1. What Data do we Process?
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 device. However, if such functions are disabled, you may not be able to use some of the Services);
(b) details about the device you use to access the Platform, which may include your IP address or other unique device 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; 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 and 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 and financial details.
2. What do we use the Data for?
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 optimise the Services and to improve and customise the user experiences of the Platform;
(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; and
(n) to design and provide products and services to you in relation to the above purposes.
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.
3. Do we disclose any Data to outside parties?
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.
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.
4. Do we Process any Data for marketing and promotional purposes?
We may from time to time send to you promotional and marketing materials and messages based on the Data (“Additional Purposes”).
The following classes of services, products and subjects 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 may provide the Data to Outside Parties for use by them in marketing their above services, products and subjects.
You may opt out from receiving any communications of Additional Purposes at any time 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. Any such request should also clearly state the details of Data in respect of which the request is being made.
Please note that after opting out, 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.
5. Can you access and correct your Data?
You 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 correct any Data which is inaccurate; and
(c) 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 such Data.
6. How do we protect the Data?
We have adequate measures to protect the Data from unauthorised access, accidental 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 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.
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 parts of the Services.
8. Retention of Data
Once we have obtained the Data, it will be maintained securely in our system; and subject to legal requirements 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.
9. Links to third-party websites
(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.
10. Data of minors and/or other individuals
11. Data Privacy Officer contact details
Your requests shall be sent to the Data Privacy Officer in the Region:
(a) If by email, please send your requests to:
Hong Kong: firstname.lastname@example.org
(Last update: February 2021)