We, HOTPIE (MALAYSIA) SDN. BHD., view and value the personal data of our users/customers seriously. This Privacy Notice describes how the Company, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “the Company”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of HOTPIE’s mobile applications and websites (respectively “Apps” and “Websites”), as well as products, features and other services globally, operated by the Company (collectively, the “Services”).

This Notice applies to our users, customers, consumers, agents, vendors, suppliers, partners, contractors and service providers (collectively “you”, “your” or “yours”).

We kindly ask you to study and understand this Notice and indicate your agreement and consent to all of the below by acknowledging at the indicated space provided.

“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, employment information and financial information.

We typically collect, use, disclose or otherwise process your Personal Data in accordance with this Privacy Notice with your consent, or in compliance with applicable laws, such as where:

• it is required for us to comply with legal requirements;
   

• it is required for us to enter into or perform a contract with you; and/or
   

• for our legitimate interests or the legitimate interests of any other persons, including but not limited to for the purposes set forth in this Privacy Notice.
   

 

1. Collection, Sources and Use of Personal Data

1.1 In the course of your dealings and transactions with us, you may be requested to furnish your personal data, from time to time, to enable us to enter into transactions, e.g. to create your account in order to provide you with access to our Services, to respond to your enquiries, to deliver notices, to provide information and updates and/or to communicate with you on the Services and/or products related to our business and render Services and to generally comply with any regulatory requirements.

1.2 Your personal data will be obtained from the following sources, where applicable or such sources which we may see fit from time to time, including but not limited to:

a. Any forms relating to registration (whether in electronic or hardcopy format);
b. Publicly available or publicly accessible information;
c. Any other written or verbal communications or documents delivered to us prior to and during usage of the mobile application known as The Company or any future names it may adopt;
d. Your interactions with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
e. Your participation in contests or events organised by us (such as pictures, audio, or videos you may submit, which may include images of yourself);
f. Various means of identity verification (such as social media logins, submission of selfie images or independently verified payment card information);
g. Demographic information you provide in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation and income information).

1.3 If you use Facebook or Google to register for or log in to the Services (or later connect your accounts), you authorize Facebook or Google, as the case may be, to share your personal information with us, including your email address, profile photo, birthday, and publicly available information about you and your Facebook friends, if you use Facebook for signup.

1.4 We may collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources. Such sources include:

a. Referral programmes;
b. Our business partners;
c. Credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
d. Publicly available or governmental sources of data;
e. When our users add you as an emergency contact;
f. When our users add you as a recipient or beneficiary of any use of our Services;
g. When you use our in-app chat;
h. Marketing services providers or partners; and/or
i. From your browser and device.

 

2. Types of Personal Data That We May Collect from You

2.1 When you use our App, we automatically collect and store certain information about your computer or mobile device and your activities. We may also collect your personal data as you provide the same to the Company, including but not limited to:

• Name, age, identity card/passport number, gender, address, email address, contact numbers, date of birth, marital status, occupation, income range, race and religious beliefs, nationality;
   

• Your location information;
   

• Device information (such as hardware model and serial number, IP addresses), file and app names and versions, GPS location, IMEI number, and advertising identifiers or any information that may indicate device or app modification;
   

• Credit card or bank account details;
   

• Feedback, ratings and compliments;
   

• Information of third parties such as your emergency contact person or authorised representatives.
   

The list of personal data stated above is not exhaustive and may include other personal data depending on the nature of dealings and transactions.

2.2 Your IP address is automatically assigned to your devices by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.

2.3 We automatically collect location data when you visit our Services. We collect information about your location through GPS, Wi-Fi, wireless network triangulation, or other methods in order to obtain your location. We may also approximate your location by your IP Address. We also use the Google Maps API to gather information about your location. Google uses various technologies to determine your location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (see Google Maps privacy policy to learn more).

2.4 We collect additional profile information about you based on your activities on the Services, including when you upload a picture, or add your interests, music genre, skills and what you love. This information enables us to provide recommendations and provide you with personalised Services, in accordance with our legitimate interests.

2.5 When you purchase a subscription or any virtual coins or other items offered via the Services, you provide our payment processor with your payment information. This is necessary to process your payment. We currently use third parties to process such payments but may change that in the future.

