Privacy Policy

At Flashket, ensuring the security of your privacy is one of our top priorities, and we are wholeheartedly committed to achieving that goal. This Privacy Policy serves as a clear and straightforward explanation of how we handle your information when you engage with Flashket services via our websites and mobile applications. Whenever we mention "you", "your", or "yours" in this document, we are referring to a wide range of individuals, including our valued customers, partner-merchants, partner-riders, contractors, and service providers. Consider this policy as your reliable companion, providing insights into how your privacy is safeguarded while you make use of the Flashket platform.

When you participate in activities on the Flashket platform, such as using the app, registering, or placing orders, you are indicating your agreement to adhere to this privacy policy. This policy covers all personal data collected by us during your interactions with our platform. The range of personal data encompasses various details, including, but not limited to, your name, nationality, contact number, banking and credit card information, personal preferences, email address, images, government-issued identification documents along with their respective numbers, biometric data, ethnicity, birthdate, marital status, religious beliefs, health-related details, vehicle information, employment particulars, and financial records. This classification also encompasses any information that aids in identifying you.

I. Collection of Personal Data

Our primary purpose in gathering your personal data is to fulfill our obligations as a platform. However, the decision to provide or withhold this information while using our platform remains entirely at your discretion. When you engage with our platform, we collect your personal data, which may encompass the following:

• 1. your geographical location;
• 2. ratings and compliments;
• 3. your chosen method of payment;
• 4. insights into your platform utilization;
• 5. device details (such as hardware model, serial number, IP addresses), application names and versions, GPS location, IMEI number, and advertising identifiers, as well as any indications of device or application modifications;
• 6. personal information that you input through messages in utilizing Flashket’s in-app communication features;
• 7. personal data obtained from your interactions with us and our partners; and
• 8. personal data of other individuals that you provide during your platform usage process

A. Acquisition of Additional Personal Data

Certain personal data, such as your name, contact details, and other identifying information, will be collected from diverse sources, including but not limited to:

• 1. referral promotions;
• 2. collaborative business partners;
• 3. credit bureaus and other credit-related reporting entities;
• 4. accessible public and governmental data repositories; and
• 5. instances where you are designated as a recipient or beneficiary by other users of our platform

B. Collection of Sensitive Information

The collection of sensitive data from you may encompass various categories, including your nationality, telephone number, banking and credit card details, personal preferences, email address, visual representation, government-issued identification documents and their associated numbers, biometric details, racial background, date of birth, marital status, religious affiliation, health particulars, vehicle specifics, employment particulars, and financial insights. It is essential to emphasize that we only gather such sensitive data with your explicit consent and/or in full compliance with pertinent regulations.

In situations where you are required to provide us with specific documents or details that include sensitive Personal Data for a particular purpose (which may not necessarily be essential for that purpose), you acknowledge and assume responsibility for removing such sensitive Personal Data before submitting such documentation or details to us.

Furthermore, there may arise instances where you need to furnish us with personal data of third parties (e.g., your spouse, family members, friends). This could involve adding an emergency contact if necessary, utilizing the in-app chat feature, or identifying other individuals as beneficiaries of Flashket services. By doing so, you affirm and assure that you possess the requisite permissions from these individuals to collect, utilize, and disclose their Personal Data in strict accordance with the guidelines outlined in this Privacy Policy.

Parents and legal guardians, it is your responsibility to ensure that minors under your care do not provide Personal Data to us. If Personal Data of a minor is inadvertently submitted to us, you hereby acknowledge and consent that Flashket will process the minor's Personal Data, and you accept and agree to be bound by this Privacy Policy. Furthermore, you assume the responsibility for overseeing the minor's activities on the Flashket platform.

II. Utilization of Your Personal Data

Through your utilization of Flashket, you provide us the consent to employ your Personal Data in accordance with the objectives outlined within this privacy policy and the stipulations within the Flashket Terms and Conditions. In instances where you engage with Flashket in varying roles (such as functioning as both a merchant and a customer), we retain the right to establish connections between the Personal Data obtained across your diverse roles. This interlinking is intended to streamline and enhance your experience when engaging with our services.

