Effective Date: March 2025
This Privacy Policy (“Policy”) describes how Damoov Pte. Ltd. (“Damoov”, “we”, “us”, or “our”) collects, processes, stores, discloses, and protects Personal Data in connection with our telematics software development kit (“SDK”), DataHub platform, APIs, analytics services, and related products (“Services”).
1.1 “Personal Data” means any information relating to an identified or identifiable natural person as defined under applicable data protection laws.
1.2 “Institution” or “Client” refers to an organization (e.g., university, business) that engages Damoov and determines the purposes and means of processing Personal Data. Damoov acts as the Data Processor for such Clients.
1.3 “End User” means an individual who uses a mobile application or platform integrating Damoov’s SDK or telematics services.
1.4 “DeviceToken” refers to a pseudonymised identifier generated by the SDK used to process telematics data without direct personal identifiers.
2.1 This Policy applies to all processing of Personal Data performed by Damoov in relation to:
2.2 For Client deployments, the Institution acts as the Data Controller and Damoov acts as the Data Processor.
2.3 For direct consumers, Damoov acts as Data Controller.
3.1 Identifiers
Damoov processes only minimal identifiers necessary for telematics analytics, including:
3.2 Telematics and Mobility Data
All telematics processing uses pseudonymised identifiers (DeviceToken) and does not include personal identity attributes.
4.1 Damoov processes Personal Data strictly for:
4.2 Prohibited Uses
WE DO NOT:
5.1 When acting as Data Processor, Damoov processes Personal Data solely under the documented instructions of the Institution.
5.2 For direct End Users, processing is carried out under:
6.1 Damoov employs strong pseudonymisation measures, including:
6.2 Personal identity information is never stored within the telematics analytics pipeline.
7.1 Personal Data may be stored or processed in Singapore, the EU (Germany), or the United States.
7.2 All cross‑border transfers comply with:
8.1 Damoov may disclose Personal Data only to authorized subprocessors that provide strictly limited services such as:
System monitoring providers receive only operational metrics and do not receive any Personal Data, as logs are stripped of identifiers and include only internal technical references.
8.2 Subprocessors do not access raw telematics data or identifiable user information.
All telematics data processed internally is pseudonymised using DeviceToken (UUID), and no identity data is included in analytics pipelines.
8.3 For map-enrichment purposes, Damoov may transmit anonymised telematics elements, such as GPS waypoints or road geometry inputs, to third-party location services (e.g., HERE Maps, Google Maps).
These data points:
8.4 Damoov does not disclose Personal Data to any third party, including these enrichment providers, unless required by law or expressly instructed by the Client.
9.1 Personal Data is retained only as necessary to deliver Services or as instructed by the Institution.
9.2 Backups are maintained for a maximum of seven (7) days.
9.3 Upon Client request or contract termination, Damoov will:
10.1 Damoov supports all rights under GDPR, PDPA, and CCPA, including:
10.2 For institutional deployments, all rights requests must be submitted through the Institution.
Damoov employs administrative, physical, and technical safeguards including:
12.1 Damoov uses machine learning solely for telematics analytics, including:
12.2 ML models use only pseudonymised data.
12.3 No institutional data is used for external model training.
12.4 Institutions may opt out of ML-based analytics.
We do not release Personal Data to law enforcement without a valid warrant, court order, or legal obligation.
14.1 Damoov does not intentionally process Personal Data relating to children below the applicable age of digital consent under relevant laws (including COPPA, GDPR-K, and similar regulations).
14.2 Damoov does not collect identity information, age, or any attributes that would allow the Company to determine whether a data subject is a child.
The Damoov SDK is implemented within third-party applications, and the Company processes only pseudonymised telematics data (e.g., DeviceToken, sensor readings) that cannot be used to identify an individual or determine age.
14.3 Responsibility for verifying user age and obtaining all necessary parental or guardian consents rests exclusively with the Client or third-party application provider acting as the Data Controller.
14.4 By using Damoov Services, the Client confirms that all required consents have been obtained and that no Personal Data of children is submitted to Damoov without such consents.
We may update this Policy periodically. Material changes will be communicated to affected Clients.
For privacy inquiries, contact:
Damoov Pte. Ltd.
Email: [email protected]
Corporate Address: 68 Circular Road, #02-01, Singapore, 049422