Privacy Policy

Version as of 31 May 2021

This privacy policy and any supplement(s) (our “Privacy Policy”) describe how the Pickup group of companies which include its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “Pickup”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of Pickup’s platforms including its mobile applications and websites (“Pickup Platforms”), as well as products, features and other services globally, operated by Pickup
(collectively, the “Pickup Services”).

This Policy applies to all of our merchants, suppliers, customers, users, agents, vendors, business partners, service providers, contractors and any other third party that may use or access the Pickup (collectively “you”, “your” or “yours”).

This Privacy Policy applies in conjunction with any other terms and conditions, policies, codes, notices, consents or contractual arrangements that apply in relation to the collection, storage, use, disclosure and/or processing of your information by us and is not intended to override any of them unless expressly stated otherwise.

1. What do we collect?
As part of your use of the Pickup Platforms or the Pickup Services, we may collect data from you. The data that we collect from you may include information that may be personal to you and from which you can be identified, including but not limited to your name, address, telephone numbers, email addresses, financial information such as bank account details and credit card information, personal identifiers such as your date of birth, age, nationality, race, marital status, religion, facial image,
fingerprint or other biometric information, employment information, information from government issued documents, health information, vehicle ownership and insurance information, any of your device information including IP addresses, hardware information, model numbers and serial numbers, any related metadata generated from your use of the Pickup Platforms or the Pickup Services or any other information required in order to allow access or utilise the Pickup Platforms or
Pickup Services (together “Personal Data”).

We recognise that Personal Data that we collect from you may at times be sensitive. Such sensitive data may include Personal Data about your government issued ID information, race, personal background information (including financial and criminal records, where legally permissible), marital status, sexual orientation, religious beliefs, health data, disabilities and biometric data. We collect this information only with your consent and/or in strict compliance with applicable laws.

2. How do we collect Personal Data?
By using the Pickup Platforms or Pickup Services you are agreeing that we may collect your Personal Data and any Personal Data that you have provided to us is done so voluntarily. Without being exhaustive, you may be providing us your Personal Data when:

you create a user profile or submit a registration form on any of the Pickup Platforms or to utilise any of the Pickup Services;
you submit information, including Personal Data, to us to register as a merchant on the Pickup Platforms or to utilise any of the Pickup Services;
you use the Pickup Platforms or Pickup Services including but not limited to when you:
1. execute any transactions including placing or accepting any orders or making any payments;
2. provide any user feedback or ratings;
3. communicate using any of our messaging or other communications systems; or
4. interact with us, our agents or third party partners through the Pickup Platforms or otherwise;
you interact with any of our social media pages including through your personal, business’ or company’s social media account; or
you enter into, participate or join any events, campaigns competitions, contests, surveys, market research studies or other such promotions that Pickup may organise by itself or through a third party.

Furthermore, you may be providing your Personal Data to our third party partners including but not limited to our delivery partners, payment processing partners, marketing and promotion partners or any other partners whose services you may be availing of. You agree that, to the extent that you have consented and in accordance with applicable laws, such third parties may provide such Personal Data that they have collected to Pickup and that Pickup may use that Personal Data in order to provide you with access to the Pickup Platforms or use of the Pickup Services.

There may be circumstances where you may need to provide Personal Data of other individuals including information about your family or friends to us. If you do provide any such Personal Data, you represent and warrant to us that you have obtained the consent of such individuals to disclose their Personal Data to us and that we may collect and use such Personal Data in accordance with this Privacy Policy as if we collected such information directly from such individuals and that you will be liable for and indemnify us for any claim made by such individual as a result of our collection or use of their Personal Data that you have provided to us.

To use the Pickup Platforms or the Pickup Services, you should be over legal age under the applicable laws where you are utilising the Pickup Platforms or the Pickup Services. In the event that a legal minor utilises the Pickup Platforms or the Pickup Services, whether with the knowledge or not of their parent or legal guardian, and such minor provides any Personal Data to us, you as their parent or legal guardian consent to the processing of that minor’s Personal Data and you further agree to be responsible for any actions of such minor and to be bound by this Privacy Policy.