To facilitate the delivery, customization, maintenance, and augmentation of Flashket services, we will utilize your Personal Data as applicable to perform the following actions:

• 1. provide an array of services spanning our diverse business domains;
• 2. keep your account(s) updated, upgraded, and maintained;
• 3. process, administer, or assess your eligibility for accessing Flashket's services, promotions, incentives, and subscriptions;
• 4. conduct due diligence investigations and assess risks pertaining to your account(s);
• 5. verify your identity and age;
• 6. validate your payment transactions;
• 7. offer personalized recommendations for products and services tailored to your preferences, enhancing your Flashket experience;
• 8. streamline transactions for you, including automatic population of your registration details such as name, phone number, and email;
• 9. undertake internal activities essential for service delivery, such as analyzing usage trends, monitoring and rectifying software glitches and operational issues, testing, and data analysis;
• 10. safeguard the integrity and security of our service facilities, equipment, and infrastructure;
• 11. enable communication between our users;
• 12. solicit your participation in surveys and research initiatives;
• 13. facilitate the selection of our delivery partners and drivers;
• 14. authenticate your identity during Flashket login;
• 15. employ your device's location, profile, usage patterns, and other personal data to thwart, identify, and counteract fraud or potentially hazardous actions;
• 16. ensure adherence to our Terms and Conditions and Privacy Policy;
• 17. investigate and address user concerns;
• 18. enhance tracking and response within our customer service;
• 19. address queries, comments, and feedback; and
• 20. notify you of measures taken to address user support issues

We may employ the Personal Data we collect for purposes such as testing, research, analysis, and product development. This enables us to gain insights into your requirements and preferences, safeguard your Personal Data, enhance the safety and security of our Services, create novel features, goods, and services, and contribute to the advancement of additional solutions.

The Personal Data we collect may find application in legal contexts, including the examination and resolution of claims or disputes, the deterrence, prevention, and prosecution of criminal activities, and in other ways stipulated or mandated by law. Additionally, we may utilize your personal information if compelled by our legal advisors or any duly authorized local or international legal, regulatory, governmental, or other authority. This encompasses a variety of scenarios, not limited to:

• 1. adhering to court orders or complying with other legal, administrative, or regulatory obligations;
• 2. enforcing our Terms and Conditions and other relevant agreements;
• 3. safeguarding our rights or property in the context of claims and disputes;
• 4. providing you with exclusive offers encompassing a wide array of Flashket's service offerings that align with your interests or preferences;
• 5. forwarding notifications, updates, bulletins, mailers, exclusive perks, and seasonal greetings; and
• 6. keeping you informed, inviting you to events or activities, and managing your participation.

As relevant, we may deliver such marketing communications to you via multiple channels, including SMS, popular chat platforms (e.g. Messenger, Telegram, Viber, WhatsApp, WhatsApp), push notifications, phone calls, and emails. Should you wish to discontinue receiving these marketing messages, you can easily opt out by clicking the "unsubscribe" link found in the email or unsubscribe instruction in the message. It's important to note that even if you choose not to receive marketing or promotional communications, Flashket may continue sending you messages pertaining to your account's services, such as transaction notifications, promotional offers, rewards updates, and the like.

Please be aware that any content you upload, such as personal information, your profile name, uploaded images, and any other details you decide to include in your content, will be publicly accessible whenever you publish content on the Flashket platform.

III. Disclosure of Personal Data

In order to fulfill our services, we might share your personal information with other users. Depending on your role, if you're a customer, the scenarios for disclosing your data may include:

• 1. sharing your list of ordered items with our partner merchants who are responsible for fulfilling your booking request; and
• 2. sharing your delivery drop-off locations with our partner riders who are facilitating your request.

For partner riders, potential examples of data disclosure could involve:

• 1. revealing your real-time GPS location while in the process of delivering an order to our customer; and
• 2. disclosing your contact number during the order delivery process.

If you are a partner merchant, potential scenarios for data disclosure might encompass:

• 1. making the GPS location of your store branches available to our customers and riders to streamline order provision; and
• 2. disclosing your branch contact number to facilitate order fulfillment.

