Privacy Policy

1. Introduction

Torquevine ("we," "our," or "us") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our luxury car rental services or visit our website.

We operate in accordance with Singapore's Personal Data Protection Act 2012 ("PDPA") and maintain the highest standards of data security and privacy protection.

For any questions regarding this policy or our data practices, please contact us at [email protected].

2. Data Collection Information

2.1 Personal Data We Collect

We collect the following categories of personal information:

• Identification Information: Full name, NRIC/passport number, date of birth, driver's license details
• Contact Information: Email address, phone number, residential or business address
• Financial Information: Credit card details, billing information (processed through secure payment gateways)
• Rental Information: Vehicle preferences, rental duration, pick-up and drop-off locations, driving history
• Technical Information: IP address, browser type, device information, cookies, and similar technologies

2.2 How We Collect Data

We collect personal data through:

• Reservation forms submitted through our website or in person
• Phone conversations and email correspondence
• Vehicle handover and return processes
• Cookies and analytics tools on our website
• Third-party service providers (insurance companies, payment processors)

2.3 Legal Basis for Processing

We process your personal data based on:

• Contractual Necessity: To fulfill rental agreements and provide services
• Consent: For marketing communications and optional services
• Legitimate Interests: For business operations, fraud prevention, and service improvement
• Legal Obligations: To comply with Singapore laws, including LTA and tax regulations

2.4 Data Retention Periods

We retain personal data for the following periods:

• Rental records and contracts: 7 years (tax and legal compliance)
• Payment information: 6 years (financial record-keeping requirements)
• Marketing consent records: Until consent is withdrawn or 3 years of inactivity
• Website analytics data: 26 months
• Correspondence and inquiries: 3 years from last contact

3. Data Usage Explanation

3.1 How We Use Your Data

We use your personal information to:

• Process vehicle reservations and manage rental agreements
• Verify driver credentials and insurance eligibility
• Facilitate payment processing and billing
• Communicate regarding reservations, vehicle availability, and service updates
• Send weather briefings for convertible rentals
• Provide route guidance and parking recommendations
• Coordinate valet services and vehicle delivery
• Generate environmental impact reports for corporate clients
• Improve our services through feedback analysis
• Comply with legal obligations including tax reporting and vehicle registration

3.2 Data Sharing with Third Parties

We may share your personal data with:

• Insurance Providers: To verify coverage and process claims
• Payment Processors: To handle credit card transactions securely
• Vehicle Service Centers: For maintenance coordination (limited to vehicle and contact details)
• Government Authorities: When required by Singapore law (LTA, IRAS, police investigations)
• Professional Advisors: Lawyers and accountants bound by confidentiality obligations

We do not sell your personal data to third parties. All service providers are contractually obligated to protect your information and use it only for specified purposes.

3.3 Marketing Communications

With your consent, we may send:

• Promotional offers for vehicle collections
• Seasonal driving recommendations
• Updates about new services or amenities
• Corporate client newsletters

You can withdraw marketing consent at any time by clicking "unsubscribe" in our emails or contacting [email protected].

4. Data Protection Measures

4.1 Security Measures

We implement comprehensive security measures:

• 256-bit SSL encryption for data transmission
• Secure server infrastructure with regular security audits
• Access controls limiting employee access to personal data
• Encrypted storage for sensitive information including payment details
• Regular security assessments and vulnerability testing
• Staff training on data protection and privacy procedures

4.2 Data Breach Procedures

In the event of a data breach affecting your personal information:

• We will assess the breach within 24 hours
• Notify the Personal Data Protection Commission if required under PDPA
• Inform affected individuals within 72 hours if there is significant risk
• Take immediate steps to secure systems and prevent further unauthorized access
• Provide guidance on protective measures you can take

5. Cookie Information

Our website uses cookies to enhance user experience and analyze site usage. We use:

• Essential Cookies: Required for website functionality (session management, security)
• Analytics Cookies: To understand how visitors use our site (Google Analytics)
• Preference Cookies: To remember your settings and preferences

You can manage cookie preferences through our Cookie Policy page or your browser settings. Disabling certain cookies may affect website functionality. For detailed information, see our Cookie Policy.

6. User Rights Section

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

6.1 Right to Access

You can request a copy of your personal data we hold. We will provide this within 30 days of your request, subject to identity verification.

6.2 Right to Correction

You may request correction of inaccurate or incomplete personal data. We will update our records within 10 business days after verification.

6.3 Right to Withdraw Consent

You can withdraw consent for marketing communications or optional data processing at any time. This will not affect the lawfulness of processing based on consent before withdrawal.

6.4 Right to Data Portability

Upon request, we can provide your personal data in a structured, commonly used format for transfer to another service provider where technically feasible.

6.5 How to Exercise Your Rights

To exercise any of these rights, contact us at:

• Email: [email protected]
• Phone: +65 6345 8271
• Mail: 501 Bukit Timah Road, #03-07, Singapore 259760

We may require identity verification before processing your request to ensure data security.

7. Third-Party Links

Our website may contain links to third-party websites including insurance providers, payment processors, and mapping services. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

8. Children's Privacy

Our services are not directed to individuals under 21 years of age (Singapore's minimum car rental age requirement). We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from someone under 21, we will delete it promptly.

9. Policy Updates

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. The "Last Updated" date at the top indicates the most recent revision.

Significant changes will be communicated through:

• Email notification to registered users
• Prominent notice on our website
• For corporate clients, notification through account managers

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

10. Contact Information

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

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with Singapore's Personal Data Protection Commission at www.pdpc.gov.sg.