Privacy Policy

This Privacy Policy sets out how JUMBOEX and its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively referred to as “JUMBOEX”, “we” or “us”) collect, use and protect your Personal Data. Please read this Privacy Policy carefully to understand how we will collect and use your Personal Data and the rights you have in relation to your Personal Data. This Privacy Policy may vary and be updated from time to time, so please check it regularly.

This Privacy Policy applies to all our User(s), agents, vendors, suppliers, partners, contractors, service providers, third party merchants and Third Party Provider(s) (such as Third Party Deliverer(s)) (collectively referred to as “you”, “your” or “yours”).

By visiting our User(s) Application, Deliverer Application and/or Platform and/or using our Services, you acknowledge the terms and conditions of this Privacy Policy and consent to the use and disclosure of your Personal Data in the manner set out in this Privacy Policy.

  1. WHAT IS PERSONAL DATA?
  2. “Personal Data” means any information which can be used to identify you or from which you are identifiable. The types of Personal Data that we collect directly from you or from third parties depend on the circumstances of collection and on the nature of the service requested or transaction undertaken. It may include name, email address, billing address, premises address for delivery, telephone number, credit card information, personal interests, your image, government-issued identification numbers, biometric data, race, gender, date of birth, marital status, religion, vehicle and insurance information.


  3. WHAT PERSONAL DATA WE MAY COLLECT FROM YOU?
  4. We may collect the following Personal Data about you:-
    • personal information to establish your identity and background such as your full name, passport or identity card number, nationality, religion, race and gender;
    • contact information such as billing address, premises address for delivery services, telephone number, fax number and email address;
    • contact information such as billing address, premises address for delivery services, telephone number, fax number and email address;
    • license information, vehicle information and background check results (to the extend permissible by law);
    • sensitive information such as your race, religion or other beliefs, political opinions, health or criminal record. Generally, we do not collect sensitive information unless it is necessary due to exceptional circumstances to serve you better and meet your particular needs;
    • recording of your image via closed-circuit television cameras installed at our business premises;
    • recording of calls placed by you to our customer services; and
    • recording of messages and correspondences during the interaction between you and our customer services.

    Please note that:-
    • although no personal data is revealed to us for general web browsing, certain technical and statistical information (such as cookies, your IP address, the time, date and duration of your visit) is made available to us through our internet service provider; and
    • if you provide us with any personal data relating to a third party (for example:- information of your spouse, children, parents, and/or employees) by submitting such personal data to us, you represent to us that you have obtained the prior consent of the third party to provide us with their personal data for the purposes as listed below.


  5. HOW DO WE COLLECT YOUR PERSONAL DATA?
  6. We may collect Personal Data about you in the ways specified below. We may also combine the collected Personal Data with other Personal Data in our possession. If you have or are a party to multiple business relationships with us (for example:- if you use our Services across our various business verticals or if you are both a Third Party Provider(s) as well as a User(s) or a customer on our other business verticals), we will link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes specified below.

    Personal Data provided by you to us
    We collect your Personal Data when you provide it to us voluntarily in situations such as below:-
    • complete a user profile section or registration form (such as your name, contact information and other identification information where required);
    • provide information to assess your eligibility to provide services as Third Party Provider(s) (such as your driver’s license information, vehicle information and background check results, if you are Third Party Deliverer(s) or business license information, corporate information and background check results, if you are third party merchant(s) (to the extent permissible by law));
    • communicate with us such as by email, telephone, in writing or through our customer services pages or social media platforms (such as your social media account ID, profile photo and any other publicly available data);
    • participate in surveys, questionnaires, contests, events, offers or promotions organised by us (such as your age, gender, marital status, preferences, occupation and income information, pictures, audio files, or videos you may submit, which may include images of yourself); and
    • verify your identity through various means (such as social media logins, submission of selfie images or independently verified payment card information).