In addition to the aforementioned, we collaborate with various third-party service providers to effectively deliver our grocery delivery services. These entities encompass payment processors, payment gateways, delivery partners, and customer service providers. These third-party service providers are authorized to access and use your personal information solely for the intended purposes for which it was shared, while upholding the confidentiality and security of your data.

There are situations where we may need to disclose your personal information to third parties, including:

• 1. sharing information with our payment processing partners to facilitate seamless transactions;
• 2. complying with legal and regulatory mandates; and
• 3. undertaking measures to investigate or prevent instances of fraud or other illicit activities.

We may also disclose non-personal information to third parties for marketing, advertising, or other similar purposes. This could encompass:

• 1. cloud server providers;
• 2. advertising, marketing, and analytics service providers;
• 3. customer relationship management partners;
• 4. research collaborators;
• 5. training partners;
• 6. merchant partners;
• 7. financing associates; and
• 8. identity verification collaborators

Furthermore, your Personal Data might be shared with government authorities, our legal advisors, law enforcement agencies, and other third parties, solely for the following purposes:

• 1. responding to an event that jeopardizes an individual's life, health, or safety;
• 2. addressing matters that are in the public interest, such as instances of public health emergencies requiring contact tracing;
• 3. fulfilling legal obligations or regulatory requirements

In the event of acquisitions, sales, mergers, joint ventures, consolidation, restructuring, financing, or any other form of business transaction, we may disclose your Personal Data to relevant parties. However, it is crucial to note that your Personal Data will remain subject to the stipulations outlined in any previously agreed-upon Privacy Notice.

IV. Data Retention

Flashket will retain your Personal Data for the duration required to fulfill the purposes outlined in this Privacy Policy, unless an extended retention period is necessary or permissible by law. Should your personal data cease to serve a purpose within Flashket's services, or if a legal or business rationale for retaining it no longer exists, we will initiate measures to expunge, erase, anonymize, or restrict access to or utilization of your Personal Data. In instances where your account remains inactive on the Flashket platform for a period exceeding 365 days, we reserve the right to implement erasure in accordance with our storage limitation protocols. However, your Personal Data may still be utilized to ensure compliance with this Privacy Policy, or for matters related to safety, security, fraud prevention, and identity verification, consistent with applicable legal regulations.

V. Advertising on Third-Party Platforms, Cookies, and Web-Tracking

Flashket and its selected partners may utilize a range of technologies like cookies, web beacons, tags, scripts, and analogous tools while you engage with the Websites and Apps. These technologies, which might persist or remain temporarily, could be stored within your browsers or devices throughout your interaction sessions.

It is necessary to recognize that Flashket might authorize third parties to utilize cookies on the Websites and Apps, gathering the same kind of Personal Data for comparable objectives as Flashket itself. In some instances, these third parties could link the collected Personal Data with additional information about you obtained from alternate sources. Importantly, it should be clarified that our access to or control over the cookies employed by these third parties may be limited.

Advertising on Third-Party Platforms

We facilitate the presentation of targeted advertisements on other platforms, potentially encompassing various online platforms you use.

While we refrain from employing your Personal Data to deliver targeted ads on external platforms, you might still encounter general advertisements that seem pertinent to you. This is because we might engage third-party advertisers/platforms to showcase ads to users with specific attributes or demographic profiles who could find the content relevant.

We might also collaborate with third-party advertisers by sharing aggregated and non-personal information. This collaboration aims to optimize the quality and relevance of the advertisements encountered on our platform.

Cookies

Cookies may possess unique identifiers and reside in various locations, including on your computer, mobile device, emails we transmit, and our web pages. These cookies serve multiple functions:

• 1. Essential Functions: They facilitate core and fundamental operations for utilizing our Websites, Services, or Apps.
• 2. User Authentication and Preferences: Cookies authenticate your identity and retain user preferences and settings.
• 3. Advertising Effectiveness: Cookies play a role in delivering and gauging the efficacy of advertising campaigns, encompassing metrics such as view counts and click-through rates.
• 4. Traffic Analysis: They analyze site traffic patterns and trends.
• 5. Relevant Advertisements: Cookies enable the presentation of pertinent ads on other applications and websites owned by different entities, whether us or other advertisers.
• 6. Enhanced User Experience: By comprehending the online behaviors and interests of users who interact with our Website, Services, or Apps, cookies contribute to enhancing the user interface and overall experience.