Pickup will not be responsible for any unauthorised use of the Pickup Platforms or use of the Pickup Services by yourself, users who act on your behalf or any other unauthorised users. While we will use our reasonable endeavours to monitor and prevent misuse of the Pickup Platforms or the Pickup Services in accordance with this Privacy Policy, it is your responsibility to take make your own informed choices about use of the Pickup Platforms or Pickup Services and take the necessary steps to prevent any misuse using your Personal Data.

3. How do we use your Personal Data?

Aggregation of your Personal Data
Any data or information that we collect, including Personal Data, may be used by us in combination with other data or information that we collect, including other Personal Data that we have collected. This means that if we collect Personal Data from you from your use of any of the Pickup Platforms or the Pickup Services, that Personal Data may be aggregated or linked with other Personal Data that we have collected from other sources.
For your use of the Pickup Platforms and Pickup Services
We may use your Personal Data to provide access to and to maintain, optimise and improve the Pickup Platforms and Pickup Services. As such, Pickup may, without limitation, use your Personal Data for the following purposes:
1. to provide you with access to the Pickup Platforms and Pickup Services which may exist or be available from time to time including the creation, maintenance and administration of your account, to enable certain personalizations and steam lining to enhance your user experience including participating in promotions, rewards, subscriptions or other such features or functionalities;
2. to conduct due diligence checks about you including the verification of your age and date of birth, your identity or other KYC related information including for fraud detection services;
3. to take and process orders, process payments including saving your preferred payment methods and to arrange delivery services;
4. to offer different product offerings and enhancements which may include financial or insurance products;
5. to store, host and back up your Personal Data;
6. to perform systems and security integrity checks and maintenance, software and systems troubleshooting, debugging, data and activity analytics, testing, research and monitoring and trend analysis or for other testing, research, analysis or product development;
7. for marketing, advertising or other promotional activities either from Pickup or our third party business partners;
8. to allow communications between you, Pickup, merchants, suppliers, users, clients, service providers and our other business partners including but not limited to notifications, alerts, updates, promotions, invitations to participate in events either via the Pickup Platforms, post, telephone, data messaging services, push notifications, emails or other communication mediums;
9. to resolve any customer service or support issues including the investigation of any complaints or concerns, monitoring and improvement of customer service responses, in responding to any questions, comments or feedback or to inform users about the resolution of any relevant issues; and
10. any other use that we consider to be necessary for the provision, enhancement or development of the Pickup Platform or Pickup Services, subject to applicable laws.
Use of your Personal Data in other Circumstances
We may also use your Personal Data in the following circumstances which are meant to be illustrative but not exhaustive:
1. to produce data for our own internal and statutory reporting and/or record-keeping requirements;
2. to act as a data processor where you may have provided consent to another third party data controller for such services to be rendered (for example from merchants that you have purchased goods or services from and who are utilising the Pickup Platforms or Pickup Services to fulfill part of their service to you);
3. to enforce our own terms of service or other agreements as they may exist from time to time;
4. to conduct automated decision-making processes in relation to the provision of the Pickup Services;
5. to ensure the safety and security of all of our users including the monitoring of compliance with this Privacy Policy, our terms and conditions and other relevant codes and policies;
6. to investigate and resolve claims, investigations or disputes including those raised by any relevant regulator or government authority or to protect our own rights or property relating to such claims, investigations or disputes;
7. to detect, prevent, report and assist in the prosecution of any illegal activities or crimes;
8. to comply with any court orders or other legal, governmental or regulatory requirements; or
9. in connection with any contemplated or completed merger, acquisition, joint venture, sale of company assets, consolidation, restructuring, financing, business asset sale, or acquisition of all or part of the Pickup business by another company or entity.
Compliance with Legal or Contractual Requirements
In certain circumstances, we may need you to provide your Personal Data so that we may use the information to satisfy or comply with certain legal requirements or for contractual purposes. If you do not provide us with such Personal Data, we may be unable to provide you access to the Pickup Platforms or use of the Pickup Services as it may not be possible for us and you to comply with the necessary legal requirements or contractual obligations.

