This Privacy Notice (“Privacy Notice”) describes how Freshie Sdn. Bhd., its respective holding company, subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “Freshie”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of mobile applications, websites, products, features and other services globally, operated by Freshie (collectively, “Services”).

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

“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.

 

1. Why do we collect your Personal Data? 

Freshie may use your Personal Data for the following purposes set out in the list below. (“Purposes”). 

Providing services and features

Your Personal Data will be used to provide, personalise, maintain and improve our Services. This includes, but is not limited to:

• manage your requests for products and services, including deliveries, processing payments and refunds, reward points, and discounts;
• respond to feedback, complaints or concerns you have regarding our products and services;
• registering and servicing your account, including keeping your information up-to-date, and verifying your identity;
• request feedback through surveys and research so that we can improve our products and services;
• improve our operational processes to enhance your customer experience;
• work with our service providers;
• conduct safety, security, investigative, fraud, and loss prevention activities;
• facilitate corporate transactions like mergers and acquisitions, e.g. to assess those transactions and manage the transition of the business; and
• as otherwise required or permitted by law.

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 Freshie’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 Freshie’s product and service offerings;
• 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 marketing to you by various means, where applicable (including by SMS, chat applications (e.g. WhatsApp, Telegram), call, and by email).

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.

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 legal, governmental or regulatory requirements;
• enforce our Terms of Service or other agreements; and
• protect our rights or property in the event of a claim or dispute.

Research and 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 business solutions.

User Published Content

If you publish content (such as a review or comment) on Freshie’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.

 

2. Types of Personal Data collected 

The types of personal information we collect for the purposes listed in Section 1 includes, but is not limited to:

• your identity and contact details: this includes your name, residential address, email address, telephone number(s), age and gender, images, videos;
• financial and transaction information: this includes payment cards and transaction history;
• health information: this includes medical or hospital services in connection with an injury/condition related to a public liability or workers compensation claim that has been raised with Freshie;
• loyalty program information: information about your participation in Freshie Loyalty Program and GrabRewards;
• location information: our websites or applications might ask for location information to help better serve you information and, if you have given permission to our app, device data to help serve relevant information about nearby stores or information applicable to your region;
• user data: information about you as a customer of our stores and how you engage with our products and services. For example, transactional data, product purchases, interests, feedback you provide on your shopping experience and audio and video footage captured in-store and within facilities;
• usage and Interaction data: details of how you interact with our products and services;
• contact history: details of your contact and interactions with our Customer Care teams across Freshie; and
• marketing and communications data: this includes your marketing and channel preferences.

 

3. How do we collect your Personal Data?

We collect Personal Data about you in the ways listed 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 relationships with us (for example if you use our Services across our various business verticals, or if you are a consumer to Freshie as well as a consumer to our other affiliated companies), we will link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below.

You provide your Personal Data to us

We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

• visit a store, make a purchase in store, or place an order online; 
• complete a user profile or registration forms;
• use your GrabPay, payment cards or any other associated identifiers such as electronic payment method accounts;
• activate and use your Freshie Loyalty Program eCard;
• participate in a promotion, competition, event, or survey (such as the pictures, audio files, or videos you may submit, which may include images of yourself);
• participate in any loyalty programs (including but not limited to our mailing list);
• request customer service (including but not limited to contact forms, messaging, email and telephone);
• provide personal data when you contact us (including but not limited to contact forms, messaging, emails, or calls);
• post a review or comment on one of our websites or social media pages, or post a rating, review, or other user generated content on our websites or applications; 
• visit our premises or attend events organised by us and your images are captured via photographs or videos taken by us or our representatives; 
• use our related websites, applications, social media, and other digital services;
• register your visit on our premises; and
• submit your personal data to us for any other reason.

When our services are used

Personal Data may be collected through the normal operation of our Services. Some examples are:

• device information (such as hardware model and serial number, IP address, file names and versions, and advertising identifiers or any information that may provide indication of device or app modification);   
• information about the individual web pages or products that you view;
• what websites or search terms referred you to the Site;
• information about how you interacted with our applications, website or Services (such as features used and content viewed); and
• transaction information (such as payment method).

From other sources

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

• Grab Holdings Inc, its respective subsidiaries, affiliates, associated companies and jointly controlled entities;
• insurance and financial providers;
• credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
• publicly available or governmental sources of data;
• when our users add you as a recipient or beneficiary of any use of our Services; 
• anyone authorised to act on your behalf; and
• marketing services providers or partners.

When you provide Personal Data of other individuals to us

In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, 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.

Personal Data of minors 

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to Freshie. In the event that such Personal Data of a minor is disclosed to Freshie, 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.

 

4. Who do we disclose your Personal Data to?  

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

With subsidiaries and affiliates

We share Personal Data with our parent company, subsidiaries, associated companies, jointly controlled entities and affiliates. The companies in the Freshie 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 Services, and for the Purposes set out in this Privacy Notice.

Other Disclosures 

We may also disclose or share your personal data in connection with the purposes described in Section 1 above, including to the following parties:

• third parties such as partners, suppliers, or service providers, who are appointed to provide services to us, including but not limited to. payment processing services, IT and technology services, marketing companies, insurance companies, event organisers, business advisory services, legal services, administrative services, logistic services;
• third parties that we conduct joint marketing and cross promotions with;
• insurance companies;
• business partners; and/or 
• regulatory authorities and government agencies.

When disclosing personal data to third parties, we will (where appropriate and required by applicable law) enter into contracts with these third parties to protect your personal data in a manner that is consistent with applicable laws and/or ensure that they only process your personal data in accordance with our instructions.

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. Security of your Personal Data

We will take reasonable legal, organisational and technical 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 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.

 

6. Use of cookies 

Freshie, 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 (“Cookies”) in connection with your use of the websites and applications. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Apple’s IDFA). 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 Service, 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.

Freshie may allow third parties to use Cookies on the websites and applications to collect the same type of Personal Data for the purposes Freshie 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.

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.

Disabling the collection of cookies on our websites 

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. 

 

7. International Transfers of Personal Data

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”).

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 Alternate Country 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 (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.

 

8. Your rights and obligations with us 

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 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); 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.

Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your Personal Data with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section 2 or that you are unable to make use of the Services. After you withdraw your consent, we may be able to continue processing your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

 

9. Changes to Privacy Notice

Freshie may modify, update or amend the terms in this Privacy Notice at any time. Such amendments shall be notified to you through the Application and/ or other appropriate means at least five (5) business days before the effective date. The updated version will be posted on the website http://www.freshie.my. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Services, purchase products from Freshie or continuing to communicate or engage with Freshie 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. Contact us

For more information about our privacy practices, or if you have questions, please contact us by e‑mail at hello@myvc.co or by mail using the details provided below:

Freshie

[Re: Compliance]

GEO Bukit Rimau, SH-1-23 Pangsapuri Knox Wawasan, Jalan Sungai Burung 32/68, Seksyen 32, 40460 Shah Alam, Selangor, Malaysia