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Privacy Policy 

HelloJack! Privacy Policy September 2019

 

This privacy policy explains how HelloJack! Limited (a limited liability company incorporated under the laws of Hong Kong), its subsidiaries, affiliates and associated companies (“we”, “us” or “our”) collect, hold, process, use, share and protect personal data about you when you use our HelloJack! mobile application, website or other platform (“HelloJack!”). This privacy policy covers both the “online” (e.g., web and mobile services) and “offline” (e.g., collection of data through telephone 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 Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong SAR (the “Ordinance”).

 

Where practicable, we undertake to also apply the principles and the processes set out in the Ordinance to our operations globally. If our operations are subject to privacy legislation other than that of Hong Kong SAR (for example, the Personal Data Protection Act 2012 of Singapore), 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 using HelloJack! or by otherwise giving us your information (INCLUDING PERSONAL DATA), you acknowledge and agree to the terms of this privacy policy. We will request all persons using HelloJack! to voluntarily provide us with the personal data (as set out in section 1 below) for the purposes as set out in section 2 below. Do not use HelloJack! 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 (such term as defined in our Terms and Conditions) to you if you do not provide such information about you to us. 

 

We may update or change this privacy policy from time to time to reflect our latest privacy policies and practices. Any changes will be effective immediately upon posting of the revised privacy policy. If we make material changes, we will notify you by means of a notice on HelloJack!. We recommend that you review our privacy policy regularly for information about our latest privacy policies and practices.

 

Since we use the Google Maps Application Program Interface (API), Google’s privacy policy, as may be amended by Google from time to time, is incorporated by reference: http://www.google.com/privacy.html.

 

1.  What information do we collect, hold, process and/or use about you?

We may collect, hold, process and/or use the following data about you:

–  your name, your email, your telephone number and your location data (if you do not want your devices to provide us with location-tracking information, you can 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.);

 

–  details about the device you use to access HelloJack!, which may include your IP address or other unique device identifiers;

 

–  cookies information as set out in section 7 below;

 

–  any other information provided by you pursuant to your use of HelloJack!; and

 

–  if you contact us, a record of that correspondence.

 

 If you are a driver/courier user of HelloJack!, we may also collect, hold, process and/or use the following data about you:

 

 –  your contact details, other registration or profile information and reporting information about your use of HelloJack!;

 

–  details required in order to collect and pay to you any fees as relevant;

 

–  ratings information (where other users of HelloJack! are able to rate you as a HelloJack! driver/courier); and

 

–  your driver/courier performance, operational and financial details.

 

 You understand and acknowledge that this privacy policy does not apply to any unsolicited information you provide to us through HelloJack! or through any other means. All unsolicited information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose and distribute such unsolicited information to others without limitation or attribution.

 

 

2.  What do we use your information for?

The purposes for our collection, holding, processing and/or use of information and/or data about you on HelloJack! include the following:

–  to verify your identity;

 

–  to provide the Services to you, including processing any bookings and payments;

 

–  to operate, protect, improve and optimize the Services and to improve and customize the experiences of you and other users of HelloJack! when using the same;

 

–  to notify you about changes to HelloJack! or respond to any communication and/or request from you;

 

–  to monitor the use of HelloJack!;

 

–  to investigate any complaints or potential breaches of the Services;

 

– to send you marketing and/or cross marking information about our products or services which maybe of your interest (including but not limited to, products and services of our affiliates, holding companies, subsidiaries, fellow subsidiaries, our business partners and our agents);

 

–  where applicable and subject to compliance of the Ordinance, to provide you with marketing and promotional materials for your enjoyment of benefits as users of HelloJack!;

 

–  only when you have provided the consents required under the Ordinance, to provide you with personal newsletters, marketing and promotional messages and other information as set out in section 4 below;

 

–  to identify those of you who have enjoyed benefits as users of HelloJack! by receiving and using marketing and promotional materials;

 

–  to design and provide products and services to you in relation to the above purposes;

 

–  to compile aggregate statistics about you and to analyze HelloJack! and service usage;

 

–  where applicable and subject to compliance of the Ordinance, to match (as defined in the Ordinance) your personal data with other data collected for other purposes and from other sources including third parties in relation to the provision of goods and Services to you;

 

–  to facilitate our use of your personal 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;

 

–  to comply with our obligations under the applicable laws and regulations from time to time; and

 

–  to disclose to and/or assist relevant authorities where we suspect you have committed a criminal offence, where we suspect existence of fraud or when required by the relevant laws or court orders, or as requested by relevant law enforcement authorities.

We will seek your (or seek from your respective relevant persons (as such term is defined under the Ordinance)) express consents to changes in how we use (including disclose) your personal data if requested by law, but otherwise use of the Services following such changes constitutes your acceptance of the revised statement then in effect.

