Unless otherwise defined herein, capitalised terms used in this privacy policy (“Privacy Policy”) shall have the same meanings as those defined in our Terms and Conditions.
This Privacy Policy explains how we collect, hold, process, use, protect, store, share and transfer (collectively ‘‘Process’’, and ‘‘Processing’’ shall be construed accordingly) information and/or data provided by you to us, including but not limited to your personal data and information (“Data”) when you use the Platform. This Privacy Policy covers both the “online” (e.g., web and mobile services) and “offline” (e.g., collection of Data through telephone calls or in person) activities owned, operated, provided and/or made available by us. This Privacy Policy specifically addresses our obligations in respect of personal data privacy under the Relevant Laws. Where practicable, we undertake to also apply the principles and the processes set out in the Relevant Laws to our operations globally. If our operations are subject to privacy legislation other than that of the Region, then this Privacy Policy will apply so far as practicable and consistent with such legislation.
Please review this Privacy Policy carefully so that you understand our privacy policies and practices.
BY AGREEING TO GIVE US YOUR DATA WHILE UPON YOUR REGISTRATION TO THE PLATFORM, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS PRIVACY POLICY AND GIVE US YOUR CONSENT TO PROCESS YOUR DATA.
We request all persons using the Platform to voluntarily provide us with the Data (as set out in section 1 below) for the purposes as set out in section 2 and section 4 below. Do not use the Platform or give us any of your information if you do not agree to the terms of this Privacy Policy. However, we will not be able to provide Services to you if you do not provide such Data to us. If you wish to revoke your agreement to the terms of this Privacy Policy, please notify us by sending an email to our Data Privacy Officer in accordance with section 11 below or via any other means as prescribed by us from time to time. This Privacy Policy is an integral part of our Terms and Conditions.
We may update or change this Privacy Policy from time to time to reflect our latest privacy policies and practices as we deem fit pursuant to, inter alia, the prevailing relevant legislation and the changing business circumstances. Whenever a change is made, we will seek your express consent, objection or no objection thereto on the Platform. Any changes will be effective immediately upon posting of the revised Privacy Policy and your indication of consent or no objection thereto, whichever is later. The revised Privacy Policy will then supersede and prevail over the original Privacy Policy and form an integral part of our Terms and Conditions. You shall then be bound by such revised Privacy Policy.
By using the Platform, you acknowledge and agree that we may use various Google Application Program Interfaces (API) (including the Google Maps API), and you agree to be bound by the relevant Terms of Use and Privacy Policy (as may be amended by Google from time to time), which are incorporated herein by reference.
We may Process the following Data:
(a) your name, your email, your telephone number, and/or other contact details, as well as your location data (if you do not wish to provide us with location-tracking information, you may disable the GPS or other location-tracking functions on your online device. However, if such functions are disabled, you may not be able to use some of the Services);
(b) details about the device that you use to access the Platform, which may include your IP address or other unique device address or identifiers;
(c) cookies information as set out in section 7 below;
(d) any other information provided by you pursuant to your use of the Platform (including but not limited to the uploading of any images or photos); and
(e) if you contact us, a record of that correspondence.
If you are a Participating Provider, we may also Process the following Data:
(f) any registration and/or profile information and reporting information about your use of the Platform;
(g) details required in order to collect any fees from you and/or pay to you any fees as relevant;
(h) rating information (where other users of the Platform are able to rate you as a Participating Provider); and
(i) your performance, operational (including but not limited to the uploading of any images or photos such as electronic proof of delivery) and financial details.
You understand and acknowledge that this Privacy Policy may not apply to any unsolicited information which you provide to us through the Platform or through any other means in certain regions where we operate. Where applicable, all unsolicited information shall be deemed to be non-confidential and we shall be free to Process, reproduce, disclose and distribute such unsolicited information to others without limitation or attribution.