    Personal Data collected when our Services are used
    Personal Data may be collected through the normal operation of our User(s) Application, Deliverer Application, Platform and/or Services. For examples:-
    • your location (to detect pick-up locations for Parcel(s));
    • feedback, ratings, compliments or complaints;
    • transaction information (such as payment method and distance travelled);
    • information about how you interacted with our mobile apps, website and/or services (such as features used and content viewed);
    • device information (such as hardware model and serial number, IP address, file names and versions and advertising identifiers or any information which may provide indication of device or app modification);
    • personal data you enter in messages when you use our in-app communication features; and
    • personal data that may be captured through your interaction with us, our agents, in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).

    Personal Data collected from other source
    We may collect Personal Data from other sources which may include:-
    • referral programmes;
    • our business partners, such as Third Party Provider(s) and payment providers;
    • insurance and financial providers;
    • insurance and financial providers;
    • publicly available sources of data;
    • governmental sources of data;
    • when our User(s) add you as an emergency contact; and
    • marketing services providers or partners.
    When we collect Personal Data from other sources, we use reasonable efforts to make sure that such Personal Data is transferred to us in accordance with applicable laws.

    Personal Data about Third Party Deliverer(s)
    If you are a Third Party Deliverer(s), we may collect:-
    • telematics data (such as your speed, acceleration, and braking data);
    • device data (such as accelerometer data, GPS location, your IMEI number and the names of mobile apps you have installed on your device);
    • your vehicle registration and license data; and
    • personal data that may be captured through your interaction with us, our agents, our in-vehicle audio and/or video recording during a ride (such as your image or voice or both, and its related metadata).

    Sensitive Personal Data

    Some of the Personal Data that we collect is sensitive in nature. This may include Personal Data relating to your national identity information, race, religious beliefs, background information (including health, financial and criminal records, to the extent permissible by law), marital status and biometric data, as applicable. We collect this information only with your consent and/or in strict compliance with applicable laws.

    Personal Data of Minors

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

    When Personal Data of other individuals are provided to us

    In situations where you provide Personal Data of other individuals (such as your spouse, family members or friends) to us (example; for emergency contact), 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 Policy.


  7. HOW DO WE USE THE PERSONAL DATA COLLECTED?
  8. You agree that we may use your Personal Data for the following purposes (“Purposes”) to the extent permitted by law:-

    To provide services and features
    Your Personal Data may be used to provide, personalise, maintain and improve our mobile apps, websites and/or services. This includes using your Personal Data to:-
    • provide you with services across our various business verticals;
    • engage you to provide services;
    • create, administer and update your account;
    • conduct due diligence checks;
    • verify your identity and your age (if necessary);
    • verify your identity and your age (if necessary);
    • offer, obtain, provide, facilitate or maintain insurance or financing solutions;
    • track the progress of the delivery of Parcel(s) and detect abnormal trip variations;
    • enable features that personalise your mobile app;
    • make your experience more seamless, such as filling in your registration information (such as your name, address or phone number) automatically from one service to another service or when you participate in our surveys or questionnaires;
    • 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 our services and any facilities or equipment used to make our services available;
    • process and manage your rewards and entitlements;
    • process, manage or verify your application of promotions, rewards and subscriptions with us;
    • enable communications between our User(s);
    • 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 (for example:- the organisation you had purchased goods or services from, and for whom we are providing services on behalf of) for such services to be rendered.

    Safety and security
    We may use your data to ensure the safety and security of our Services and all User(s).
    This includes:-
    • screening User(s) or Third Party Provider(s) before enabling their use of our Services;
    • identifying unsafe driving behaviour such as speeding, harsh braking and acceleration, and providing personalised feedback to Third Party Deliverer(s);
    • verifying your identity when you log in to your account;
    • using device, location, profile and other Personal Data to prevent, detect and combat fraud or unsafe or illegal activities;
    • monitoring compliance with our terms and conditions and policies; and
    • detecting, preventing and prosecuting crime.

