HEYHO APP ("HeyHo App") is committed to safeguarding your privacy. This Privacy Policy (the “Policy”) describes HeyHo App’s policies and procedures regarding the collection, use and disclosure of the information collected through the HeyHo services via mobile applications, and other affiliated websites owned and operated by HeyHo App (the site, and any products and services provided by HeyHo App are collectively referred to as the "HeyHo Services," which includes the technology platform, as defined below). By using our HeyHo Site or HeyHo Services, you agree to the terms of this Policy. What is Personal Data In the course of engaging for our HeyHo Services, we will request that you provide data and information about yourself and/or your organisation (“Personal Data”) to enable us to enter into transaction with you or to deliver the necessary services and/or deliverables in connection with our business. Personal data means any data relates directly or indirectly to a data subject, who is identified or identifiable from that information or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject; but does not include any information that is processed for the purpose of a credit reporting business carried on by a credit reporting agency under the Credit Reporting Agencies Act 2010. Sensitive personal data means any personal data consisting of information as to the physical or mental health or condition of a data subject, his political opinions, his religious beliefs or other beliefs of a similar nature, the commission or alleged commission by him of any offence or any other personal data as the Minister may determine by order published in the Gazette. We will not process your Sensitive Personal Data, unless the you have given your “explicit consent” or where, for example, the processing is necessary for: the purpose of any legal proceedings; or (ii) the purpose of obtaining legal advice; or (iii) establishing, exercising or defending the data user’s legal rights. We do not intentionally gather Personal Data from visitors who are under the age of 13. If we learn that a child under the age of 13 has submitted Personal Data to HeyHo App, we will attempt to delete such data as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us. The following data is collected by or on behalf of HeyHo: Data provided by users. This includes: User Profile We collect data when users create or update their HeyHo accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of drivers and delivery persons, emergency contact information, user settings, and evidence of health or fitness to provide services using HeyHo App. This also includes gender and/or occupation (when required for certain HeyHo services or programs, if applicable). We may use the photos submitted by users to verify their identities, such as through facial recognition technologies. Background check and identity verification: We collect background check and identity verification information for drivers and delivery persons. This may include information such as driver history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on HeyHo’s behalf. We also collect identity verification from HeyHo users who request alcohol delivery. Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties. User content: We collect the information users submit when they contact HeyHo customer support, provide ratings or compliments for other users or restaurant partners, or otherwise contact HeyHo. This may include feedback, photographs or other recordings collected by users. Data created during use of our services. This includes: Location data (driver and delivery person): HeyHo collects this data when the HeyHo app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device. Location data (riders and delivery recipients). We collect precise or approximate location data from riders’ and delivery recipients’ mobile devices if they enable us to do so. HeyHo collects this data from the time a ride or delivery is requested until it is finished, and any time the app is running in the foreground of their mobile device. We use this data to enhance your use of our apps, including to improve pick-up locations, enable safety features, and prevent and detect fraud. HeyHo collects driver location data, and links location data collected during a trip with their rider’s account, even if the rider has not enabled us to collect location data from their device. This enables us to offer services to the rider like receipt generation and customer support. Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, delivery information, date and time the service was provided, amount charged, distance travelled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person. Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Site areas accessible only to registered users require that your browser accept Cookies. HeyHo App uses Cookies to verify that you are properly signed in, to display information for your primary location, and to highlight your pending reservations, for example. We may also use Cookies from time to time to measure your response to new aspects of the HeyHo Services and/or emails in an effort to continually improve customer service and HeyHo Services usability. Please be aware that a Cookie cannot spread computer viruses, retrieve any other data from your hard drive, or capture your email address. You can erase or block Cookies from your computer if you wish to do so (your internet browser help screen or manual will thoroughly explain this process), but certain parts of the HeyHo Services, as well as parts of the Site, may not work correctly or will not work at all if your browser is set not to accept Cookies. Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data. Communications data: We enable users to communicate with each other and HeyHo through HeyHo’s mobile apps and websites. For example, we enable drivers and riders, and restaurants or delivery persons and delivery recipients, to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, HeyHo receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. HeyHo may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics. Rental devices data: We collect data generated by rental devices, such as bicycles, scooters, or other light electric vehicles or devices, when they’re in use. This includes the date and time of use, and the location, route, and distance travelled. To the extent permitted by law, the location data collected from the rental device during the trip will be linked to the renter’s account, even if they have not enabled HeyHo to collect location data from their mobile device. Audio recordings: In certain jurisdictions, and where permitted by law, users can record the audio of their trips through an in-app feature. Recordings are encrypted and stored on users’ devices, and are only shared with HeyHo if submitted to customer support by the users in connection with safety incidents. Data from other sources. This includes: User feedback, such as ratings, feedback, or compliments. Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user. HeyHo account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of HeyHo for Business accounts. Users or others providing information in connection with claims or disputes. HeyHo business partners through which users create or access their HeyHo account, such as payment providers, social media services, or apps or websites that use HeyHo’s APIs or whose APIs HeyHo uses. Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes. Insurance, vehicle, or financial services providers for drivers and/or delivery persons. Partner transportation companies (for drivers or delivery persons who use our services through an account associated with such a company). Publicly available sources. Marketing service providers. HeyHo may combine the data collected from these sources with other data in its possession. Purpose of Collection of Personal Data Personal Data you provide will be collected, used and otherwise processed by us for, amongst others, the following purposes: the delivery of goods, services or deliverables and the marketing of such services or deliverables whether present or future, to you; to facilitate payment for our HeyHo Services; member or client relationship management procedures under the HeyHo App; our internal record keeping; meeting any legal or regulatory requirements relating to our provision of services and deliverables, and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular, code applicable to us; and enable us to send you information by e-mail, telecommunication means (telephone calls or text messages) or social media about products and services offered by selected third parties that we think may interest you. What are the effects arising from failure to provide Personal Data? The failure to supply such Personal Data will / may:- result in us being unable to provide you with the services and/or deliverables requested under HeyHo Services; and result in us being unable to update you on legal developments, our services, deliverables and/or launches. Disclosure Personal Data provided to us will generally be kept confidential but you hereby consent and authorize us to provide or disclose Personal Data to the following categories of parties:- any person to whom we are compelled or required to do so under law or in response to a competent regulatory or government agency or in compliance of an order of a court; government agencies, statutory authorities and industry regulators; our auditors, consultants, accountants, insurers, lawyers, or other financial or professional advisers and the Bar Council; our sub-contractors or third party service or product providers as may determine to be necessary or appropriate; Users are to note that the processing of Personal Data in certain instances have been excluded from compliance with the Disclosure Principle and we will disclose Personal Data that we collected when any of the circumstances below occurs. These instances and/or circumstances are as follows: where personal data is processed for the prevention or detection of crime or for the purpose of investigations; or where personal data is processed for the apprehension or prosecution of offenders; or where personal data is processed for the assessment or collection of any tax or duty or any other imposition of a similar nature; or where personal data is processed for the preparation of statistics or carrying out research (subject to the personal data not being processed for any other purpose and the resulting statistics or the results of the research being anonymised); or where personal data is processed for the purpose of or in connection with any order or judgment of a court; or where personal data is processed for the purpose of discharging regulatory functions; or where personal data is processed for journalistic, literary or artistic purposes. Security measures We will keep and process Personal Data in a secure manner. We endeavour, where practicable, to implement the appropriate administrative and security safeguards and procedures in accordance with the applicable laws and regulations to prevent the unauthorized or unlawful processing of Personal Data and the accidental loss or destruction of, or damage to, such Personal Data. The steps will be taken in consideration of the following: (i) nature of the Personal Data and the harm that would result from the lost, misuse, modification, unauthorised or accidental access or disclosure; the location where the Personal Data is stored; the security measures incorporated into the equipment in which the Personal Data is stored; the measures taken for ensuring the reliability, integrity and competence of personnel having access to the Personal Data; and (v) the measures taken for ensuring the secure transfer of the Personal Data. Rights of Access and Correction You have the right to request access to and correction of Personal Data held by us subject to 7 days prior written notice is given to us and in this respect, you may: check whether we hold or use such Personal Data and request access to such data; request that we correct any Personal Data that is inaccurate, incomplete or out-of-date; request that we specify or explain its policies and procedures in relation to data and types of Personal Data handled by us. 7. Retention of Personal Data We will process the Personal Data for the abovementioned purposes only and will not keep the Personal Data longer than is necessary for the fulfilment of that purposes. We are responsible to take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted in the event that you decided to closed or delete your HeyHo account and the Personal Data is no longer required for the purposes for which it was to be processed. Data Integrity We will take reasonable steps to ensure that the Personal Data is accurate, complete, not misleading and kept up-to-date by having regard to the purpose for which the Personal Data was collected and further processed. Language of this Policy This Policy is prepared in Bahasa Malaysia and English version. In the event of any conflicts in interpretation between the two versions, the English version will prevail to the extent of the conflict. Please address any queries or request to: [email protected]