We collect information which identifies or can be used to identify, contact, or locate the person or device to whom that information pertains or personal data (“Personal Information”). Personal Information includes, but not limited to, Your name, nick name, address, nationality, date of birth, occupation, contact number, fax number, e-mail address, bank details and credit-card details, gender, government issued identifier or document (e.g. NRIC, Passport, identification card and etc), motor vehicle information, insurance information or other photo, phone number of our users and non-users in your mobile phonebook/contact, and biometric information (including but not limited to facial recognition), others information about your transactions in relation to the Services such as reward points, reward points account balances, redemption history, and account activities as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Information”, means, data that is not associated with or linked to your Personal Information including, aggregated information. Anonymous Information does not, by itself, permit the identification of individual persons. Additionally, to the extent other information, including a personal profile, and/or unique identifier, is associated or combined with Personal Information, then that information is also Personal Information. The Personal Information which we collect may be provided by You directly or by third parties (for example: when You register or use the App, when You contact our customer services, or You otherwise provide Personal Information to us). We may collect information in various forms and purposes (including purposes permitted under applicable law).
In order to enable us to provide you this Service we may need to and/or may be required to collect, record, hold, use, disclose and store (i.e. “process”) Personal Information and Anonymous Information, including, but not limited to :
a) Information obtained from You or Your mobile phone or mobile device directly to us or through your relationship with us, including but not limited to, information provided by You when using the Services, when interacting with the Platform, Merchants or third parties Service Provider, when taking part in customer surveys, competitions and promotions. Examples include:
- When You register and create an account with us using the App You have to provide to us certain Personal Information, including Your full name, National Registration Identity Card (NRIC) number or passport number or reference number of any other official documents of the customer or beneficial owner, residential and mailing address, date of birth, nationality, profile picture/ photos/avatar, gender, ethnicity, marital status, educational level, interests, hobbies, occupation, precise location-based information, address, e-mail address, name of employer or nature of self-employment or nature of business, Your contact number and/or password, motor vehicle details, insurance details and any other information you directly give us through the Services (including, but not limited to messages that you send through the Services) that you will use to access the App after registration.
- When You use the App, you have to provide Us with relevant information as may reasonably be required by us in order for the App to work, for example:
a. If You are using the GoNet App as a user, You will need to provide us with information as to the type of service You seek, and details as You order, purchase, book, pay, pick-up and/or delivery info.
b. If You are using the GoNet Biz App as a Merchants, in order for the App or Site to work, you will need to provide us with the information on the services You are able to accept payment or orders for at the time, and details as to Your current, and after an order for a service placed by a user is accepted by You as the Merchants, You may need to provide us with other data that We need to manage the App and ecosystem, and to monitor overall usage of the App.
c. If You utilize and/or payment or transfer is made through the GoNetPay Account (E-money and/or E-wallet facility) provided by Us, if You are the payer, You will provide to Us information relating to the utilization, payment or transfer, including but not limited to the transfer and/or payment recipient details, the amount of payment paid.
d. If you intend to apply as registered or verified account holder of the GoNetPay Account facility provided by Us, You will provide to Us the required information including but not limited to your full name, National Registration Identity Card (NRIC) number or passport number or reference number of any other official documents of the customer or beneficial owner, residential and mailing address, date of birth, nationality, occupation type, name of employer or nature of self-employment or nature of business, contact number (home, office or mobile) and purpose of transaction.
- Information about Your interactions with the Services including, Your engagement with particular Merchants and the goods and/or services You have transacted.
- Information You disclose through Your interactions with the Merchants.
- Information necessary to complete a transaction through the Services, including Your name, transaction and shipping information where applicable.
- Information such as files and messages that You store using your App.
- Information from written communications when you provide us feedback or contact us e.g. your name, contact number and e-mail address, as well as any other content included in the e-mail, in order to send You a reply.
b) Information collected whenever You use the Platform:
- Whenever You use or access to the App or visit Our Site including Your web browser type, We may collect certain technical data concerning Your usage such as, internet protocol (IP) address (a number that is automatically assigned to Your computer when You use the Internet, which may vary from session to session), domain name, user profiles, and/or a date/time stamp for Your visit, and, with respect to Your mobile phone, information as web pages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, and also information regarding the manufacturer, model and operating system of the device that You use to access the App or our Site.
- Whenever You use or access the App through Your mobile phone or mobile device, We will track and collect your geo-location information in real-time. In some cases, You will be prompted or required to activate the Location Pin or Global Positioning System (GPS) feature on Your mobile phone or mobile device to enable Us to give You a better experience in using the App (for example, to give You information as to how close a Merchants is to you). You can always choose to disable the geo-location tracking information on Your mobile phone or mobile device temporarily. However, this can affect the functionalities available on the App.
