Last Modified: 13 April 2020

This Privacy Policy and its Addendum(s), if any, (“Policy”) describe how Easy Eat AI Sdn. Bhd., its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “Easy Eat”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of Easy Eat’s Apps and Websites (including all mobile applications and websites operated by Easy Eat (respectively “Apps” and “Websites”), products, features and other services globally (collectively, “Services”).

This Policy applies to our customers, passengers, agents, vendors, suppliers, partners (such as driver and merchant partners), contractors and service providers (collectively “you”, “your” or “yours”).

“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information.

I. COLLECTION OF PERSONAL DATA

We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession.

You provide your Personal Data to us

We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

When our Services are used

Personal Data may be collected through the normal operation of our Services. Some examples are:

From other sources

When we collect Personal Data from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include:

Sensitive Personal Data

Some of the information that we collect is sensitive in nature. This includes information such as race, and your health or religious beliefs. We only collect this information when this is necessary to comply with legal or regulatory requirements.

Personal Data of minors

In the event that any Personal Data of a minor (i.e. individuals under the age of 18) is disclosed to Easy Eat, you hereby signify your consent to the processing of the minor’s Personal Data as a parent or legal guardian of the minor (or your agreement to procure the necessary consent from the minor’s parent or legal guardian) and accept and agree to be bound by this Policy and take responsibility for his or her actions.

In the event that you are a minor and intend to provide your personal data to Easy Eat, you hereby confirm and acknowledge that you have obtained your parent or legal guardian’s agreement to be bound by this Policy.

When you provide Personal Data of other individuals to us

In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may add them as your emergency contact. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used, processed and disclosed as set out in this Policy.

II. USE OF PERSONAL DATA

Easy Eat may use, combine and process your Personal Data for the following purposes (“Purposes”).

Providing services and features

Your Personal Data will be used to provide, personalise, maintain and improve our Services. This includes using your Personal Data to:

Safety and security

We use your Personal Data to ensure the safety and security of our Services and all users. This includes:

Customer support

We use Personal Data to resolve customer support issues. For example, we may:

Research and development and security

We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our services, develop new features, products and services, and facilitate insurance and finance solutions.

Legal purposes

We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law.

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.

Marketing and promotions

We may use your Personal Data to market Easy Eat and Easy Eat’s partners’ sponsors’ and advertisers’ products, services, events or promotions. For example, we may:

We may communicate such marketing to you by post, telephone call, short messaging service, in-car engagement, in-app engagement, online messaging service as well as push notification, by hand and by email.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, you may click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings.

The provision of your Personal Data to us is on a voluntary basis. However, if you do not provide your Personal Data or if insufficient Personal Data is supplied to us when requested, this may affect our ability to fulfil the purposes mentioned above and your ability to enjoy the full range of benefits provided by us under the Services.

III. DISCLOSURE OF PERSONAL DATA

We need to share Personal Data with various parties for the Purposes. These parties include:

With Easy Eat partners at your request

For example, if you requested a Service through a Easy Eat partner or used a promotion provided by a Easy Eat partner, Easy Eat may share your Personal Data with that Easy Eat partners. Our partners include partners that integrate with our App or our App integrates with, or business partners which Easy Eat collaborate with to deliver a promotion, competition or other specialised service.

With subsidiaries and affiliates

We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.

With Easy Eat’s service providers and business partners

We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:

With our legal advisors and governmental authorities

We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other relevant third parties. This may take place due to fulfil the legal purposes (mentioned above), or any of the following circumstances:

• where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or

• where it is in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).

IV. RETENTION OF PERSONAL DATA

We retain your Personal Data for as long you maintain your Easy Eat account. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to destroy or permanently delete such Personal Data for any purpose other than compliance with law, this privacy policy, or for purposes of safety, security, fraud prevention and detection.

V. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Your Personal Data may be transferred from country, state and city in which you are present while using our Services (“Home Country”) to another country, state and city (“Alternate Country”). You understand and consent to the transfer of your Personal Data from your Home Country to the Alternate Country.

VI. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS

Easy Eat, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of the Websites and Apps. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

Easy Eat may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes Easy Eat does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising on third party platforms.

If you do not wish for your Personal Data to be collected via Cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also limit our sharing of some of this Personal Data through your App (Settings > Privacy > Ads) and mobile device settings.

VII. PROTECTION OF PERSONAL DATA

We will take reasonable legal, organisational and technical measures to ensure that your personal data is protected. This includes measures to prevent data from getting lost, or used or accessed in an unauthorised way. We limit access to your personal data to our employees on a need to know basis. Those processing your personal data will only do so in an authorised manner and are required to treat your information with confidentiality.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore, any transmission remains at your own risk.

VIII. AMENDMENTS AND UPDATES

Easy Eat shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to use the Services, purchase products from Easy Eat or continuing to communicate or engage with Easy Eat following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.

IX. CONTACT

If you have any queries or complaints relating to your Personal Data, wish to make a request for access or correction of your Personal Data, or would like to withdraw your consent in respect of the Personal Data being processed by us, please contact:

Easy Eat Data Protection Officer

c/o Easy Eat AI Sdn. Bhd..

Floor 38, Mercu 2, 3 Jalan Bangsar

KL Eco City, 59200 Kuala Lumpur

WP. Kuala Lumpur

Email: hello@easyeat.ai

Contact No.: +60 11-2115 1875

The original of this Privacy Statement is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.