WHAT INFORMATION DO WE COLLECT AND WHY?

There are three categories of information we collect:

1. Information you provide
2. Information created when you use our App; and
3. information from other sources.

1. Information You Provide

When you use the App, you might provide us with (a) personal data; (b) places and preferences; and (c) direct communications.

Personal Data

In order for us to operate the App for your utility and enjoyment in an efficient and effective manner, we may need to collect the relevant personal data from you either manually or through the App.

Places And Preferences

You may choose to provide us with information on your places and preferences, such as home and work address, saved places, stops and bus routes, news and subject matter preferences, and other travel preferences. We process this information in order to provide you with personalised city-centric services. We also store and analyse this data in aggregate to improve the App (for example, by ranking certain journey results more highly than others), and to create and evaluate routes for the user.

Direct Communications

Communications you might send to us include responses to in-App survey questions, reporting a problem, or submitting queries, concerns or comments regarding the App. These messages to us will also contain details such as the type of phone you’re using, your service provider, and if you have enabled the location permissions in your device, the latitude and longitude of your location when you contact us. We process this information in order to fix problems in the App, to reply to your communications, and to send notification to users for communication purposes.

2. Information Created When You Use The App

The following are the types of information created when you use the App. We associate this information with an installation ID number that is randomly generated each time you install the App. We use this installation ID to identify the user and pseudonymise the data we collect from you. We do not access any permanent device ID numbers.

Location Information

Users of the App: We aggregate and analyse journey start and end points. Assuming you have enabled your device to provide location information and you have not entered your start point manually, we collect and use your start location information as determined through data such as GPS, mobile phone towers, and WiFi. If you have not enabled your device to provide location information, you will have to manually enter your start and end points, which is then the location information we collect and use. We collect your location information throughout your journey. We use this data to provide on-trip support, such as alerting you when to get off a bus and if there is any public transport disruption. We also store and analyse this data in aggregate, as we do with the other types of location data described in this “Location Information” section, to improve the journey results we show to all users and to create and evaluate routes for our transportation services. We also use the information collected in this section to provide more relevant information to you such as local happenings (news), or local suggestions (food suggestions, events and deals) from unusual sightings to interesting things to do near the location provided by you.

Device Information

We collect information about the devices you use to access and use our App, including the type of computer or device you use, the installation ID of the App on your device, the hardware models, operating systems and versions, software, file names and versions, the preferred languages, time zone settings, and device motion information. This information is necessary for us to diagnose bugs and improve the App.

Log and Usage Information

Each time you interact with our App, we collect information about how and when you use it, such as the time and date when you opened the App, the searches you make, the features and journey results you click on, pages visited, app crashes and other system activity. We log user usage screen and click data for analytic purpose and store using Google Firebase and Yahoo Flurry Analytics. We use this information to improve our App in multiple ways. For example, we report crashes that happen in the App to Google Firebase Crashlytic to fix bugs and prevent future crashes, and by knowing what gets tapped or scrolled most often, we can replace unpopular features with other, more helpful features.

3. Information from Other Sources

We partner with ManjaLink ( www.manjalink.com.my ) to provide user features such as Manjalink Wallet for the users to keep track of the balance of their card and to reload it. The App collects the following types of information from ManjaLink:

User feedback on the App

We receive feedback from users in the form of ratings, compliments or incidents. We use this feedback to improve the Users’ experience and to help ensure that the App is safe and reliable.

Payment information

In order to pay for your ride or to reload your ManjaLink card through the App, you will need to provide payment information to our third-party service provider such as your credit or debit card details. Ipay88 will be the payment gateway used by ManjaLink.

Personal information

In order for Ipay88 to process the payment and to communicate any issues in relation to payment or to confirm that payment has been successfully made by you, we will provide your e-mail address and phone number to Ipay88.

