PRIVACY POLICY

Last update: May 2026

The purpose of this Privacy Policy is to describe the conditions under which Gozem Pte. Ltd., together with its subsidiaries, affiliated companies, associated entities and jointly controlled structures (collectively referred to as “Gozem Group”, “Gozem” or “we”), collect, use, retain and protect your personal data, within the meaning of the applicable data protection regulations, when you access our platforms, in particular our mobile applications and the websites that we own or operate in connection with the provision of our services, products and solutions (the “Services”). It applies to all users of our services (“you” or “your”).

1

Collection of your personal data

Users of the Gozem application consent to the processing of their personal data when installing the Gozem application.

Your personal data is collected and processed by the company Gozem Pte. Ltd.

Gozem Pte. Ltd. only collects and processes the personal data submitted by users when installing and using the Gozem application.

The disclosure by the user of their geolocation data is a prerequisite for using the Gozem application.

1.1. Types of personal data

In connection with the provision and improvement of our services, Gozem may collect, depending on the features used, various categories of personal data concerning you, in particular:

Your surname, first name, gender, date of birth, telephone number, e-mail address, user profile picture, ratings and/or payment information of the user of the application; the user’s geographic location, time of the service and destination, identification data of the device on which the Gozem application was installed; the cookies of the Gozem.co website may record the user’s geolocation data and other available browsing data.


2

Purpose of the collection and duration of the processing of personal data

The personal data that you provide to us is processed by Gozem for the purposes set out below (the “Purposes”).

In addition, if you use several of our services or if you act in different capacities on our platform, whether as a Merchant, Champion or user of the services of the Gozem Group and its partners, we may cross-reference your data arising from these different activities, in order to optimise your experience and to meet the Purposes described below:

2.1. Provision of services and features

Your personal data is used to provide, personalise, maintain and improve our platforms and services. This includes using your personal data to:

  • provide you with services across our different business sectors, including within and between the Gozem entities where applicable;
  • create, manage and update your account;
  • process, manage or verify your eligibility or your application for products, services, promotions, rewards and subscriptions;
  • carry out due diligence, assess and monitor users’ risk profiles and perform ongoing risk analysis in order to ensure compliance with regulatory and operational requirements;
  • verify your identity and your eligibility;
  • validate your ride and process payments;
  • offer, obtain, provide, facilitate or maintain insurance or financing solutions;
  • track the progress of your ride, detect abnormal variations in your journey and improve the accuracy and reliability of navigation services using data from your device;
  • enable you to benefit from loyalty programmes or marketing activities organised by our merchant partners and/or in collaboration with Gozem;
  • personalise your experience by identifying your preferences and recommending relevant products and services to you;
  • make your experience smoother by automatically filling in your registration information when you move from one Service to another;
  • protect the security or integrity of the Services and of any facilities or equipment used to make the Services available;
  • enable communication between our users;
  • enable you to take part in our events, surveys and studies;
  • enable our partners to manage and allocate their fleet resources; and
  • perform the services provided to you as a data processor, where you have given your consent to the data controller for those services to be rendered.

In order to provide you with these services and features, we may use manual or automated means, in particular artificial intelligence services. We strive to ensure the accuracy and reliability of our AI services and, where necessary, we may review the results manually.

2.2. Safety and security

We use your data to ensure the security of our Services and of all users. This includes:

  • verifying the identity of Champions and Merchants before allowing them to join our Services;
  • identifying dangerous driving behaviour such as speeding, harsh braking and sudden acceleration; and providing personalised feedback to Champions;
  • verifying your identity when you log in to Gozem;
  • using gender information in order to personalise your experience on our platform, for example by assigning rides to people of the same gender;
  • using device, location, profile, usage, in-transit activity and other personal data to prevent, intervene in, detect and combat fraud or dangerous activities;
  • sharing the location and contact details of Champions and passengers when the emergency button or the “S.O.S” feature is activated; and
  • monitoring compliance with our terms and conditions and our policies.

2.3. User support

We use personal data to resolve user support issues. In particular, we may:

  • carry out investigations and respond to concerns;
  • monitor and improve our responses to user support;
  • respond to questions, comments and feedback; and
  • inform you of the measures taken to resolve user support issues.

2.4. Legal purposes

We may use the personal data we collect for legal purposes, in particular to:

  • prevent, detect, investigate, resolve or prosecute any attempted fraud, cybercrime or unlawful activity;
  • comply with court decisions, administrative injunctions and any requirements issued by governmental or regulatory authorities;
  • implement and enforce our Terms and Conditions of Use as well as any other agreement binding the user to the platform; and
  • defend our assets, our property rights and our strategic interests in the context of litigation, complaints or judicial investigations, in whatever jurisdiction.