    Customer support
    We may use Personal Data to resolve customer support issues. For example, we may:-
    • investigate and address concerns or complaints;
    • monitor and improve our customer support responses;
    • respond to questions, complaints, comments and feedback; and
    • inform you about steps taken to resolve customer support issues.

    Research and development and security

    We may use the Personal Data we collect for analysis, testing, research and product development. This enables us to analyse and understand your needs and preferences, protect your Personal Data, improve and enhance the efficiency, safety and security of our Services, develop new products, services and features to our User(s) Application, Deliverer Application and/or Platform and facilitate insurance and finance solutions.

    Legal purposes
    We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable laws.
    We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.
    For example, we may use your Personal Data to:-
    • comply with court orders or other requirements of any local or foreign legal, regulatory, governmental or other authority;
    • enforce our terms and conditions of the Services or other agreements; and
    • protect our rights or property in the event of a claim or dispute.

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

    Marketing and Promotions
    We may use your Personal Data to market and promote JUMBOEX or our partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:-
    • send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
    • notify, invite and manage your participation in our events or activities.
    We may communicate such offers or marketing to you via post, telephone call, short message service, online messaging service, push notification by hand, email or through social media (such as Whatsapp, Facebook, Twitters and Instagram).
    If you do not agree or consent to us processing your Personal Data for the above marketing or promotions purposes, please notify us by contacting us via the contact details set out in paragraph 11 below.


  9. HOW DO WE SHARE OR DISCLOSE YOUR PERSONAL DATA?
  10. We may need to share or disclose your Personal Data with various parties for the Purposes which includes:-

    Other User(s)
    For example:-
    • If you are a Third Party Deliverer(s), we may share your Personal Data with the relevant Third Party Provider(s) and User(s), including your name and photo; your vehicle type, model, location and average rating.
    • If you are using our Parcel Delivery Services, we may share your Personal Data with the recipient of your Parcel(s), and vice versa, as well as the relevant Third Party Deliverer(s) fulfilling your service request.

    Sharing Personal Data with our partners at your request

    For example, if you requested a service through our partner or used a promotion provided by our partner, we may share your Personal Data with them. Our partners include partners that integrate with our User(s) Application and/or Deliverer Application or our User(s) Application, Deliverer Application integrates with, logistic services partners or business partners which we collaborates with to deliver a promotion, competition or other specialised service.

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

    Sharing Personal Data with our Third Party Provider(s) and business partners
    We may provide Personal Data to our Third Party Provider(s), vendors, consultants, marketing partners, research firms and other service providers or business partners. This includes:-
    • payment processors and facilitators;
    • debt collectors;
    • credit bureaus and other credit reporting agencies;
    • background check and anti-money laundering service providers;
    • cloud storage providers;
    • marketing partners and marketing platform providers;
    • data analytics providers;
    • research partners, including those performing surveys or research projects in partnership with us or on our behalf;
    • fleet and merchant partners;
    • insurance and financing partners;
    • storage facility providers;
    • third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
    • service providers who perform identity verification services; and
    • vehicle solutions partners, vendors or third-party vehicle suppliers.

    Sharing Personal Data with our legal advisors and governmental authorities
    We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties, whenever required to fulfil the legal purposes (as mentioned above) or any of the following circumstances:-
    • where it is necessary to respond to an emergency that threatens the health, life or safety of a person; or
    • where it is necessary to respond to an emergency that threatens the health, life or safety of a person; or

  11. RETENTION OF PERSONAL DATA
  12. We will retain your Personal Data as long as necessary to fulfil the Purposes unless a longer retention period is required or allowed by law.

    Once your Personal Data is no longer required for the Services or Purposes or we no longer have a legal or business purpose for retaining your Personal Data, we shall take steps to ensure that all Personal Data is erased or destroyed or prevent access or use of such Personal Data for any purpose other than compliance with this Privacy Policy or for purposes of safety, security, fraud prevention and detection in accordance with the applicable laws.


