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1. General
1.1 This is the privacy policy for the EASI app and website (together, our "Platform") operated by HungryPanda SG Pte. Ltd. ("we" or "us" or "Hungry Panda"), incorporated and registered in Singapore, whose registered office is at 68Circular Road, Singapore
1.2 Here at Hungry Panda, we respect the privacy of all individuals who interact with us and we are committed to being responsible and transparent about the personal data we collect and use. We will only process personal data in accordance with our obligations under all applicable data protection and privacy legislation in force from time to time in the SG or any successor legislation, and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (including, without limitation, the privacy of electronic communications) (together, the “Data Protection Laws”).
1.3 If you have any queries or requests concerning this privacy policy or how we handle your data more generally, please contact our general customer services team at: support@hungrypanda.co or our Data Protection Officer: legal@hungrypanda.co .
1.4 This policy, together with our Terms and Conditions, sets out
1.5 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1.6 By using our services you acknowledge you have read and understood this policy.
2. How we collect and use your personal data
2.1 As part of our commitment to the privacy of our Platform users, we want to be clear about the data we collect from you and be transparent about how we use your personal data.
2.2 We collect your personal data when you interact with us or use our services, such as:
(a) when you create an account with us or you change your account settings;
(b) when you place an order with us and during the order process (including for payment and order delivery);
(c) when you contact us directly via email, phone, post, message or via our chat function; and
(d) when you browse and use our Platform (before and after you create an account with us).
2.3 We will only process your personal data if there is a legitimate reason for doing so under the Data Protection Laws. We will have a lawful basis for processing your information:
(a) if we need to process your information in order to provide you with the service you have requested or to enter into a contract;
(b) we have your consent;
(c) we have a justifiable reason, which is in our legitimate interests, for processing your data; or
(d) we are under a legal obligation to do so.
2.4 When you visit our Platform or make an order through our Platform, you are asked to provide information about yourself including your name, contact details (mobile phone number or email address), delivery address, order details. These are basic personal data (“Basic Data”) we collect and use to fulfil our contractual obligations to you (i.e. use your contact details to deliver the food that you ordered on our Platform to you).
2.5 We also collect and process health information about you (e.g. allergies or dietary requirements) when you place an order via our Platform. These are special categories of personal data (“Special Data”) and we will only process these data when you have given us your explicit consent to do so; i.e. by voluntarily providing these information when placing an order on our Platform. We do not keep Special Data; we will only process Special Data in accordance with our legal and contractual obligations to you (i.e. informing the restaurant about your dietary requirements as per your order specification).
Payment Information
2.6 We do not process any of your financial data directly. When paying for an order placed via our Platform, you are re-directed to our collaborating third-party payment providers’ (such as PayPal, Stripe, Barclays, Alipay, Worldpay or such other FCA-regulated third-party payment gateways as Hungry Panda may work from time to time) secured platform. Your personal data will be processed by these third-party payment providers strictly in accordance with the relevant payment card industry standards. Personal data which you supply to any third-party payment providers are not within our control.
Automated interactions
2.7 As you interact with our Platform, we may automatically collect information from your device by using cookies and other similar technologies. Processing such information is necessary for us to pursue our legitimate interests in improving our services and optimise customer experience. An example of personalisation of our service, including processing data to make it easier and faster for you to place orders. By way of an example:
(a) We collect technical information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Platform.
(b) We also collect technical information about your use of our Platform through a mobile device, for example, carrier, location data and performance data such as mobile payment methods, interaction with other retail technology such as use of NFC Tags, QR Codes and/or use of mobile vouchers.
(c) Unless you have elected to remain anonymous through your device and/or platform settings, this information may be collected and used by us automatically if you use the service through your mobile device(s) via any Hungry Panda mobile application, through your mobile's browser or otherwise.
Our legitimate interests in the above include:
(a) to improve the effectiveness and quality of service that our customers can expect from us in the future;
(b) to tailor content that we or our third-party restaurant or advertising partners display to you, for example so that we can show you restaurants which are in your area based on where you tell us you are;
(c) to enable our customer support team to help you with any enquiries or complaints in the most efficient way possible;
(d) to contact you for your views and feedback on our services and to notify you if there are any important changes or developments to the Platform or our services, including letting you know that our services are operating in a new area, where you have asked us to do so;
(e) to analyse your activity on the Platform so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud;
(f) to enforce our contractual terms with you and any other agreement, and for the exercise or defence of legal claims and to protect the rights of Hungry Panda, restaurant partners, riders, or others (including to prevent fraud); and
(g) if you submit comments and feedback regarding the Platform and the services, we may use such comments and feedback on the Platform and in any marketing or advertising materials. We will only identify you for this purpose by your first name and the city in which you live.
2.8 Where we rely on legitimate interest as a basis for processing your personal data, we carry out a 'balancing test' to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests.
2.9 Image information (photos and videos), data collected, and for what purpose: a. When you register your account you will need to upload image、photos to set your avatar, homepage information, etc. b. After an order is completed, you may upload image of products for evaluation. c. You will need to use them in communication with others such as customer service. d. Other situations where not using image、photos will affect our ability to provide you with services.
3. Our promotional updates and communications
3.1 Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal data for marketing analysis and to provide you with promotional update communications about our products or services.
3.2 Where you have consented to receive marketing information from us, we may send you direct marketing materials to promote our service and to keep you updated with information about our services. We may do so via emails or text messages. If you want to opt out these marketing communications, you can freely unsubscribe via link in the text and the email or contact us directly.
4. Retention of your personal data
4.1 We will not retain your personal data for longer than it is necessary, and we will ensure the secure erasure of your personal data.