2.5. Marketing and promotions

We may use your personal data to send you marketing communications relating to personalised products or services likely to be of interest or relevance to you based on your profile, or to the products, services, events or promotions of Gozem’s partners, sponsors and advertisers.

We may send you this marketing information by various means, where applicable including push notification, WhatsApp, Telegram, call and e-mail.

If you wish to unsubscribe from these marketing communications, please click on the unsubscribe link contained in the e-mail or message concerned. You may also change your preferences in the settings of our application. Please note that even if you choose no longer to receive marketing or promotional communications, Gozem may still send you messages relating to your account and/or to the service (such as two-factor authentication, information about your transactions, your rewards, etc.)

Any content that you post on the Gozem platform (reviews, comments, etc.) will be accessible to all users, together with your profile information (username, photos) as well as any other information that you have chosen to mention there.

2.6. Retention period of your personal data

Gozem retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, unless a legal obligation requires a longer period. This period varies according to the nature of the data, the context of its collection and the legal or operational requirements in force. By way of example, identity verification photographs are deleted no later than ten years after their collection, unless otherwise provided by law or by a court.

When your data is no longer useful, Gozem takes the appropriate measures to delete it, destroy it or render it permanently inaccessible, in compliance with the applicable legal obligations concerning security and fraud prevention.


3

The method of collecting personal data

We collect your personal data when you provide it to us. In particular, when you:

  • Complete a user registration form or personalise your profile (such as your name, your contact details and other identification information where necessary);
  • Provide information enabling your eligibility to provide services as a Champion or delivery provider to be assessed (such as information relating to your driving licence, your vehicle and the results of your background check);
  • Provide supporting documents, such as proof of disability or of eligibility for a discount, so that we can better support you as a Champion, delivery rider or user of our platform;
  • Provide information enabling your suitability to become a Merchant partner, Fleet manager, supplier or other Gozem partner to be assessed (such as the name and contact details of the authorised representative);
  • Interact with our social media pages (such as your social media account identifier, your profile picture and any content (for example, photos, videos, stories) that you create for publication on our social media channels;
  • Take part in competitions or events organised by us (such as the photos, audio recordings or videos that you may submit on our various channels, which may include images of yourself);
  • Fill in demographic information in surveys (such as your age, your gender and other information that you may provide voluntarily, such as your marital status, your occupation and your income);
  • Authorise us to access the events in your calendar (such as the dates, times and names or addresses of booking locations);
  • Apply for loans, insurance claims or other financing products in order to enable us to assess your eligibility (such as income statements, bank statements, accident information, medical certificates, proof of family relationship and relevant information that you may provide voluntarily);
  • Contact us via our various customer support channels (such as in-app help, messages, e-mails, call recordings, photos that you submit in support of your claim);
  • Submit reviews, comments, ratings, media or other content concerning a place and/or any service, which we may associate with your public profile page and display alongside it;
  • Interact with other users through our in-app communication features;
  • Agree to take a ride with on-board audio and/or video recording functions;
  • Use map-related features, such as live location sharing, in which case we may collect and use precise location information from your device with your permission;
  • Provide information through the use of our artificial intelligence (“AI”) services, for example when you ask questions to AI-powered chatbots or when you enter data into our AI solutions.

We verify your identity by various means (social media login, sending of selfies, liveness check or independent verification of your bank card details). For example, if you are a user, we may verify your identity by selfie as an additional security measure.

3.1. Collection of data from other sources

We may collect personal data, including but not limited to information concerning you such as customer information, your contact details, other identification information and financial data, where applicable, from other sources. These sources include:

Referral programmes; our commercial partners, such as fleet managers, payment service providers, vehicle rental partners and transport partners; insurance and financial services providers; risk intelligence and fraud assessment providers; credit rating agencies, payment network providers, alternative credit scoring agencies and any other third-party credit information body; public or governmental data sources; and marketing service providers or partners.

Some of our partners may install personal applications or devices in their vehicles for their own purposes. This practice is neither approved nor prohibited by Gozem.

The collection, use and disclosure of personal data obtained through personal on-board applications or devices is the responsibility of the partner concerned. Please contact that partner with any question relating to the use of personal dashboard cameras.

3.2. Collection of personal data concerning third parties

In certain situations, you may be required to provide us with personal data relating to other people, in particular when you designate them as an emergency contact, make a booking on their behalf or identify them as recipients or beneficiaries of our services.

By providing us with this information, you represent and warrant that you have obtained their prior consent to the collection, use and disclosure of their personal data, in accordance with this privacy policy.