  13. TRANSFERS OF PERSONAL DATA
  14. Your Personal Data may be transferred from country, state and city in which you are present while using our Services to another country, state and city. In such situations, we will comply with our legal obligations in relation to your Personal Data, including having a lawful basis for transferring the Personal Data and using appropriate safeguards to ensure an adequate protection of the Personal Data. We will also ensure that the recipient of such Personal Data is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

    Our lawful basis will be either consent (for example:- we may ask for your consent to transfer your Personal Data from country, state and city in which you are present while using our Services to another country, state and city at the time you provide your Personal Data) or one of the safeguards permissible by laws.


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

    We may allow third parties to use Cookies on the User(s) Application, Deliverer Application and/or the Platform to collect the same type of Personal Data for the same purposes we do for ourselves. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

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

    If you do not wish for your Personal Data to be collected via Cookies on the User(s) Application, Deliverer Application and/or the Platform, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.


  17. HOW DO WE PROTECT YOUR PERSONAL DATA?
  18. We will take appropriate legal, technical and organizational security measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost or used or accessed in an unauthorised way. We limit access to your Personal Data to our employees and keep it on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.

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


  19. WHAT ARE YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA?
  20. In accordance with applicable regulations and laws, you may be entitled to:-
    • ask us about the processing of your Personal Data, including to be provided with a copy of your Personal Data;    
    • request the rectification in respect to incorrect or incomplete Personal Data and/or (in some cases) erasure of your Personal Data;
    • in some cases, request the restriction of the processing of your Personal Data or object to that processing;
    • withdraw your consent to the processing of your Personal Data (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 
    • complain to the relevant data privacy authority if your data privacy rights are violated or if you have suffered as a result of unlawful processing of your Personal Data.

    Although you are given the option to share your Personal Data with us, you can always opt not to do so. If we have requested for your consent to processing your Personal Data and you later choose to withdraw your consent, we will respect your decision subject to our legal obligations.

    However, choosing not to share your Personal Data with us or withdrawing your consent to our use of your Personal Data could mean that we are unable to perform the actions necessary to achieve the purposes of processing specified in paragraph 4 (HOW DO WE USE THE PERSONAL DATA COLLECTED) or that you are unable to make use of the Services. After you have chosen to withdraw your consent, we may be able to continue to use and process your Personal Data to the extent required or permissible under the applicable laws.

    If you wish to make a request to exercise your rights, you can contact us through our contact details set out in paragraph 11 below. Please note that we have the right to refuse your request to access and / or make any rectification to your Personal Data to the extent permitted under the applicable laws.


  21. GENERAL PROVISIONS
  22. Interpretations
    All capitalized terms but undefined terms used herein shall bear the same meaning as those defined in the Terms of Use of Services-User(s) and Terms of Use of Services-Third Party Deliverer(s).

    Language
    This Privacy Policy is issued in both English and Bahasa Malaysia. In the event of conflict between the English and Bahasa Malaysia version, the provisions in the English version shall prevail.

    Amendments and Updates
    We shall have the right to modify, update or amend the terms of this Privacy Policy at any time by placing the updated Privacy Policy on the User(s) Application, Deliverer Application and/or Platform. By continuing to use the User(s) Application, Deliverer Application, Platform and/or Services or continuing to communicate or engage with us following the modifications, updates or amendments to this Privacy Policy, you signify your acceptance of such modifications, updates or amendments.

    Our Contacts
    If you have any questions or concerns regarding our Privacy Policy or would like to exercise your rights set out in this Privacy Policy, please contact our customer service officer at:-

    MFORCE E EXPRESS SDN. BHD. (Company No. 202001010457 [1366777-H])
    Address: 1485, Jalan Seruling, Kawasan Perindustrian Valdor, 14200 Sungai Jawi, Pulau Pinang
    Contact Number: 04-545 2233
    Email: [email protected]