The purposes for our Processing of Data on the Platform and Services (“Purposes”) include the following:
(a) to verify your identity;
(b) to provide the Services to you, including processing any orders and payments;
(c) to operate, protect, improve and optimize all the features of the Services; to improve and customise the user experiences and usage trends of the Platform, and to develop new services, features and functionality;
(d) to notify you about changes to the Platform or respond to any communication and/or request from you;
(e) to monitor the use of the Platform;
(f) to investigate any reported incidents, complaints or potential breaches of the Services;
(g) where applicable and subject to compliance of the Relevant Laws, to provide you with marketing and promotional materials and messages in accordance with section 4 below;
(h) to identify whether you have enjoyed promotional benefits by receiving and using marketing and promotional materials;
(i) to compile aggregate statistics about you and to analyse the Platform and Services usage;
(j) where applicable and subject to compliance of the Relevant Laws, to match the Data with other Data collected for other purposes and from other sources including third parties in relation to the provision of Services to you;
(k) to facilitate our Processing of the Data for purposes relating to the provision of Services offered by us and marketing services, special events and/or promotions of us and/or our clients;
(l) to comply with our obligations under the applicable laws and regulations from time to time;
(m) to disclose to and/or assist relevant authorities where we suspect you have committed an offence, where we suspect existence of fraud or when required by the relevant laws or court orders, or as requested by relevant public and law enforcement authorities;
(n) to design and provide products and services to you in relation to the above purposes; and
(o) to use the Data we collect through our Services and/or Platform to help train our artificial intelligence model(s) for the Purposes outlined in this Privacy Policy.
We will seek your express consent to change how we Process the Data if required by the Relevant Laws, but otherwise use of the Services following such changes constitutes your acceptance of the revised statement then in effect.
We also reserve the right to disclose your information that we believe, in good faith, is appropriate and necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, or the rights, property, or safety of others.
We generally only permit our duly authorised staff to access the Data, and we will only release such Data to third parties under the following circumstances:
(a) where the Data is disclosed, provided and/or transferred to:
(i) any third-party suppliers or external service providers who have been duly authorised by us to use such Data and who will facilitate the Services on the Platform, under a duty of confidentiality;
(ii) our agents who have been duly authorised by us to use such Data;
(iii) any other parties in connection with a sale or proposed sale of all or part of our business or portfolio of products or other assets;
(iv) us, our business partners, and/or agents in connection with marketing and/or cross marketing about the goods or services which may be of your interest;
(v) any Outside Parties (as defined below) as set out in section 4 below;
(b) to credit reference agencies, debt collection agencies, fraud detection and/or prevention agencies;
(c) to any relevant public authorities or law enforcement agencies, including, for example, where we suspect you have committed an offence, where we suspect existence of fraud or where required by applicable law, regulation or legal proceedings;
(d) in order to enforce or apply our Terms and Conditions of your use of the Platform or any other agreement to which you and we are a party, as applicable; and
(e) where we deem necessary, in order to maintain and improve the Services.
We will not transfer any Data to any place outside Hong Kong save under circumstances allowed by Relevant Laws.
You should take care when using any Platform social networking features since the Data you disclose can be seen by other users. You understand and acknowledge that we cannot control the actions of other users of social networking features with whom you may choose to share the Data with. We do not monitor the use of such features in the normal course of business although we reserve the right to do so at our discretion. Therefore, you understand and acknowledge that we cannot and do not guarantee that the Data will not be reviewed by unauthorised persons.
We intend to and may from time to time make telephone calls to you or send you information directly by mail, fax, email or any other means of communication (including but not limited to the use of WhatsApp) based on the Data in order to offer or advertise the availability of goods, facilities or services or to solicit donations or contributions for charitable, cultural, philanthropic, recreational, political or other purposes (“Direct Marketing”).
In particular, the following classes of services, products and subjects are intended to and may be marketed:
(a) transport, logistics and automotive related products and services;
(b) special events hosted by us for you and other users of the Platform, including but not limited to competitions and social gatherings;
(c) reward, loyalty or privileges programmes in relation to the Services and related products;
(d) special offers in relation to the Services and related products, including but not limited to coupons, discounts, purchase offers and promotional campaigns;
(e) products and services offered by us and our business partners and agents which maybe of your interest;
(f) products and services offered by us and our advertisers (the names of which can be found in the relevant advertisements and/or promotional or marketing materials for the relevant products and services, as the case may be); and
(g) donations and contributions for charitable and/or non-profit making purposes.
