account, whether or not authorized by you. You must notify us immediately if you become aware of any unauthorized use, access, or security breach involving your account.
3.1 Subject to these Terms, we grant you a limited, personal, non-exclusive, non-transferable, revocable licence to use the App for personal, non-commercial purposes.
3.2 You agree to use the App only for lawful purposes and in accordance with these Terms. You must not, whether directly or indirectly:
(a) use the App in any manner that could interfere with, disrupt, or negatively affect the operation, security, or integrity of the App or any related systems;
(b) attempt to gain unauthorized access to any account, system, data, or network connected to the App;
(c) use the App to engage in any fraudulent, misleading, or deceptive activity;
(d) upload, post, or transmit any content that is unlawful, offensive, defamatory, obscene, or otherwise objectionable;
(e) copy, modify, adapt, reverse-engineer, decompile, or disassemble any part of the App or its underlying software;
(f) use the App for any purpose that infringes the intellectual property or privacy rights of others; or
(g) use automated tools, bots, or scripts to access or collect information from the App without our prior written consent.
3.3 We reserve the right to investigate any suspected breach of this clause and to take any appropriate action, including suspension or termination of access, legal proceedings, or referral to law enforcement authorities.
4.1 Information such as transport schedules, routes, estimated times of arrival (ETAs), fares, and electric vehicle (EV) charger details (including availability, status, and pricing) is provided solely for your convenience. Such information may be obtained from third-party sources and is subject to change without notice. Actual conditions, prices, and timings may vary from those displayed in the App.
4.2 You are responsible for exercising your own judgment and for complying with all applicable laws, regulations, and official advisories when using transport or EV charging services. You must also adhere to the specific terms and conditions of each EV charging operator, as displayed in the App at the point of use (see: [DC Handal and https://www.dchandal.com/term-and-conditions/]).
4.3 The Company makes no representation or warranty as to the accuracy, completeness, reliability, or availability of any such information, and shall not be liable for any loss, delay, or inconvenience arising therefrom.
5.1 Bookings for on-demand transit, bus tickets, attractions tickets and packages are provided by Merchants and governed by the applicable Merchant terms (including fare rules, inclusions, age/eligibility, safety rules, time windows, cancellations, refunds and amendments). We present the relevant Merchant terms at the point of purchase in-app for your review and acceptance, including:
5.2 A booking or ticket purchase is confirmed only when we or the Merchant issue a confirmation or ticket/QR code. We may reject or cancel transactions (with refund where applicable) for fraud, operational or compliance reasons.
5.3 Any changes, cancellations and refunds shall follow Merchant policy. Some tickets may be non-refundable, non-changeable, or subject to fees. We may assist with support, but final decisions rest with the Merchant’s terms, accessible at the point of purchase via the links above.
6.1 Manjalink and Manjapay are operated by their respective providers. Your use of stored value cards or e-wallets is governed by the provider’s terms and privacy notices, which we display and link at the point of linking, balance checks or top-up:
6.2 When you link your Manjalink or Manjapay account/card to the App, you authorise us to retrieve and display balance, transaction and status information from the provider. Displayed balances may be subject to processing or network delays.
6.3 Where the App enables top-ups: (a) you authorise us to transmit your instructions to the provider and payment processor; (b) top-ups may be subject to verification, limits, fees and processing times published by the provider; (c) successful top-ups are final except as required by law or the provider’s policy; and (d) we may decline, delay or reverse a top-up in cases of suspected fraud, error or legal/compliance requirements.
6.4 We do not hold customer funds as a bank or deposit-taking institution. Any stored value or wallet balances are held by the respective provider, not by us, unless expressly stated otherwise.
7.1 The App enables you to subscribe to, manage and use a BAS.MY transit pass with participating bus operators, including in-app validation (e.g., QR/NFC) to check in and check out of buses.