HOW WE USE YOUR INFORMATION, SUMMARISED

In summary, we use the information we collect to:

• Provide and improve our App;
• Build a profile of your preferences so we can personalise the App and provide you with relevant transport and city information;
• Recommend alternative and/or similar options that match your stated preferences and previous use of the App;
• Process or facilitate payment (through third party payment processing services) for ManjaLink;
• Respond to your emails to discuss your use of the App and answer any support queries you may have;
• Send you marketing communications by email or in-App notifications;
• Identify issues with the operation of the App, and provide crash reports in order to find resolution for performance issues;
• Improve the design, functionality and/or content of the pages of the App and customise them for you;
• Carry out research on users;
• Send you information we think you may find useful (e.g. public transport disruptions, alerts, newsletters, festive greetings, updates about the App or any other relevant information to you);
• For us to perform the services as requested by push notification and/or email (if provided);
• Inform you of our services/ products;
• For internal administrative purposes, such as auditing, data analysis, and database records;
• For us to comply with any obligations under any laws and regulations imposed by the competent authorities;
• To communicate with you for any of the purposes listed herein; and
• For all other purposes incidental and associated with any the above.

We work hard to improve the App and add functionality, which we think will make it efficient, more fun and more useful for our users. New functionality may involve similar or incidental uses of your data to those set out above. We regularly review the way we use data, and will update our privacy policy to reflect these improvements to the App.

WHAT OTHER COMPANIES WILL RECEIVE YOUR INFORMATION?

We may share the information collected amongst the companies within our group of entities comprising of the subsidiaries, associate companies (“the Group”) and Group’s agents, third party providers, contractors, developers, advertisers, partners, event companies, sponsors or any other parties duly authorized by the Company and Group who may communicate with you for any reasons whatsoever. In doing so, we will comply with all applicable laws, regulations and industry standards.

To the extent we share information with other companies, we do so to enhance your experience with the App, and we pseudonymise and minimize the data we send to them.​

• Search Partners: Our search partner is Google in order for the App to send you to the places you want to go. They receive the text you have searched for, and in order to return results most relevant to you, they receive your current location if you have enabled location permission in your device.
• Analytics Partner: We use Yahoo Flurry and Google Firebase to understand what you’ve tapped or clicked on the App, and we make features improvements based on this information. They receive information showing only that a person has tapped or used certain features in the App.
• Crash/Error Reporting Vendors: We use Google Firebase Crashlytics to report on crashes you experience with the App.
• Messaging Apps: If you choose to use certain sharing features in our App, then you may be sharing your information with those companies, depending on factors such as that company’s encryption policies. For example, if you use the “Share Directions” feature in the App, a link with your start and end points will be sent via messaging app. If the messaging app company you choose uses end-to-end encryption, your location link cannot be used or intercepted by that messaging app company.

If you do not wish to have the information collected by us shared with any other third parties (including the Group), kindly inform us by sending your request to the email address specified below.

WHAT’S OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION?

We will only process your information where we have a legal basis for doing so. Our legal basis to process your data information collected includes processing that is:

• necessary for our legitimate interests, which are:

1. to research, develop, fix and provide new and tailored features for our App users (e.g., ranking journey routing results in a way that surfaces more relevant routes at the top);
2. to evaluate routes;
3. to provide on-trip support to users and to ensure that the App are safe and secure for users;
4. to accept and administer payment from users for use of ManjaLink; and
5. to prevent breaches of our terms and policies or to prevent harmful or illegal activity;
6. to provide city data (e.g. weather forecast, road closure alerts) that can help improve users’ travelling experience
7. to provide more relevant articles (e.g. food reviews, event listings) according to user’s preferences

• necessary for the efficient performance of the App (e.g., to find you the route options you have requested in the App);
• necessary to comply with relevant legal requirements (for example, to comply with applicable regulatory obligations and to make mandatory disclosures to law enforcement); and
• based on your consent (for example, where you provide us with marketing consents), which may be withdrawn at any time by contacting us at the email address specified below.

HOW DO YOU GIVE YOUR CONSENT TO US?

By communicating with us, using the App, or by virtue of your engagement with us, you acknowledge that you have read and understood this privacy policy and agree and consent to the use, processing and transfer of the information collected by us as described in this privacy policy.