2.6 If you choose to find your friends on the Services, we will access your contacts on your device (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list) and send your contacts to our servers to check if any of them are on the Services or the App you are using. If they are, we’ll suggest you follow them (but whether you do or not is totally up to you). Each time you open the contacts page in the Company’s mobile applications, we will automatically re-send the latest version of your contacts to our servers and provide you with an updated list of matches. We delete your contacts from our servers after we’ve checked for any matches.

2.7 We do not ask you to provide us with any sensitive personal information. This may include Personal Data pertaining to your race, national ID information, religious beliefs, background information (including financial and criminal records, where legally permissible), health data, disability, marital status and biometric data, as applicable. We collect sensitive Personal Data only with your consent and/or in strict compliance with applicable laws. In the event that you are required to furnish any documentation or information to us for any Purpose which may contain such sensitive Personal Data (which is not required for that Purpose), you agree to redact such sensitive Personal Data before providing such documentation or information to us.

2.8 We have a legitimate interest in gathering information from the actions you take to recommend, create, communicate and share content so that we can work on improving our Services. This includes messages you send, information about the content you create yourself, the people you follow, the songs you mark as favourites or share, and the comments you post. In addition, we track social interactions in our Apps (e.g. what you listened to, what you loved, and your comments and invites).

2.9 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, when you use the in-app chat or when you add them as recipients or beneficiaries of any use of our Services. 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 and disclosed as set out in this Privacy Notice.

2.10 As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to the Company. In the event that such Personal Data of a minor is disclosed to the Company, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Notice and take responsibility for his or her actions.

 

3. Use of Personal Data

3.1 We may use your Personal Data for the following purposes (“Purposes”). Additionally, if you use the Company in various capacities (for example, if you use multiple Services), we may link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below:

(a) Providing services and features
Your Personal Data will be used to provide, personalise, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:

• Facilitate matches with other users in the Company’s App;
   

• Engage you to provide you with Services across our various business verticals;
   

• Create, administer and update your account;
   

• Process, manage or verify your eligibility for or application of products, Services, promotions, rewards and subscriptions with the Company;
   

• Monitor and analyse trends, usage and activities;
   

• Conduct due diligence checks and risk assessments/analysis;
   

• Verify your identity and age (where necessary);
   

• Allow you to participate in the loyalty programmes or marketing activities organised by our merchant-partners and/or in collaboration with the Company;
   

• Personalise your App experience (such as to recommend products and services relevant to you, identify your preferences or otherwise personalise your experience with the Company);
   

• Make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;
   

• Perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
   

• Protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
   

• Enable communications between our users;
   

• Invite you to participate in our surveys and studies;
   

• Enable our partners to manage and allocate fleet resources; and
   

• Fulfil the services to you as a data processor, where you have provided consent to the data controller (i.e. the organisation you had purchased goods or services from, and for whom the Company is providing services on behalf of) for such services to be rendered.
   

(b) Other users
We may share your profile information with other users in the Company’s App to facilitate matches in accordance with the functionality of our services. In addition, you may choose to share additional information with users of the Company’s App once you have matched with them.

(c) Safety and security
We use your data to ensure the safety and security of our Services and all users. This includes:

• Verifying your identity when you log in to the Company;
   

• Using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
   

• Monitoring compliance with our terms and conditions and policies.
   

(d) User support
We use Personal Data to resolve user support issues. For example, we may:

• Investigate and address concerns;
   

• Monitor and improve our user support responses;
   

• Respond to questions, comments and feedback;
   

• Inform you about steps taken to resolve user support issues.
   

(e) Research, 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 development of insurance and finance solutions.

(f) Legal purposes
We may use the Personal Data we collect for legal purposes, such as to investigate and resolve claims or disputes, detect/prevent/prosecute crime, or as allowed or required by applicable law; 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:

• Comply with court orders or other legal, governmental or regulatory requirements;
   

• Enforce our Terms of Service or other agreements;
   

• Protect our rights or property in the event of a claim or dispute.
   

(g) Marketing and promotions
We may use your Personal Data to send you marketing communications relating to customised products or services (that may be of interest or relevance based on your profile), or the Company’s partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:

• Send you special offers that may be of interest or relevance to you across all of the Company’s service offerings;
   

• Send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings;
   

• Notify, invite and manage your participation in our events or activities.
   

We may communicate such marketing to you by various means, where applicable (including by SMS, chat applications such as WhatsApp, Telegram, LINE, Viber, WeChat, Zalo, push notification, call, and by email).