7.2 Subscription, entitlements (zones, routes, time periods), eligibility, usage rules, penalties (including missed check-outs), fare adjustments, refunds and renewals are governed by the BAS.MY terms, which we present at the point of subscription and keep accessible in-app:
7.3 (a) You must follow the in-app prompts and operator instructions to check in on boarding and check out when alighting. (b) If you fail to check out, the operator may apply default fares or penalties per BAS.MY rules. We may assist with support, but final adjustments are determined by the operator and BAS.MY terms. (c) You consent to the App using device capabilities (e.g., QR/NFC/Bluetooth/location) to facilitate validation and reduce fraud.
7.4 Subscription fees, renewals, proration and cancellations shall follow the BAS.MY terms. Where auto-renewal is enabled, you authorise recurring charges to your selected payment method until you cancel in accordance with the BAS.MY terms.
7.5 You authorise us to exchange necessary data with BAS.MY and participating operators to provision, validate and administer your pass, in accordance with our Privacy Notice and the BAS.MY terms.
8.1 ManjaSIM is provided in collaboration with a licensed telecommunications provider. Purchase and use of ManjaSIM, including activation, KYC, plan inclusions, fair use, roaming, network coverage, porting, expiry, refunds, replacements, SIM swap and number retention, are governed by the ManjaSIM Terms and Conditions, presented at the point of purchase and available here:
8.2 You agree to provide accurate information and any identity documents required for SIM registration or activation, and consent to verification with the relevant authorities or providers in Singapore and/or Malaysia, as applicable.
8.3 (a) Delivery/Collection. If delivery or pick-up is offered, details, fees and timeframes will be shown at checkout. (b) Activation. Activation steps and timeframes are set out in the ManjaSIM Terms. Some plans may require activation within a specified period. (c) Returns/Refunds. Returns, exchanges or refunds for ManjaSIM follow the ManjaSIM Terms and any mandatory consumer protections. Activated SIMs and used top-ups may be non-refundable.
8.4 You must use ManjaSIM lawfully and in accordance with the ManjaSIM Terms and the telecommunications provider’s acceptable use policy. We may suspend or cancel orders if we detect fraud, abuse or regulatory non-compliance.
9.1 Payments made through the App may be processed by the Company acting as agent for the Merchant or through a third-party payment service provider. By using the App, you authorise charges to your selected payment method for all amounts due, including applicable taxes, fees, surcharges, and currency conversion charges.
9.2 We may place pre-authorisations, verification charges, or temporary holds on your selected payment method. If any payment is unsuccessful or reversed, you remain responsible for all amounts due and any related fees or penalties.
9.3 You agree to cooperate fully with the Company, payment processors, and relevant service providers to resolve any billing or transaction issues. We may share relevant transaction details with your payment issuer or financial institution to assist in handling chargebacks, disputes, or investigations.
9.4 To comply with applicable anti-money laundering (AML), countering the financing of terrorism (CFT), sanctions, and regulatory requirements in Singapore and Malaysia, we may:
(a) request identity verification or “Know Your Customer” (KYC) information;
(b) impose transaction limits;
(c) delay or decline processing of transactions; and/or
(d) report suspicious activity to relevant authorities.
9.5 All payments made through the App are final unless otherwise stated by the relevant Merchant or required by applicable law. The Company does not process or guarantee refunds on behalf of any Merchant. Any request for refunds, cancellations, or service disputes must be directed to the respective Merchant in accordance with their refund or cancellation policy.
9.6 Where we act as the Merchant’s payment agent, we may facilitate refunds only upon the Merchant’s instruction. The timing and method of such refunds are subject to the Merchant’s approval and the policies of the relevant payment service provider or financial institution.
9.7 In cases where a transaction is reversed, disputed, or charged back by your payment issuer, we reserve the right to deduct, recover, or set off any refunded amount or associated fees from your account or future transactions.
9.8 We are not responsible for any delay, loss, or failure in the processing of refunds caused by payment processors, banks, or other intermediaries.
10.1 Merchants are independent third parties. The Company does not control, direct, endorse, or guarantee any Merchant’s actions, availability, quality, safety, legality, pricing, or fitness for purpose. Unless expressly stated, the Company is not a party to any contract or transaction between you and a Merchant.