4.2 The data that we collect will be retained for as long as needed to fulfil the purposes outlined in the 'How we collect and use your personal data' section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws, such as retaining the data for regulatory reporting purposes.
4.3 When determining the relevant retention periods, we will consider factors including:
(a) our contractual obligations and rights in relation to the data involved;
(b) legal obligation(s) under applicable law to retain data for a certain period of time;
(c) statute of limitations under applicable law(s);
(d) our legitimate interests where we have carried out balancing tests (see section on 'How we collect and use your personal data' above);
(e) actual or potential disputes;
(f) the establishment, exercise or defence of any actual or potential legal claim; and
(g) guidelines issued by relevant data protection authorities.
5. Disclosure of your personal data
5.1 All of our Platform users’ personal data are stored securely on our servers located within the EU.
Sharing your personal data internally
5.2 We may share your personal data with other Hungry Panda group companies only where it is necessary for the purposes set out in the ‘How we collect and use your personal data’ section above.
Sharing your personal data with third parties
5.3 We may share your personal data with third-party service providers acting on our behalf when it is necessary to carry out our services and fulfil our contractual obligations to you. Any third-party service provider will only use your personal data to provide the service under appropriate contractual arrangements with Hungry Panda. Any third-party service provider that we use must act in accordance with our instructions and the Data Protection Laws. The types of third-party service providers whom we share your information with includes:
(a) Payment providers (including online payment providers and fraud detection providers): for the purposes of providing services to us, for example when they process information such as credit card payments for us, provide support services to you or carry out fraud checks for us;
(b) IT service providers (including cloud providers): for the purposes of data storage and analysis;
(c) Restaurant partners: that you have placed your order with so that they can fulfil your order, be made aware of any food allergies you have volunteered to tell them about, resolve issues, or improve their services;
(d) Riders: so they can deliver your order to you;
5.4 Hungry Panda will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy when it is transferred to third parties.
5.5 If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your personal data may be disclosed or transferred to the target company, our new business partners or owners or their advisors.
5.6 We may also share your personal data:
(a) if we are under a duty to disclose or share your personal data in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention;
(b) in order to enforce our contractual terms with you and any other agreement;
(c) to protect the rights of Hungry Panda, restaurant partners, riders, or others, including to prevent fraud.
6. Where we store your data & international data transfers
6.1 As part of Hungry Panda global business and IT infrastructure needs, at times, it may be necessary for Hungry Panda to process your personal data outside of the Singapore.
6.2 Where your personal data is transferred outside the Singapore, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.
6.3 We may transfer your personal data outside the Singapore:
(a) in order to store it.
(b) in order to enable us to provide goods or services and fulfil our contract with you or the company you work for. This includes order fulfilment, processing of payment details, and the provision of support services.
(c) where we are legally required to do so.
(d) as part of normal application operation and processing.
(e) in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
6.4 We may transfer your personal data to the following countries and entities outside the Singapore:
We using “Standard Contractual Clauses” with entities outside the Singapore to ensure that they comply with the Data Protection Laws when processing your personal data.
7. Security
7.1 We adopt robust technologies and policies to ensure your personal data are adequately protected.
7.2 We take steps to protect your personal data from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We use security measures such as MD5 encryptions, access controls, data separations and other methods to ensure your personal data is kept safe and secure.
7.3 Where you have chosen a password that allows you to access certain parts of our Platform, you are responsible for keeping your password safe and confidential. You should not share your password with anyone.
8. Your rights
8.1 Under the Data Protection Laws, you have various legal rights in relation to your personal data. If you wish to exercise any of these rights, please contact our Data Protection Officer using the contact details set out above. This policy does not list every right that you have under the Data Protection Laws but we have set out the ones we consider most relevant to you in the context of engaging our services and using our Platform:
(a) The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. Should you find it difficult to understand this policy, or if you wish for us to further explain any aspects of this policy, please feel free to contact us directly.
(b) The right of access. You have the right to obtain access to your personal data (if we're processing it). This will enable you, for example, to check that we're using your personal data in accordance with the Data Protection Laws.
(c) The right to rectification. You are entitled to have your personal data corrected if it is inaccurate or incomplete.
(d) The right to erasure. This is also known as 'the right to be forgotten' and, in simple terms, enables you to request the deletion or removal of certain of your personal data that we hold about you.
(e) The right to restrict processing. You have rights to 'block' or 'suppress' further use of your personal data.
(f) The right to data portability. You have the right to obtain your personal data in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers.
(g) The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your personal data with the national data protection authority .
(h) The right to withdraw consent. If you have given your consent to anything we do with your personal data (i.e. where we rely on your consent as a legal basis for processing your data), you have the right to withdraw that consent at any time.
(i) The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling. You can object by changing your marketing preferences as set out above.
8.2 Should you wish to exercise any of your rights outlined above, please contact our Data Protection Officer or our general customers service team. In most cases, we will deal with your requests free of charge and within one month of receipt of your request. However, we may charge a reasonable fee to cover our administration costs and/or extend the time period for dealing with your request to two months, where your request is complex or repetitive. If this is the case we will keep you informed.
8.3 We will never charge you to change your marketing preferences or unsubscribe to our promotional updates and communications.
9. Contact Us
We welcome your feedback and questions. If you would like to contact us, please send us an email.
General customer service team: support@hungrypanda.co
Data Protection Officer: legal@hungrypanda.co
10. Changes to our privacy policy
Any changes to our privacy policy will be posted on our Platform. This privacy policy was last updated: June 2022.