- If You utilize and/or when a payment or transfer is made through the GoNetPay transaction provided by Us, We may collect certain information related to Your source of fund for reload or top up credit to Your GoNetPay Account including bank details and credit/debit card details, account details of withdrawal or receiver, transaction history (including receiver details), bill details, invoice details and phone number details.
- If You utilize GoNetPay Account or GoNet Biz account provided by us to receive payment from payer, whether You are a user’s or merchant’s, we may collect certain information related to your utilization including but not limited to service and/or goods transacted, amount You collect from every transaction, refund, withdrawal or settlement of account details and history.
Information collected from third parties
We may also collect Your Personal Information from third parties (including our merchants, agents, vendors, suppliers, contractors, partners and any others who provide services to us, perform functions on our behalf, or whom we collaborate with) or other sources which You have given Your consent to disclose information relating to You and/or where not otherwise restricted. In such cases, We will only collect Your Personal Information for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be). We do not collect your information for tracking purposes.
Information collected about third parties You provide to Us
- You may provide Us with Personal Information relating to other third-party individuals (including Personal Information relating to Your spouse, family members, friends, or other individuals). We will collect Your information and the third party’s information; names, contacts and email addresses in order to contact or send an e-mail or SMS and follow up with the third party.
- We do not mandate or endorse, nor prohibit, the installation or use of in-vehicle recording devices in any Vehicles. Where such devices are installed and used in any Vehicles, we do not collect any Personal Information from any in-vehicle recordings by such devices, and any collection of Personal Information from such in-vehicle recordings is not being done on our behalf. The collection of Personal Information from such in-vehicle recordings is solely at the discretion of the Merchants. We have no control over such collection of Personal Information by the Merchants and any subsequent use or disclosure by the Merchants of the Personal Information so collected. Where You are a Merchants and choose to install and use such in-vehicle recording devices in Your Vehicle, it is Your sole responsibility to notify the user of the same. Where You are a user and You have any objection to the use of in-vehicle recording devices within the Vehicle of any Merchants, You must inform the Merchants directly and it will be Your personal responsibility to do so.
- If You intend to use the features for e-money fund transfer services in GoNetPay Account, You will provide Us with the phone numbers of our App users stored on Your mobile phonebook/contact on a regular basis to enable You in using Our chat features and for other internal purposes.
- If You intend to use the features chatting services in GoChat, You will provide Us with the phone numbers of our App users stored on Your mobile phonebook/contact on a regular basis to enable You in using Our chat features and for other internal purposes.
We may use Personal Information collected for any of the following purposes stated above, either to respond to requests that You make, or to aid us in serving You better, whether or not through the App means, for one or more of the following purposes:
a) Where You are a user, we may use Your Personal Information:
- to identify You and to register You as a user and to administer, verify, deactivate, or manage Your GoNet Account as such;
- to facilitate or enable any verification as We may in Our discretion consider necessary before the Merchants provide You with the services or before we register You as a user, including Customer Screening process;
- to send You a One Time Password (OTP) and to verify ownership of the mobile number provided by Your before GoNet Account is created;
- to identify You as a user in Our system for security and verification purposes;
- to enable Merchants to provide you with such of the Services as You have requested;
- to process and facilitate orders, booking, refund and payment transactions made by You and our day-to-day operations and administrative purposes including account management, billing and collection, audits, reporting, investigations and internal audit purposes;
- to communicate with You and to send you information in connection with the use of the App;
- to notify You of any updates to the App or changes to the Services available;
- to process and respond to enquiries and feedback received from You to improve and customize the quality of experience when You interact with the Platform, and the Services;
- to maintain, develop, test, enhance and personalize the App to meet Your needs and preferences as a user;
- to monitor and analyse user activities, behaviour, and demographic data including trends and usage of the various Services available on the App;
- to process and manage Your loyalty programme and send offers or promotional materials related to our Services and for other marketing purposes;
- to offer or provide Services from our Merchants;
- to send You directories on Our Services; or goods, services and special offers by the Merchants whose goods and/or services or targeted marketing communications, advertisement, vouchers, promo code, promos, surveys, and information on special offers or promotions.