10.2 The Company operates solely as a technology platform to facilitate connections between users and Merchants. It does not own, manage, or operate any services, products, or offerings provided by Merchants. All transactions, services, and arrangements made between users and Merchants are strictly between those parties.
10.3 The Company makes no representation or warranty, whether express or implied, regarding any Merchant’s products or services, including their quality, safety, suitability, reliability, legality, timeliness, or performance. To the fullest extent permitted by law, the Company shall not be liable for any loss, damage, claim, cost, or expense arising out of or in connection with any transaction, service, or interaction between users and Merchants, including but not limited to service failures, cancellations, delays, defects, or errors.
10.4 Users are solely responsible for verifying and evaluating the Merchant’s services, credentials, and terms before proceeding with any transaction.
11.1 You are solely responsible for all content you submit, upload, post, or otherwise make available through the App (including but not limited to reviews, photos, feedback, and preferences). You represent and warrant that you own or have the necessary rights and permissions to share such content, and that your content is lawful, accurate, and does not infringe any third-party rights.
11.2 By submitting content through the App, you grant the Company a worldwide, non-exclusive, royalty-free, transferable, and sublicensable licence to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, publicly perform, and display such content in connection with the operation, improvement, and marketing of the App and related services.
11.3 The Company reserves the right, but not the obligation, to review, remove, or restrict access to any content that it deems, in its sole discretion, to violate these Terms, applicable law, or the rights of any third party.
12.1 The App, including all software, source code, design, text, graphics, interfaces, trademarks, logos, icons, trade names, and other intellectual property rights contained therein, are and shall remain the exclusive property of the Company and its licensors.
12.2 Except as expressly permitted under these Terms, no licence or right is granted to you, whether by implication, estoppel, or otherwise, to use, copy, reproduce, modify, adapt, translate, publish, distribute, transmit, display, perform, or create derivative works based on any part of the App or its content.
12.3 You agree not to remove, obscure, or alter any copyright, trademark, or proprietary notices contained in or accompanying the App.
12.4 All rights not expressly granted under these Terms are reserved by the Company. Any unauthorized use of the App or its content may constitute a violation of intellectual property laws and may result in legal action.
13.1 Your privacy is important to us. The collection, use, disclosure, and processing of your personal data in connection with your use of the App are governed by our Privacy Notice, which forms part of these Terms.
13.2 By accessing or using the App, you acknowledge and agree that we may collect and process your personal data as described in the Privacy Notice, including sharing certain information with third-party service providers, payment processors, and Merchants as necessary to operate and provide the App’s features and services.
13.3 You are responsible for ensuring that any personal data you provide is accurate, current, and complete, and for obtaining any necessary consents for personal data that you submit on behalf of others.
13.4 We implement reasonable technical and organizational measures to safeguard your information; however, no system or transmission over the internet can be guaranteed to be completely secure. To the extent permitted by law, the Company shall not be liable for any unauthorized access, disclosure, or loss of data beyond its reasonable control.
14.1 The App may contain links to or integrations with third-party websites, applications, APIs, or services that are not owned or controlled by the Company. Such links and integrations are provided solely for your convenience.
14.2 The Company does not endorse, monitor, or assume responsibility for the content, products, services, or practices of any third party. Your access to and use of such third-party platforms are governed by their respective terms and privacy policies, and you are solely responsible for reviewing and complying with them.
14.3 The Company shall not be liable for any loss, damage, or harm arising from or related to your use of, or reliance on, any third-party content, service, or integration accessible through the App.
14.4 The inclusion of any link or integration does not imply any partnership, sponsorship, endorsement, or affiliation between the Company and the third party, unless expressly stated.
15.1 The App and all content, information, and services made available through it are provided on an “as is” and “as available” basis. The Company makes no representations or warranties, whether express, implied, or statutory, including without limitation any warranties of merchantability, fitness for a particular purpose, accuracy, completeness, reliability, availability, or non-infringement.