The above products, services and subjects may be provided or solicited by us, third-party service providers providing the above services, products and subjects and charitable and/or non-profit making organizations (“Outside Parties”). We intend to and may provide the Data to Outside Parties for use by them in marketing their above services, products and subjects.
We may not use the Data in Direct Marketing or provide the Data to Outside Parties for their use in Direct Marketing unless we have received your consent to such intended use. Upon your registration to the Platform, you will be directed to a page where you will be asked to express consent, objection or no objection to all or parts of our intended use of the Data in Direct Marketing and to our intended provision of the Data to Outside Parties for their use in Direct Marketing. Your answer will be sent to and saved in our system.
In addition to Direct Marketing, you hereby consent that we may from time to time make telephone calls to you or send you information directly by mail, fax, email or any other means of communication (including but not limited to the use of WhatsApp) based on the Data in order to communicate with you.
Should there have been offline collection of your Data (e.g., by telephone calls or in person), your consent will be asked by our staff orally to express consent, objection or no objection to all or parts of our intended use of the Data in Direct Marketing and to our intended provision of the Data to Outside Parties for their use in Direct Marketing and for communicating with you through any means of communication from time to time. Within 14 days after our staff’s receipt of your indication of consent or no objection, we will send you a written confirmation by email or by post for your record.
Please note that by indicating your objection to all or parts of our intended use of the Data in Direct Marketing and to our intended provision of the Data to Outside Parties for their use in Direct Marketing and/or for communicating with you:
(a) you may not be able to use some or all of the Services; and
(b) you may still receive non-marketing and non-promotional messages, including but not limited to product updates and service notices as permitted under applicable local laws and regulations.
When we use your Data in Direct Marketing and for communicating with you for the first time, we will remind you of your right to require us to cease such use.
You are entitled to require us to cease to use your Data in Direct Marketing or to cease to provide your Data to Outside Parties for their use in Direct Marketing and/or for communicating with you at any time even after you have previously expressed consent or no objection to such use.
You (or a relevant person on your behalf) have the right, if expressly permitted by Relevant Laws, to:
(a) check whether we hold any Data and, if we hold the Data, to receive copies of such Data;
(b) request us to make necessary correction to any Data which is inaccurate; and
(c) request us to erase any of your Data in such form as you reasonably request on the Data Access Request Form and within a reasonable time we will provide a mechanism to erase such Data.
The Data Request Form can be obtained from: https://www.pcpd.org.hk/english/publications/files/Dforme.pdf. The completed form should be sent to the Data Privacy Officer in the Region in accordance with section 11.
(d) any other request that is expressly permitted by Relevant Laws.
Subject to Relevant Laws, we have the right to charge a reasonable fee for processing a data access request; and if expressly permitted by Relevant Laws, we shall provide you with an estimate of the fee after we receive a data access request from you. However, the final fee to be charged may differ from the estimated fee. If the final fee to be charged is higher than the estimated fee, we shall inform you of the higher fee. Your data access request may be refused if you do not pay the fee.
The aforementioned requests in relation to the Data may be made by contacting our Data Privacy Officer by email or by post in accordance with section 11 below. Any such request should also clearly state the details of Data in respect of which the request is being made and we may request you to prove your identity in relation to your request to access and/or correct and/or erase such Data.
We have adequate measures in place and will take all practicable steps to protect the Data from unauthorised or accidental access, processing, erasure, loss or destruction. Where we have given you (or you have chosen) a password which enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of Data via the Internet is not completely secure. While we endeavour to protect your Data, we cannot guarantee the security of Data transmitted to the Services; any transmission is at your own risk. Once we have received the Data, we will use strict procedures and security features to try to prevent unauthorised access. In case of cyber-security risks, we may issue warnings and provide instructions, guidance or suggestions in relation to coping measures to you in accordance with the Relevant Laws.