- to assist in the prevention, detection or investigation of crime or possible criminal activities or for the purposes of enforcing or defending our legal rights and/or obtaining legal advice;
- to track user-specific information on what pages users access or visit;
- for such other purposes incidental to the above and the usage of Our Service as may be directed or consented to by You; and
- for all other purposes in relation to or incidental to the above.
b) Where You are a Merchant, We may use Your Personal Information:
- to identify You to register you as a Merchants and to administer, manage or verify Your GoNet Biz Account as such;
- to facilitate or enable any verification as We may in our discretion consider necessary before we register You as a Merchants, including Merchants Screening process;
- to send You an email and to verify ownership of the e-mail address provided when Your GoNet Biz Account was created;
- to enable You to provide goods and/or services to users across the Platform or partners and third parties Service Providers;
- to process, facilitate, and complete payments or settlements due to You relating to any services You have provided;
- to communicate with You and send You information in relation to the provision of Your services, including to relay user orders to You and to facilitate Your acceptance of such orders;
- to provide You with notification and updates on the App or changes to the manner in which services are to be provided;
- to provide You with a report in relation to the services that you have provided;
- to process and respond to feedback from users on the services which You have provided;
- to maintain, develop, test, enhance and personalize the App to meet Your needs and preferences as a Merchant;
- to monitor and analyse user activities, behaviour, and demographic data including trends and Merchant’s responsiveness for the various services available on the App;
- to process and manage Your loyalty programme or services from You; and
- to offer or provide services direct to You from our affiliates or partners or others Merchants.
c) Whether You are a user or a Merchant or otherwise provide Personal Information to Us, We may also use Your Personal Information more generally for the following purposes (although we will in each such case always act reasonably and use no more Personal Information than what is required for the particular purpose):
- to undertake associated business processes and functions;
- to monitor usage of the App and administer, support and improve the performance efficiency, growth, user experience and the functions of the App;
- to provide assistance in relation to and to resolve any technical difficulties or operational problems with the App or the Services;
- to generate statistical information and analytics data for the purpose of testing, research, analysis, product development, commercial partnership, and collaboration;
- to prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activities;
- to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving Us and/or any of Our affiliates; and
- to enable us to comply with our obligations under any applicable law (including but not limited to responding to regulatory enquiries, investigations or directives) and conducting audit checks, due diligence and investigations.
a) Third Parties (including our merchants, agents, vendors, suppliers, contractors, partners and any others who provide services to us or you, perform functions on our behalf, or whom we enter into commercial collaboration with). We may share Your Personal Information with Merchants who may be located within or outside Malaysia:
- to provide You with the products and/or services that We offer You through Our Platform;
- to conduct quality assurance testing, or other activities including marketing, research, analysis and product development;
- to facilitate creation, authenticate You or connect with Your App Account;
- to provide technical support; and/or
- to provide other services to Us. These Merchants are not required to use Your Personal Information other than to provide the Services requested by Us.
c) Social Networking Sites (SNS). The Services may, with Your consent, automatically post, information on your SNS profile based on Your most recent activities.
d) We Do Not Share Personal Information with Advertisers, but…we do, however, allow advertisers to request that their advertisements are directed at certain users (e.g., users in a certain geographic location, or age, gender and/or with certain interests). In the event that You interact with certain advertisements, the advertisers (or the company which the advertiser works with, for example, its advertising agency or an advertising network) may determine certain characteristics about You.
e) Third Party directed or consented to by You. We may share Your Personal Information with any persons directed by or consented to by You including in connection with insured information or claim for the purpose of processing the insurance cover or claim to the insurance company that We engage or have collaboration with.
f) Professional Advisors. We may share Your Personal Information with Our professional advisors including but not limited to legal advisors, tax advisors, financial advisors, auditors, insurance brokers etc.
g) Other Disclosures. Regardless of any choices You make regarding Your Personal Information, We may disclose Your Personal Information if we believe in good faith that such disclosure is necessary:
- in connection with any legal investigation;
- to comply with relevant laws or to respond to subpoenas or warrants served on Us;
- to protect or defend our rights or property or users of the Services; and/or
Please note that there is still the possibility that some of Your Personal Information might be retained by the other parties (including by the Merchants, if you are the user; or by the user, if you are the Merchants) in some manner. Information relayed through communications between You and Merchants made other than through the use of the App (such as by telephone calls, e-mail, SMS, WhatsApp, mobile messaging or other method of communication) may also be retained by some means. We do not authorise and encourage the retention of Personal Information by such means and we have no responsibility to You for the same. We shall not be liable for any such retention of Your Personal Information.
You hereby agree to indemnify, defend and release us, our officers, directors, employees, merchants, agents, partners, suppliers, contractors and Affiliates from and against any and all claims, losses, liabilities, expenses, damages and costs (including but not limited to legal costs and expenses on a full indemnity basis) resulting directly or indirectly from any unauthorised retention of Your Personal Information.
a)Choices. We offer You choices regarding the collection, use, and sharing of Your Personal Information. Nevertheless, should You decline to provide any Personal Information that is essential to us to enable us to process your application/request (for example for the registration), we may not be able to process your application/request or provide You with this Service.