 

 

3.  Do we disclose any information to outside parties?

 

 

 

We generally only permit our duly authorized staff to access your personal information and data, and we will only release such personal information and data to third parties under the following circumstances:

–  where the information and/or data is disclosed and/or transferred to any third-party suppliers or external service providers who have been duly authorized by us to use such information and/or data and who will facilitate the Services on HelloJack!, under a duty of confidentiality;

 

–  where the information and/or data is disclosed and/or transferred to our agents who have been duly authorized by us to use such information and/or data;

 

–  where the information and/or data is disclosed and/or transferred to 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;

 

– where the information and/or data is disclosed and/or transferred to us (including but not limited to, our affiliates, holding companies, subsidiaries, fellow subsidiaries, our business partners and our agents) in connection with marketing and/or cross marketing about the products or services which maybe of your interest;

 

–  only when you have provided the consents required under the Ordinance, where the information and/or data is disclosed, provided and/or transferred to any Outside Parties (as defined below) in connection with direct marketing as set out in section 4 below;

 

–  to credit reference agencies, debt collection agencies, fraud detection and/or prevention agencies;

 

–  to any relevant public authorities or law enforcement agencies, including, for example, where we suspect you have committed a criminal offence, where we suspect existence of fraud or where required by applicable law, regulation or legal proceedings;

 

–  in order to enforce or apply the terms and conditions of your use of the HelloJack! or any other agreement to which you and we are a party, as applicable; and

 

–  where we deem necessary, in order to maintain and improve the Services.

You should take care when using any HelloJack! social networking features since the information you choose to make available can be seen by other users in the selected group. You understand and acknowledge that we cannot control the actions of other users of social networking features with whom you may choose to share your information (which may include your personal data). 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 your information (which may include your personal data) will not be reviewed by unauthorized persons.

 

 

4.  Do we use any information for direct marketing?

 

 We may from time to time send to you personal newsletters, promotional/marketing materials and messages based on the personal information and data that you have provided to us only if you have given us the consent (including, an indication of no objection) as required under the Ordinance to use your personal data for such purpose. We may use your information and data in direct marketing and we require your consent (including, an indication of no objection) as required under the Ordinance to use your personal data for that purpose.

 

 The following classes of services, products and subjects may be marketed:

 

 –  transport, logistics and automotive related products and services;

 

–  special events hosted by us for you and other users of HelloJack!, including but not limited to competitions and social gatherings;

 

–  reward, loyalty or privileges programmes in relation to the Services and related products;

 

–  special offers in relation to the Services and related products, including but not limited to coupons, discounts, purchase offers and promotional campaigns;

 

– products and services offered by us (including our affiliates, holding companies, subsidiaries, fellow subsidiaries, our business partners and our agents) which maybe of your interest;

 

– 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

 

–  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 your personal information and/or data to Outside Parties for use by them in marketing their above services, products and subjects and we require your consent (including, an indication of no objection) as required under the Ordinance to use your personal data for that purpose.

 

 

5.  Can I access and correct my personal data?

In accordance with the terms of the Ordinance and subject to the exemptions specified in the Ordinance, you (or your respective relevant persons as defined under the Ordinance on your behalf) have the right to:

–  check whether we hold personal data about you and, if we hold personal data about you, to receive copies of such data; and

 

–  require us to correct any personal data relating to you which is inaccurate.

In accordance with the terms of the Ordinance, we have the right to charge a reasonable fee for processing a data access request.

Requests for access to personal data, correction of personal data and information relating to the kind of data held, may be made by contacting our Data Privacy Officer by email at info@HelloJack!.hk or by post at HelloJack!, P.O. Box 62499, Kwun Tong Post Office, Kowloon. Any such request should also clearly state the details of personal 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 your personal data.

 

 

6.  How do we protect your personal data?

 

We have adequate measures to protect your personal information from unauthorized 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 information via the Internet is not completely secure. While we will do our best to protect your information and data, we cannot guarantee the security of data transmitted to the Services; any transmission is at your own risk. Once we have received your information and data, we will use strict procedures and security features to try to prevent unauthorised access.

 

 

7.  Do we use cookies?

We use Google Analytics on our website to help analyze how users use the site. Google Analytics is a web analysis service provided by Google LLC. Google utilizes the data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize 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 this site 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, analyze 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 HelloJack! 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. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

 

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 personal data

Once we have obtained your personal information and/or data, it will be maintained securely in our system. Subject to legal requirements and our internal policy, your personal information and/or data may be retained by us after deactivation of the relevant Services where such personal data is still required for the purpose for which the personal data was used.

9.  Links to third-party websites

 

Subject to this privacy policy, at our discretion, we may include or offer third-party products or services on HelloJack!. You understand and acknowledge that the fact that the we may include or offer third-party products or services on HelloJack! does not mean that we endorses or authorizes the collection of personal data from you to such third parties, nor does it constitute a representation of any affiliation between us and such third parties. You understand and acknowledge that, 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 information from you. You understand and acknowledge that such third-party websites applications and advertisements follow separate and independent privacy policies regarding the collection, holding, processing, use and/or disclosure of the personal data you submit to them. Hence, you understand and acknowledge that we have no responsibility or liability for the content and activities of these linked websites, applications and advertisements (including any collection, holding, processing, use and/or disclosure of your personal data by such third parties). Nonetheless, we seek to protect the integrity of HelloJack! and welcome any feedback about these sites.

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