We use Google Analytics to help analyse how users use the Platform and Services. Google Analytics is a web analysis service provided by Google LLC. Google utilises the Data collected to track and examine the use of our Platform and Services, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualise and personalise the advertisements of its own advertising network. Google Analytics features implemented on this site include Display Advertising (Demographics and Interest Reporting). Google’s ability to use and share information collected by Google Analytics regarding your visits to the Platform is restricted by the Google Analytics Terms of Service.
We do use certain cookies (such as Google Analytics’ cookies) and other similar technologies as part of our Services. The cookies used are for the purposes of enabling you to use the Services (for example, to enable you to complete a registration or access information) and for us to understand and save your preferences for future visits, analyse usage patterns, keep track of advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools for the Platform in the future. We may contract with third-party service providers to assist us in better understanding our site visitors in accordance with this Privacy Policy.
You can choose to disable cookies (through changing your browser or device settings) although you should be aware that this may prevent you from being able to use all of the Services.
Once we have obtained the Data, it will be maintained securely in our system; and subject to legal requirements expressly provided in Relevant Laws and our internal policy, may be retained by us after deactivation of the relevant Services where such Data is still required for the purpose for which it was Processed.
Once your Data is no longer necessary or required for the purposes stated in section 2 above and any directly related purposes or is inaccurate, we will take all practicable steps to erase such Data as soon as reasonably practicable unless any such erasure is prohibited under any law or it is in the public interest for the Data not to be erased.
Subject to this Privacy Policy, at our discretion, we may include or offer third-party products or services on the Platform. You understand and acknowledge that the fact that we may include or offer third-party products or services on the Platform does not mean that we endorse or authorise the collection of Data by such third parties, nor does it constitute a representation of any affiliation between us and such third parties. You understand and acknowledge that:
(a) once you click on a link to third-party websites, applications or advertisements, you will access third-party websites, applications and advertisements which may collect Data;
(b) such third-party websites, applications and advertisements follow separate and independent privacy policies regarding the Processing of the Data you submit to them; and
(c) hence, we have no responsibility or liability for the content and activities of these linked websites, applications and advertisements (including any Processing of the Data by such third parties)
Nonetheless, we seek to protect the integrity of the Platform and welcome any feedback about these sites.
In some circumstances, you may have provided Data relating to minors and/or other individuals (e.g., individuals who are incapable of managing his or her own affairs or mentally incapacitated persons within the meaning of the Mental Health Ordinance (Cap.136)) and in such circumstances you represent and warrant that you are authorised to provide the Data to us and you have obtained their consent for the Data be Processed in the manner as set forth in this Privacy Policy.
Where applicable, as a parent or legal guardian, please do not allow the minor(s) under your care to submit the Data to us. In the event that such Data is provided to us, you hereby consent to the Processing of the minor’s Data and personally accept and agree to be bound by this Privacy Policy and take responsibility of his or her actions.
If we learned that Data has been collected on the Service from a minor and without verifiable parental consent, then we will take the appropriate steps to delete the Data information. If you are a parent or legal guardian and discover that a minor under your care has obtained an account on the Service, then you may alert our Data Privacy Officer at the contact in section 11 and request that we delete that minor’s Data information from our systems.
Your requests shall be sent to the Data Privacy Officer in the Region:
(a) If by email, please send your requests to:
Hong Kong: [email protected]
Singapore: [email protected]
India: [email protected]
Vietnam: [email protected]
(b) If by post, please send your requests to:
Hong Kong: P.O. Box 62499, Kwun Tong Post Office, Kowloon, Hong Kong
Singapore: 601 MacPherson Road #08-10, Grantral Complex @ MacPherson, Singapore 368242
India: 3rd Floor, No ⅓(½-2),Annachi Building, Soundarajan Street, Chennai, Tamil Nadu – 600017, India
Vietnam: Bluesky Office, 4th Floor, No.01 Bach Dang, Ward 2, Tan Binh District, Ho Chi Minh City, Vietnam