- We will periodically send you free newsletters, notification and e-mails that promote the use of the Services. When You receive newsletters, notification or promotional communications from Us, You may indicate a preference to stop receiving further communications from Us and You will have the opportunity to “Disable” instructions provided in the App or by contacting us directly.
b)Changes to Personal Information. You may not have access to or change of Your Personal Information in our possession or control through Your profile within Your Account. Any request of access to, or to correct or change, some or all of Your Personal Information may be subjected to a fee and also to the provisions of the applicable laws.
We reserve the right to decline or refuse Your requests that jeopardize the security and privacy of the Personal Information of others as well as requests that are impractical or not made in good faith. Additionally, it is important to note that system-recorded Personal Information is not editable. When We delete any information, it will be deleted from the active database, but may remain in our archives. To the extent of our possession or control if permitted or required under law, we may also retain your information for fraud prevention or similar purposes required by laws.
Confidentiality and security of Your Personal Information is of utmost importance to us. We will use all reasonable efforts to protect and regularly review and implement up-to-date technical and organisational security measures to safeguard the confidential and secure Your Personal Information against access, collection, use or disclosure by unauthorised persons and against unlawful processing, accidental loss, destruction and damage or similar risks. Unfortunately, the transmission of information via the Internet is not completely secure. Although We will do Our best to protect Your Personal Information, You acknowledge that We cannot guarantee the integrity and accuracy of any Personal Information which You transmit over the Internet, nor guarantee that such Personal Information would not be intercepted, accessed, disclosed, altered or destroyed by unauthorised third parties, due to factors beyond Our control.
You are responsible for keeping Your Account details confidential and You must not share your account details, including Your password and One Time Password (OTP), with anyone and You must always maintain and fully responsible for the security of the device that You use.
We and our Merchants may send You direct marketing, advertisement, and promotional communications via push-notification App, message, post, telephone call, short message service (SMS), and e-mail (“Marketing Materials”) if You have agreed to subscribe and/or consented to receive marketing and promotional materials from Us. You may disable from receiving such marketing communications at any time by clicking on any “Disable” facility embedded in the relevant message, or otherwise contacting us using the contact details stated below. Please note that if You disabled, we may still send You non-promotional messages or notifications, such as ride receipts or information about Your Account.
- The App, Site, and Marketing Materials may contain links to Applications, platforms or websites that are operated by third parties services and SNS. We do not control nor accept liability or responsibility for these websites and for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties and SNS. Please consult the Terms and Conditions and Privacy Policies of those third-party Applications, platforms or websites to find out how they collect and use Your Personal Information.
- Advertisements contained on Our App, Site, or Marketing Materials operate as links to the advertiser’s Applications, SNS, platforms or website and as such information they collect.
Where indicated (for example, during first-time sign-in for an Account), it is obligatory to provide Your Personal Information to us in order to enable us to process Your application for GoNet or GoNet Biz Account, or for us to provide You with our Services. Should You decline to provide such obligatory Personal Information, We may not be able to process Your application and/or provide You with Our Services.
We may create, use, license or disclose Personal Information, provided, however, (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, (ii) that has been combined with similar data such that the original data forms a part of a larger data set, and (iii) this Anonymous Information may be used to personalize the Services, including directing certain advertisements to make them more relevant to You or to analyse request and usage patterns so that we may enhance the content of the Services and improve the Platform navigation or for any related market research purposes, either internally or through third parties.
The accuracy and completeness of Your Personal Information depends on the information and documents You provide. We assume that the information You have provided is accurate, up to date and complete unless You inform us otherwise.
- In circumstances where You provide Us with Personal Information relating to other individuals (such as Personal Information relating to your spouse, family members, friends, or other parties) and Information, You represent and warrant that You have obtained such individual’s consent for, and hereby consent on behalf of such individual and to, the collection, use, disclosure and processing of his/her Personal Information and Information by Us.
- You may withdraw Your consent to any or all collection, use or disclosure of Your Personal Information at any time by giving us reasonable notice in writing using the contact details stated below. You may also withdraw Your consent for us to send You certain communications and information via any “Disable” facility contained in our messages or notifications to You. Depending on the circumstances and the nature of the consent which You are withdrawing, You must understand and acknowledge that after such withdrawal of consent, You may no longer be able to use the App or Services. A withdrawal of consent by You may result in the termination of Your Account or of Your contractual relationship with Us, with all accrued rights and obligations remaining fully reserved. Upon receipt of Your notice to withdraw consent for any collection, use or disclosure of Your Personal Information, We will inform You of the likely consequences of such withdrawal so that You can decide if indeed You wish to withdraw consent.