If you wish to unsubscribe from receiving such marketing communications, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings. Please note that while you may opt out of marketing or promotion communications, the Company may still send you account and/or service-related messages (such as two-factor authentication, information on your transactions, rewards, etc.).

(h) User published content
If you publish content (such as a review or comment) on the Company’s platform, it will be shown publicly along with your personal data (such as profile name, uploaded photo(s)), and other information you choose to include in your content.

3.2 We may from time to time post photos, videos relating to our Services on social media platforms for marketing purposes but such material will have no identifiable clients’ details. We may use or share limited or restricted clients’ personal data with our third party service providers (any party that we may transact or deal with) to the extent necessary to fulfil the purposes listed above and in consistency with this Privacy Notice, and reasonable care will be exercised to protect our clients’ personal information.

 

4. Protection and Disclosures

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

• Other users
   

  • If you use our in-app chat service, we may share your mobile number and registered name with the other parties to your chat.
     

  • If you post content to the forum or other message boards, within chat, on a profile page, to a blog, or any other services to which you are able to post information and content (including, without limitation, social media pages), then the information you post will be available to any person who can view that page or service.
     

  • If you choose to share using your connected social media account, then your shared content will be visible to your friends, other users of the platform, and the social media account provider.
     

  • If you choose to share information using the share function, you authorize us to facilitate the sharing of the information you have selected, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.
     

• Third parties
  These include website hosting, data analysis, payment processing, trade process, information technology and related infrastructure provision, customer service, email delivery, auditing, targeted advertising identification and delivery, mailing service, tax and accounting services, contest fulfilment and other services in connection with the overall delivery of the Services.
   

• Subsidiaries and affiliates
  We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates. The companies in the Company group share resources, such as infrastructure and technology with each other to provide you with a consistent, relevant and secure experience when you use our products or Services, and for the Purposes set out in this Privacy Notice. For example, we do this to make your experience more seamless, such as by automatically completing your registration information from your use of one Company product or Service when you sign up for a new product or Service.
   

• The Company’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:
   

  • Payment processors and facilitators;
     

  • Debt collectors;
     

  • Credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
     

  • Background check and anti-money laundering service providers;
     

  • Cloud storage providers;
     

  • Document storage and management providers;
     

  • Advertising and marketing partners and platform providers;
     

  • Data analytics providers;
     

  • Research partners, including those performing surveys or research projects in partnership with the Company or on the Company’s behalf;
     

  • Educational and training institute partners;
     

  • Fleet and merchant partners;
     

  • Financing partners;
     

  • Third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
     

  • Service providers who perform identity verification services.
     

• Legal advisors and governmental authorities
  We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes mentioned above, or in 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 necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).
     

• Business transfers
  We may share your Personal Data with other parties, in connection with any acquisitions, sales, mergers, joint ventures, consolidation, restructuring, financing or any other type of business transactions. Your Personal Data will however remain subject to our obligations made in any pre-existing Privacy Notice that you have agreed to.
   

 

5. Retention of Personal Data

5.1 We retain your Personal Data for the period necessary to fulfil the Purposes outlined in this Notice unless a longer retention period is required or allowed by law. 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 erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Notice, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

 

6. International Transfers of Personal Data

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

6.2 When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in the Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

6.3 Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.

 

7. Cookies, Related Technologies and Advertising on Third Party Platforms

7.1 The Company and third parties with whom we partner may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (such as software development kits (SDKs), which have similar functions to cookies and which may be installed in the Company App to allow partners to collect certain information about your interaction with the Company App) (collectively, “Cookies”) in connection with your use of the Websites and Apps, which may be persistent or stored only during an individual session on your browsers or devices.

7.2 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 be used for various purposes such as to:

• Provide the essential, basic functions of the use of our Websites, Services or Apps;
   

• Authenticate you, or remember your user preferences and settings;
   

• Deliver and measure the effectiveness of advertising campaigns, such as by measuring number of views or clickthroughs;
   

• Analyse site traffic and trends;
   

• Serve you relevant advertisements across other apps and websites owned by other companies (whether by us or by other advertisers); and
   

• Enhance user interface and experience by generally understanding the online behaviours and interests of users who interact with our Website, Services or Apps.
   

7.3 The Company may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes the Company 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.

7.4 You have the right to choose to disable, block or deactivate cookies. Please note, however, that refusal or removal of some cookies could affect the availability, functionality or use of our Website, Services or Apps.