15.2 The Company does not warrant that the App, its servers, or any data transmitted will be error-free, uninterrupted, secure, or free of viruses, defects, or harmful components, nor that any issues will be corrected promptly.
16.1 To the fullest extent permitted by law, the Company, its directors, officers, employees, agents, and affiliates shall not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages, or for any loss of profits, revenue, goodwill, data, or business opportunities arising out of or in connection with:
(a) your access to or use of (or inability to access or use) the App;
(b) any transaction, communication, or relationship between you and any Merchant or third party;
(c) any errors, inaccuracies, or omissions in the App or any content provided through it; or
(d) any event beyond the Company’s reasonable control.
16.4 In no event shall the Company’s total aggregate liability to you for all claims arising out of or in connection with these Terms or your use of the App exceed the total service fees (if any) paid by you to the Company in respect of the specific transaction or service giving rise to the claim, regardless of the cause of action or theory of liability.
16.5 Some jurisdictions do not allow the exclusion or limitation of certain warranties or liabilities. In such cases, the exclusions and limitations above shall apply only to the extent permitted by applicable law.
17.1 You agree to indemnify, defend, and hold harmless the Company, its affiliates, directors, officers, employees, agents, and contractors (collectively, the “Indemnified Parties”) from and against any and all claims, actions, proceedings, liabilities, losses, damages, costs, and expenses (including reasonable legal fees) arising out of or in connection with:
(a) your access to or use of the App, including any content or services obtained through it;
(b) your breach of these Terms or any applicable law or regulation;
(c) any transaction, dispute, or interaction between you and any Merchants or third party; or
(d) any act, omission, or negligence by you or any person accessing the App using your account.
17.2 The Company reserves the right to assume the exclusive defence and control of any matter subject to indemnification by you, in which case you agree to cooperate fully with the Company in asserting any available defences.
17.3 This indemnity obligation shall survive the termination or expiry of your account and these Terms.
18.1 These Terms apply from your first use of the App and continue until terminated.
18.2 We reserve the right, at our sole discretion and without prior notice, to suspend, restrict, or terminate your account or access to the App (in whole or in part) if:
(a) you breach or are suspected of breaching these Terms or any applicable law;
(b) we reasonably believe your continued use may cause harm, loss, or legal exposure to the Company, any user, or any Merchant;
(c) we are required to do so for security, operational, or regulatory reasons; or
(d) your account has been inactive for an extended period of time.
Upon termination, your right to access or use the App will immediately cease. Any provisions of these Terms which by their nature should survive termination (including disclaimers, limitations of liability, and indemnities) shall remain in effect.
18.3 You may stop using the App at any time and request account deletion via the App or by contacting us via email.
19.1 These Terms are entered into between you and the Company, not with Apple Inc. (“Apple”) or Google LLC (“Google”). Apple and Google are not responsible for the App or its content and have no obligation to provide any maintenance, support, or related services for the App.
19.2 In the event that the App fails to conform to any applicable warranty (to the extent not disclaimed under these Terms), you may notify Apple or Google, as applicable, and—if you paid a purchase price—be entitled to a refund of that purchase price. To the maximum extent permitted by applicable law, Apple and Google shall have no other warranty obligations or liability with respect to the App.
19.3 You agree to comply with all applicable third-party terms of service (including those of Apple or Google) when using the App. Apple, Google, and their respective subsidiaries are third-party beneficiaries of this Section, and upon your acceptance of these Terms, they shall have the right (and will be deemed to have accepted the right) to enforce this Section against you as a third-party beneficiary.
20.1 You must at all times comply with all applicable laws, regulations, and official requirements, including but not limited to traffic and transport rules, parking and charging site regulations, telecommunications and SIM registration requirements, anti-money laundering and countering the financing of terrorism (AML/CFT) obligations, and sanctions or export control laws.
20.2 You must not interact with or operate the App while driving or in control of a vehicle. Plan your route in advance or use approved hands-free functionality where permitted by law. The Company shall not be liable for any accident, injury, or violation arising from unsafe or unlawful use of the App.