4. When we may disclose your Personal Data?
We understand and recognise how sacred and valuable your Personal Data is. As such, our commitment is to ensure that we will only disclose or share your Personal Data for legitimate purposes and as necessary to provide you access to the Pickup Platforms and so that you can use the Pickup Services. With that in mind, there are circumstances where it is necessary for us to disclose your Personal Data to other parties outside of Pickup which may include but is not limited to the
following:

Third party partners including delivery service providers, payment processing partners and facilitators, data processing and analytics partners, cloud storage service providers, debt collection agencies, credit bureaus or credit reporting agencies, anti-money laundering service providers, criminal and background checking agencies, identity verification service providers, marketing, advertising or other promotional partners, research firms, insurance firms, financing partners including bankers, fund managers, brokers, asset managers and custodians, merchants, stores, wholesalers, suppliers and distributors, consultants, legal advisors and other business partners;
Other users of the Pickup Platforms or the Pickup Services including but not limited to its merchants, customers, delivery drivers and riders and recipients of orders; or
Government authorities and members of law enforcement including where it may be required to protect the public interest or safeguard the community, in emergency situations where the life, health or safety of an individual or group of individuals may be at risk or where there may be a breach or to prevent a breach of law.

We may also be required to disclose information in our possession, including your Personal Data, in circumstances where a merger with or acquisition by another company of Pickup may be contemplated or has occurred. Prior to any such disclosure, we will ensure that anyone we disclose
such information to is subject to any applicable data protection laws or regulations.

5. How long do we retain Personal Data?
Your Personal Data shall be retained for the period necessary to allow us to provide you access to the Pickup Platforms or to allow you to utilise the Pickup Services and to comply with the terms of this Privacy Policy, unless a longer retention period is required or allowed by law.

Once your Personal Data is no longer necessary to access the Pickup Platforms or use the Pickup Services, or we no longer have a legal or legitimate business purpose for retaining your Personal Data, we shall take reasonable steps to destroy, delete, erase, anonymise or prevent access or use of such Personal Data for any purpose other than to comply with this Privacy Policy, or for other legitimate purposes such as detection or prevention of criminal, fraudulent or other illegal activities,
security or community safety in accordance with the requirements of applicable laws.

6. Do we transfer your Personal Data internationally?
Sometimes it may be necessary for us to transfer your Personal Data outside of the jurisdiction in which you reside. We will only transfer your Personal Data outside of your jurisdiction in accordance with this Privacy Policy and in compliance with any applicable laws or regulations.

7. What about your tracking and cookies policy?
In order to optimise your use of the Pickup Platforms and the Pickup Services and to provide you with the best user experience possible, we routinely use devices such as cookies, tags, scripts, web beacons and other similar technology as part of the Pickup Platforms (collectively “Cookies”). When you use the Pickup Platforms, receive emails we send you, access our web pages or avail of the Pickup Services using any of your devices, you may be accepting to have these Cookies placed on your computer, mobile device or other equipment. These Cookies may transmit information or data, including Personal Data, about you and your use of the Pickup Platforms and web pages. This may include information about your browser, any searches you may have done or preferences you may have, your IP address, any advertisements that may have been presented to you or that you have clicked on or interacted with, and the time and date of any access or use by you. While some of these Cookies may be deleted after a specific session, others may continue to be stored on your computer or mobile device even after you have completed using the Pickup Platforms.

Pickup may also allow some of our third party partners to use their own Cookies on the Pickup Platforms and such third party partners may also collect the same type of information and Personal Data from your use of the Pickup Platforms. We may not necessarily have access to or control over the Cookies that third parties use and it is possible they may utilise some of the Personal Data they collect from you with other Personal Data they have about you through other sources.

It is also possible that Cookies may be used to share Personal Data with third parties that has been anonymised which can facilitate the display of targeted advertising on third party or social media platforms.