7.5 You may adjust your internet browser settings to disable, block or deactivate cookies, delete your browsing history or clear the cache from your internet browser. The settings may be contained within the “History”, “Preferences”, “Settings” or “Privacy” section of your internet browsers, or you may otherwise consult the help section of your internet browser for more information.

7.6 We may facilitate the display of targeted advertising on other platforms, such as on other online platforms that you may be a user of. Although we will not use your Personal Data to show you such targeted advertisements on other platforms, you may still see generic ads that appear relevant to you. This may be because we have engaged third party advertisers/platforms to display ads to users of specific attributes or demographic makeups who may find them relevant. You may be able to limit seeing these advertisements through managing your preferences on these platforms.

 

8. Protection of Personal Data

8.1 We will take reasonable legal, organisational and technical measures to keep confidential your personal data and will not disclose any of your identifiable personal data to any third party without your consent stated herein. 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. We will retain your personal data for the period necessary to fulfil the many different purposes outlined in this Privacy Notice unless a longer retention is permitted or required by law.

8.2 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 Personal Data transmitted through any online means; therefore, any transmission remains at your own risk.

 

9. Managing and Deleting Your Information

9.1 In accordance with applicable laws and regulations, you may be entitled to:

• Inquire about the processing of your Personal Data and be provided with a copy of it;
   

• In some cases, request the correction and/or deletion of your Personal Data;
   

• In some cases, request the restriction of or object to the processing of your Personal Data;
   

• Withdraw your consent to the processing of your Personal Data within our possession or control (and where we are processing your Personal Data based on your consent);
   

• Request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and/or
   

• Complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment as a result of unlawful processing of your Personal Data.
   

9.2 We offer the ability to correct or update or delete the information collected during registration via your account settings on our website or the applications or by contacting us and we rely on the accuracy of the information you provide us (such as your age).

9.3 We retain your information in our server logs, our databases and our records only for as long as necessary in light of the purposes set out in this Policy, subject to any legal obligations to further retain such information. We may use third party service providers to store and maintain such data. We retain your verification-related information for a reasonable period of time, even if you do not complete all verification steps, to assist with future verifications and to prevent abuse of our verification processes. If you decide not to verify the account and would like us to delete the verification information you provided, kindly contact us.

9.4 After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulation.

9.5 The user may request to delete the account and personal data from the Company’s App at any time and for any reason by contacting us at heyutechnologies@gmail.com. We will process the request within 30 days after verifying the user’s identity and confirming the consent. If a user deletes the account, they will lose access to all the features and services of the Company’s App, including profile, songs, gifts, rewards, and interactions with other users. Any unused balance in the user’s account will be forfeited.

9.6 Upon deletion of the data, such data will be deleted from the system immediately and cannot be recovered by any users or us after this point. Data which has been deleted or otherwise destroyed cannot be recovered at any time. Sufficient warning is given to the account administrator before data are permanently deleted. However, if you create content with other users, their recorded performances included in such group content will remain after you delete your account.

9.7 Please note that choosing not to share your Personal Data with us, withdrawing your consent to our use of it or to your agreement with our Privacy Notice could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section 3 (Use of Personal Data) or that you are unable to make use of the App or the Services. All our legal rights and remedies are expressly reserved in the event of termination and any subsequent event. The withdrawal of consent shall not affect the lawfulness of any collection, use or disclosure of personal information which is not subject to consent, or for which we are otherwise legally permitted to retain.

9.8 We reserve the right to modify, update and amend this Privacy Notice from time to time as may be required. We will notify you of any changes via announcements on our mobile application or other appropriate means as determined by us. The updated version will be posted on the website [https://www.hotpieinternational.com]. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Apps, Websites or Services, purchase of products from the Company or continuing to communicate or engage with the Company following the modifications, updates or amendments to this Notice, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.

 

10. Data Retention

10.1 The Company retains the personal information we receive as described in this Privacy Policy for as long as you use our services or as necessary to fulfil the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

As outlined above, the Company works with a third-party identity verification company, Persona, to use biometric identifiers and associated information for photo verification. Biometric data will be destroyed when the verification purposes have been satisfied, within no more than 3 years of your last interaction with Persona, unless otherwise required by law or legal process to retain the data.

 

11. Contact Us

If you have any queries about this Notice or would like to exercise your rights set out in this Notice, you may contact us by email at heyutechnologies@gmail.com.