21.1 We may send you service messages, transactional notices, and important updates via the App, email, SMS, or push notifications. You may manage or disable non-essential notifications through your device or account settings; however, certain operational or security-related communications may still be sent.
21.2 Notices to the Company may be sent by email or post to the following:
Email: support@lugo.com.my
Postal Address: 3 Church Street, Samsung Hub #17-02 Singapore 049483
21.3 A notice shall be deemed received:
(a) if delivered by hand — upon actual delivery;
(b) if sent by email — upon transmission, provided no bounce-back or error message is received; or
(c) if sent by registered post — after three (3) business days for domestic deliveries or seven (7) business days for cross-border deliveries.
22.1 We may update, revise, or modify these Terms from time to time. If we make material changes, we will provide notice to you through the App, by email, or through other reasonable means.
22.2 Unless otherwise stated, all changes will take effect on the effective date specified in the updated Terms. Your continued access or use of the App after the effective date constitutes your acceptance of the revised Terms.
22.3 If you do not agree to the updated Terms, you must stop using the App before the effective date of the changes.
23.1 These Terms and any non-contractual obligations arising out of or in connection with them shall be governed by and construed in accordance with the laws of Singapore, without regard to conflict of law principles.
23.2 Any dispute, controversy, or claim arising out of or relating to these Terms, the App, or your use of any related services shall first be resolved amicably through good-faith discussions within thirty (30) days of written notice by either party.
23.3 If the dispute cannot be resolved amicably, it shall be subject to the exclusive jurisdiction of the courts of Singapore, provided that the Company may, at its sole discretion, commence proceedings in the courts of Malaysia (or any other jurisdiction where you reside or operate) to enforce its rights or obtain equitable relief.
23.4 Nothing in this clause prevents the Company from seeking urgent injunctive, interim, or equitable relief in any competent court to protect its rights, property, or interests.
24.1 Singapore. Nothing in these Terms excludes or limits non-excludable rights under the Consumer Protection (Fair Trading) Act 2003 and other applicable law.
24.2 Malaysia. Nothing in these Terms excludes or limits non-excludable rights under the Consumer Protection Act 1999 (Malaysia) and related laws. Where such laws apply, our liability is limited to the minimum extent permitted.
25.1 Entire Agreement. These Terms, together with the Privacy Notice and any additional terms or policies incorporated by reference, constitute the entire agreement between you and the Company concerning your use of the App and supersede all prior agreements, understandings, or representations relating to the same subject matter.
25.2 Severability. If any provision of these Terms is held to be invalid, illegal, or unenforceable, that provision shall be deemed modified to the minimum extent necessary to make it valid and enforceable, and the remaining provisions shall remain in full force and effect.
25.3 Assignment. You may not assign, transfer, or delegate any of your rights or obligations under these Terms without the prior written consent of the Company. The Company may assign or transfer its rights and obligations under these Terms to any affiliate or successor in connection with a merger, acquisition, corporate restructuring, or sale of assets.
25.4 Waiver. No failure or delay by the Company in exercising any right or remedy under these Terms shall operate as a waiver of that right or remedy, nor shall any single or partial exercise preclude any other or further exercise.
25.5 Force Majeure. The Company shall not be liable for any delay or failure in performance resulting from causes beyond its reasonable control, including acts of God, natural disasters, pandemics, war, terrorism, labour disputes, network failures, or governmental actions.
25.6 Interpretation. Headings are provided for convenience only and do not affect interpretation. References to “including” or “includes” mean “including without limitation.”
25.7 Survival. Any provisions of these Terms which by their nature are intended to survive termination (including indemnities, disclaimers, and limitations of liability) shall continue to apply after termination or expiry.
If you have any questions, feedback, or concerns about these Terms or the App, you may contact us at:
Hugo Mobility Pte. Ltd. (UEN 201615566Z)
We will make reasonable efforts to respond to all legitimate enquiries within a reasonable time.