You may deactivate Cookies on the websites that you visit by changing your internet browser settings to disable, deactivate or block them and you can delete Cookies by deleting them from your device’s browser history or cache. However, there are some Cookies that are necessary to enable certain functionality on the Pickup Platforms and so changing your settings or deleting certain Cookies may affect your ability to utilise the Pickup Platforms or the Pickup Services.

8. How do we protect your information and Personal Data?
As previously mentioned, we know how your information and Personal Data is important to you. We will use reasonable technological and legal measures to ensure the protection of your Personal Data. We will use systems and measures to prevent unauthorised access to or use of your Personal Data and to prevent your Personal Data from being lost or stolen.

Any access to your Personal Data within Pickup will be limited to our employees and personnel on a need to know basis. Any processing of your Personal Data will be done so in an authorised manner and any individuals or persons carrying out such processing must treat any information they handle
with the utmost confidentiality.

Despite the safeguards and measures we take to try to protect the security of your Personal Data, as you may be aware, the transmission of information via the internet or world wide web may not be completely secure and that online hackers and thieves are constantly attempting to breach security protocols. As such, we cannot guarantee the security of your Personal Data that is transmitted via the internet, world wide web or other online means and you should be aware that any transmission
remains at your own risk.

The Pickup Platforms or your use of the Pickup Services may contain links or lead you to other applications or websites operated by other third parties, such as our business partners, merchants or payment gateways and processors. We are not responsible for the privacy practices of our business partners, merchants or payment gateways and processors or the applications or websites that they operate. We recommend and advise you to independently review the applicable privacy policies of
such third parties to determine how they will handle any information they collect from you.

9. What are your rights with respect to your Personal Data?
We will adhere to applicable laws and regulations in the collection, processing and storage of your Personal Data. In that regard and in accordance with applicable laws and regulations, you may be entitled to:

inquire about how your Personal Data is processed, including requesting from us a copy of your Personal Data;
request any changes, corrections and/or (in some cases) deletion of your Personal Data;
withdraw or revoke your consent to the processing of your Personal Data;
ask us to transmit to you or another entity, in a machine-readable form, the Personal Data that you have provided to us; and
make a complaint to the relevant data privacy authority if you believe your data privacy rights have been or are being violated or that we have done something wrong with respect to your Personal Data.

Where we have asked you to share your Personal Data with us, it is always your right to choose whether to share your Personal Data with us or not and whether to consent to us processing your Personal Data or not. If you have agreed to provide your Personal Data to us and consented to our processing of that Personal Data, we will respect your choice to later withdraw that consent and will abide by your choice in accordance with applicable laws and our legal obligations. In the event that you have withdrawn your consent, we may still continue to process your Personal Data to the extent we are reasonably required to do so and/or in compliance with any applicable laws or regulations.

If you do choose not to share your Personal Data with us or you withdraw your consent to our use of such Personal Data, we may be unable to provide access to the Pickup Platforms and you may not be able to use the Pickup Services.

Where you make any request in relation to your Personal Data as outlined above, we may require you to provide us with supporting documentation and information to allow us to verify your identity and authority to make such request and any response we provide will be conditional on our satisfaction that your identity has been verified and within any timelines as prescribed by any applicable laws or regulations.

10. What if we amend our Privacy Policy?
We may modify, update or amend the terms of our Privacy Policy at any time by placing such updated Privacy Policy on our website or the Pickup Platforms. By continuing to access the Pickup Platforms or use the Pickup Services following us placing such modified, updated or amended Privacy Policy on our website or the Pickup Platforms, you shall be agreeing and accepting to such modifications, updates or amendments. You are responsible for checking back frequently to see if any updates, amendments or changes have been made to this Privacy Policy.

11. How can you contact us in relation to our Privacy Policy?
If you have any queries about our Privacy Policy or would like to exercise your rights as provided for
under this Privacy Policy, you can contact our Data Protection Officer at:

Pickup Data Protection Officer
Email: dataprotection@pickup.ph
Address: Level 19, 102 H.V. Dela Costa Street, Makati, 1227 Metro Manila, Philippines

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