WHAT ARE YOUR RIGHTS IN RELATION TO THEPERSONAL DATA WE HOLD ABOUT YOU?

Access
You shall, upon written request, whenever possible, be granted access to all personal data held or stored or processed by us. To avoid confusion, “access” for the purposes of this section shall mean notification of such personal data of yours that is processed by or on behalf of us and to have a copy of such personal data communicated or conveyed to you in an intelligible form of our choosing.

Portability
Whenever possible, you shall have the right to receive the personal data concerning you, which you provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another party.

Deletion
Subject to any legal obligations to keep your information longer, we store your personal data for as long as is necessary to provide our services and products, or until you ask us to delete it only if it is possible for us to do so, whichever comes first. If you ask us to delete your personal data by emailing us at support@lugo.live, please use the subject line “Account Deletion.” Once we received your written request, our Protection Data Officer communicate with you before proceeding to delete your personal data. Note that residual copies may take longer to be removed from our backup systems. We will keep a record of your request in order to ensure compliance with legal obligations.

Marketing opt-out
You have the right at any time to prevent the use of your personal data for direct marketing purposes. If you no longer want to receive marketing messages from us, please let us know by writing to our Data Protection Officer at the email address given below, and you will be unsubscribed accordingly. Please note that sometimes it can take a short amount of time to refresh our records for these purposes.

Notifications
We may send you information we think you may find useful or which you have requested from us by push notification and/or by email (if provided), and we or your device’s operating system will give you the option to opt-out of receiving further notifications or emails.

Correction
Notwithstanding anything to the contrary, you may at any time withdraw your consent for us to use your personal data by writing to us in accordance with the procedures set out in the PDPA and GDPR. We shall take all necessary measures to give effect to your withdrawal of consent, to the extent that such withdrawal does not conflict with any of our other legal obligations.

Withdrawal of Consent
Notwithstanding anything to the contrary, you may at any time withdraw your consent for us to use your personal data by writing to us in accordance with the procedures set out in the PDPA and GDPR. We shall take all necessary measures to give effect to your withdrawal of consent, to the extent that such withdrawal does not conflict with any of our other legal obligations.

HOW WE KEEP YOUR INFORMATION SECURE

We place great importance on the security of all information associated with our users. We use measures such as encryption, pseudonymisation, information access controls, and firewalls. Keep in mind that submission of information over the internet and mobile networks is never entirely secure. We cannot guarantee the security of information you submit via the App whilst it is in transit over the internet or mobile networks and any such submission is at your own risk.

WHAT COUNTRIES WILL YOUR PERSONAL DATA BE SENT TO?

Information that you submit via the App is sent to and stored on secure servers located in Singapore. Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above, which may be situated outside Singapore.

DO YOU COLLECT CHILDREN’S INFORMATION?

We do not knowingly collect personal data from children under the age of 16. If you’re under the age of 16, please do not submit any personal data through the App or email. We encourage parents and legal guardians to monitor their children’s internet use and to help enforce our privacy policy by instructing their children never to provide personal data on our website without their permission. If you have reason to believe that a child under the age of 16 has provided personal data to us, please contact us as specified below, and we will work to delete that information from our databases.

HOW WILL YOU KNOW ABOUT CHANGES TO OUR PRIVACY POLICY?

We may revise this privacy policy from time to time. Any changes and additions to this privacy policy will be posted in the App and are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your personal data. This privacy policy is the first version published by us.

WHAT IF YOU HAVE A COMPLAINT?

We work hard to handle your personal data responsibly. If you’re unhappy about the way we do this, please contact our Data Protection Officer at support@lugo.live, +65 6363 5133, 3 Church Street #17-02 Samsung Hub, Singapore. However, you also have the right to lodge a complaint about the data processing activities carried out by us with the Personal Data Protection Commission in Singapore and the Information Commissioner’s Office in UK.

HOW TO GET IN TOUCH WITH US

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal data by communicating with our Data Protection Officer at support@lugo.live , +65 6363 5133, 3 Church Street #17-02 Samsung Hub, Singapore.