You possess the right to opt for the deactivation, blocking, or discontinuation of cookies. It's crucial to acknowledge, however, that declining or removing certain cookies could potentially impact the accessibility, functionality, or usage of our Website, Services, or Apps. You retain the authority to configure your browser settings to accept, reject, or delete cookies. It is important to note that disabling cookies may affect the functionality of certain features on our platform.

Web-Tracking

Web beacons, pixel tags, and other tracking technologies are employed to gather insights into your interactions with our platform. These tools play a pivotal role in monitoring user engagement, analyzing trends, and enhancing our services. Through web-tracking, we collect information such as your IP address, browser type, operating system, referring URLs, and visited pages. This data empowers us to derive insights for analysis, thus enriching your overall platform experience.

In certain instances, third-party services we engage with might utilize web-tracking technologies to monitor your online activities across various websites. We advise consulting the privacy policies of these third-party services to gain a comprehensive understanding of their data practices.

VI. Your Rights Over Your Personal Data

You have certain rights concerning your Personal Data, as governed by relevant laws and regulations:

• 1. The right to know how we process your Personal Data and obtain a copy of it.
• 2. In certain situations, you can ask us to correct or delete your Personal Data.
• 3. If needed, you can limit or object to how we handle your Personal Data.
• 4. You can change your mind and withdraw consent to process your Personal Data (when it is based on consent).
• 5. You can ask us to give you your Personal Data in a readable format (when we use your data based on consent or a contract).
• 6. You have the right to complain to the authorities if your data rights are violated or if you've been harmed by unauthorized use of your Personal Data.

When you're given the choice to share your Personal Data with us, you're in control – you can choose not to. If you give us permission to use your data and then decide to withdraw it, we'll respect your choice according to our legal obligations.

Remember, not sharing your Personal Data, withdrawing consent, or disagreeing with our Privacy Notice could affect our ability to provide the services or limit your use of our services.

After you withdraw consent, we may still need to process your Personal Data as allowed by the law. All requests will be carefully checked and confirmed. To make sure it's really you and that you have the authority to request, we may ask for additional information or documents. Once we've confirmed, we'll handle your request following the timeframes set by the law.

VII. Modifications

We retain the right to modify this privacy notice to ensure alignment with relevant legal and statutory requirements, which include the Data Privacy Act and its Implementing Rules and Regulations. You will be duly informed of any substantial alterations, such as changes in purpose or the introduction of new processing purposes. The updated version will be made available on our website. It is your responsibility to periodically review the Privacy Policy. Continuing to use the app, website, or our services, making purchases from us or via the app, or engaging with Flashket in any form after the alterations, updates, or amendments to this Policy – whether or not you've personally reviewed them – signifies your acceptance of and consent to abide by these changes.

CONTACT US

If you wish to utilize any of the following options, we kindly ask you to directly contact us via email at inquiries@flashket.com:

• 1. Data Copy Request: You have the right to request a copy of the personal data that we have collected and maintained about you.
• 2. Access and Usage Restriction: If you desire to limit or specify the ways in which we access or use your personal information, please let us know.
• 3. Information Correction/Update: Should you identify any inaccuracies in the information we have about you, or if your details have changed, we encourage you to inform us to ensure the accuracy of your data.
• 4. Privacy Breach Reporting: If you suspect or become aware of any potential breaches of our privacy policy, including unauthorized access to your data, please alert us promptly.

Your privacy is of utmost importance to us. Rest assured, we will address your requests promptly, prioritizing the security and confidentiality of your information throughout the process.

Please note that while we make every effort to respond promptly, it may take some time to thoroughly address complex inquiries or requests. Rest assured, we will make every endeavor to provide you with the information and assistance you require.

Last Updated: September 2023