PRIVACY POLICY

1. INFORMATION WE COLLECT

Personal Information

We collect information that you provide directly to us when using our services:

• Name and contact details (email address, telephone number, mailing address)
• Driving license information and passport/NRIC details
• Payment card information and billing address
• Vehicle preferences and rental history
• Communication preferences and correspondence records

Automatically Collected Information

When you access our website, we automatically collect certain information:

• Browser type, device information, and operating system
• IP address and geographic location
• Pages visited, time spent on pages, and navigation patterns
• Referral URLs and search terms used to find our website
• Cookies and similar tracking technologies (see our Cookie Policy)

Legal Basis for Processing

We process your personal data based on:

• Contract Performance: Processing necessary to fulfill our rental service agreements
• Consent: Where you have provided explicit consent for specific processing activities
• Legitimate Interest: Business operations, fraud prevention, and service improvement
• Legal Obligation: Compliance with Singapore laws and regulations

2. HOW WE USE YOUR INFORMATION

We use collected information for the following purposes:

Service Delivery

• Processing and managing vehicle rental reservations
• Verifying driver eligibility and insurance coverage
• Coordinating vehicle delivery and collection services
• Providing customer support and responding to inquiries
• Sending booking confirmations and rental documentation

Business Operations

• Processing payments and managing billing
• Maintaining accurate business records
• Analyzing service usage patterns to improve offerings
• Conducting quality assurance and staff training
• Detecting and preventing fraud or security breaches

Marketing Communications

• Sending promotional offers for new services or vehicles (with consent)
• Providing information about rental packages and special programs
• Sharing news about Viathorn and automotive design content
• You may opt out of marketing communications at any time

3. DATA SHARING AND DISCLOSURE

We share your information only in the following circumstances:

Service Providers

We engage third-party service providers who process data on our behalf:

• Payment processors for secure transaction handling
• Insurance providers for coverage verification and claims
• IT service providers for hosting and technical support
• Marketing platforms for email communications (with consent)
• Analytics services to understand website usage patterns

All service providers are contractually bound to protect your data and use it only for specified purposes.

Legal Requirements

We may disclose information when legally required:

• To comply with Singapore laws, regulations, or court orders
• To respond to lawful requests from government authorities
• To protect our rights, property, or safety, or that of our clients
• To investigate potential fraud or security incidents

4. DATA SECURITY MEASURES

We implement comprehensive security measures to protect your personal information:

Technical Safeguards

• SSL/TLS encryption for all data transmission
• Secure servers with firewall protection
• Encrypted storage for sensitive personal data
• Regular security audits and vulnerability assessments
• Intrusion detection and prevention systems

Operational Safeguards

• Access controls limiting data access to authorized personnel only
• Staff training on data protection requirements and best practices
• Confidentiality agreements with all employees and contractors
• Regular backup procedures with secure off-site storage
• Documented incident response procedures

Data Breach Notification

In the event of a data breach that may affect your rights, we will notify you and the Personal Data Protection Commission of Singapore within 72 hours of becoming aware of the breach, in accordance with PDPA requirements.

5. DATA RETENTION

We retain your personal information for specific periods based on legal requirements and business needs:

• Rental Records: 7 years from completion (for tax and insurance purposes)
• Payment Information: As required by financial regulations
• Marketing Consent: Until you withdraw consent or request deletion
• Customer Communications: 3 years from last contact
• Website Analytics: 26 months maximum

After retention periods expire, we securely delete or anonymize your data unless longer retention is required by law.

6. COOKIES AND TRACKING

We use cookies and similar technologies to enhance your website experience. Types of cookies we use:

• Essential Cookies: Required for website functionality (always active)
• Analytics Cookies: Help us understand website usage patterns
• Marketing Cookies: Used for personalized advertising
• Preference Cookies: Remember your settings and choices

You can manage cookie preferences through our Cookie Policy page or your browser settings. Note that disabling certain cookies may affect website functionality.

7. YOUR PRIVACY RIGHTS

Under Singapore's PDPA, you have the following rights:

Access and Portability

• Request copies of personal data we hold about you
• Receive your data in a structured, commonly used format
• Transfer your data to another service provider where technically feasible

Correction and Update

• Correct inaccurate or incomplete personal information
• Update your contact details or preferences

Deletion and Restriction

• Request deletion of your personal data (subject to legal retention requirements)
• Restrict certain processing activities
• Object to processing based on legitimate interests

Consent Withdrawal

• Withdraw consent for marketing communications at any time
• Opt out of non-essential data processing activities

How to Exercise Your Rights

To exercise any of these rights, contact us at [email protected]. We will respond to your request within 30 days.

8. CHILDREN'S PRIVACY

Our services are intended for individuals aged 25 years and older who meet our rental eligibility requirements. We do not knowingly collect personal information from individuals under 18 years of age. If we become aware that we have inadvertently collected data from a minor, we will promptly delete such information.

9. INTERNATIONAL DATA TRANSFERS

Viathorn operates primarily within Singapore. Some service providers may be located outside Singapore. When we transfer data internationally, we ensure appropriate safeguards are in place:

• Standard contractual clauses approved by Singapore authorities
• Adequacy decisions confirming equivalent data protection standards
• Binding corporate rules for transfers within corporate groups
• Your explicit consent where required

10. THIRD-PARTY WEBSITES

Our website may contain links to third-party websites, including social media platforms, partner sites, or service providers. We are not responsible for the privacy practices or content of these external sites. We recommend reviewing the privacy policies of any third-party sites you visit.

11. POLICY UPDATES

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or operational needs. Significant changes will be communicated through:

• Prominent notice on our website
• Email notification to registered clients
• Updated "Last Updated" date at the top of this policy

Continued use of our services after policy updates constitutes acceptance of the revised terms.

12. CONTACT INFORMATION

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

Data Protection Officer

Viathorn

333 Orchard Road, #07-12

Singapore 238867

Email: [email protected]

Phone: +65 6851 3427

If you are not satisfied with our response, you have the right to lodge a complaint with the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.