3.3. Personal data of persons under a legal protection regime

Information for legal representatives

The safety and the protection of the privacy of users under a legal protection regime are a priority for Gozem. In connection with the use of our services on behalf of your minors under guardianship and adults under curatorship, it may be necessary to process certain of their personal data, in particular the surname, the first name, the telephone number, the date of birth and the location.

This information is used in order to verify their access to the dedicated features, such as ride tracking, as well as to facilitate exchanges through notifications or calls integrated into the application.

Additional data may also be collected where this proves necessary, subject to having an appropriate legal basis. By authorising the registration on the platform of a person who is subject to a legal protection measure, you consent, in your capacity as parent, guardian or curator, to the processing of their personal data.

Information for persons under a legal protection regime

The services offered may require the use of certain personal information provided by your legal representatives through the application. This data may include your surname, your first name, your telephone number, your date of birth as well as your location.

It is used to ensure your safety and to keep you informed of the services available. In certain cases, this information may be shared with trusted partners, such as Champions or delivery providers, in order to enable the requested services to be carried out.


4

Disclosure of personal data to third parties

In connection with the provision of our services, Gozem may be required to transfer certain of your personal data to third parties, strictly within the limits of what is necessary. In particular:

4.1. Sharing between users of the platform

Users’ personal data may be shared between them to the extent necessary for the provision and the proper functioning of the services offered by Gozem.

Certain information, such as the name, the telephone number, the geographic location or any other relevant data related to the service, may be disclosed to the users, partners, drivers, merchants, delivery riders or providers concerned, according to the operational needs of the service used.

After the service has been provided, the user’s name may remain visible to the driver. This is necessary in order to allow drivers to resolve any problem related to the provision of the service, for example to contact the user if an item has been left behind in the car.

Comments on the quality of the service are anonymous and drivers do not receive any information about the names and telephone numbers of the users who provided comments.

4.2. Sharing with third parties in connection with your services

We may disclose your personal data to service providers for the purposes set out in this privacy policy:

In the event of an incident, the information necessary for the handling of a claim notification may be shared with the insurance company and the competent authorities concerned.

In the event of authorisation to connect a third-party payment method, the data necessary for the transaction will be disclosed to the provider concerned.

4.3. Sharing with business account managers

If you use a Gozem Business account, your employer or the administrator of the group to which your account is attached will be able to access the data relating to your business transactions.

4.4. Sharing within the Gozem group

The entities of the Gozem group may share personal data between themselves in order to ensure the consistency, the reliability and the security of the services offered, as well as for the purposes of analysis, risk management and regulatory compliance.

We may transfer your personal data for commercial and direct marketing purposes to commercial partners or to affiliated companies.

Depending on the user’s location, their personal data may be transferred to the competent local entities providing the services of the Gozem application. Any collection and any processing of personal data by Gozem’s local service providers will be carried out under the same conditions as those set out in this privacy policy.

4.5. Sharing with the competent authorities

We will be entitled to disclose your personal data if a regulatory body, a governmental authority, a public official or a security body requests it from us for the purposes of an investigation into an alleged crime.

4.6. Restructuring or disposal transactions

In connection with a merger, acquisition, disposal or any other transaction involving all or part of Gozem’s business, your personal data may be transferred to the parties concerned, in compliance with the confidentiality undertakings previously accepted.


5

Security and deletion of data

In connection with its activities, Gozem may be required to transfer your personal data to other countries, in particular for the purposes of processing, storage, administration or technical support.

All personal data collected in connection with the provision of the Gozem service is transferred and stored in the data centre located in the territory of England.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do everything in our power to protect your personal data, we cannot guarantee the security of the data that you transmit to our sites. Once your information has been received, we will implement strict procedures and security measures in order to prevent any unauthorised access.

Please note that uninstalling the Gozem application from your device does not result in the closure of your account and, consequently, the deletion of your personal data.

If you wish to delete your personal data collected by Gozem, please send a written request for account closure and deletion of personal data by e-mail.

Please note that requesting the deletion of your personal data is only possible if we delete your account. Consequently, you will no longer be able to use the Gozem services with your current account. After deletion, your personal data will be anonymised and used solely for analysis purposes.

If you consider that we (or any other Gozem entity processing your personal data) are carrying out this processing in breach of your personal rights or of the law, in particular if the personal data is inaccurate, you may:

  • a) ask us (and/or any other Gozem entity processing your personal data) for an explanation;
  • b) ask us (and/or any other Gozem entity processing your personal data) to remedy the situation that has arisen (in particular by blocking, correcting or supplementing the personal data);
  • c) appeal directly to the data protection authority with competence over personal data.