PRIVACY POLICY 

Entrek (B) Sdn Bhd as Jollibee (Jollibee, we) are committed to protecting your personal  data and respecting your privacy. 

Under data protection laws, we are required to provide you with certain information about  who we are, how we process your personal data and for what purposes, and your rights in  relation to your personal data (information, data, personal data).  

The Jollibee Mobile Application Ordering Platform (Platform) is owned and operated by  Jollibee, who is the “data controller” of the personal data that you provide. The Platform is  hosted by LimeTray, who is a Jollibee third-party service provider. 

This policy, together with our Mobile Application Ordering Platform TERMS OF USE, explain  how we may use information we collect about you, as well as your rights over any personal  data we hold about you. Please read this policy and our Mobile Application Ordering  Platform TERMS OF USE carefully. 

You can download a pdf version of the policy here: [LINK]. 

Index of Privacy Policy Clauses 

1. Information we collect about you through the Mobile Application Ordering Platform. 2. How your information is collected 

3. Using your information 

4. Purposes for which we will use your information 

5. Marketing communications 

6. Data storage 

7. Disclosing your information 

8. Your rights 

9. Changes to our policy 

10. Cookies 

11. How you can withdraw consent 

12. Contacting us 

## 1. Information we collect about you through Mobile Application Ordering Platform. We collect personal data about you when you: 

- register to use the Platform; 

- use the payments facility in the Platform to pay for your purchase; 

- contact us via the Platform in relation to a request, concern, suggestion, or claim. 

More generally, we collect, use, store and transfer the following types of personal data about  you: 

- Identity Data includes first name, last name, date of birth (optional), profile photo. - Contact Data includes address (home, postal or other physical address), email address  and telephone numbers. 

- Financial Data includes payment card details, however, please note that your card details  are not stored on the Platform and they are only used in accordance with your payment 

instructions. Your card details are stored with our payment gateway partner – MPGS (Mastercard Payment Gateway System). You have to use the payments facility within the Mobile Application to pay for your purchase through the website. 

- Transaction Data includes details about payments to and from you and details of web  delivery purchases. 

- Content Data includes information stored on your Device, including photos for profile  pictures if selected (photo required for certain features). 

- Profile Data includes, your username and password, web delivery purchase history, your  interests, preferences, feedback and survey responses 

- Marketing and Communications Data includes your preferences in receiving marketing  from us and our third parties and your communication preferences. 

- Location Data includes your current location disclosed by GPS technology.  

Your personal data is stored in an encrypted database and transferred over a secure network  connection. You decide which data you do and do not share with us. If you ask us to, we will  update, correct, or delete any data which you give to us. 

## 2. How your information is collected 

We will collect and process the following data about you: 

- Information you give us. This is information (including Identity, Contact, Financial, and  Marketing and Communications Data) you consent to giving us about you by filling in forms  on the Mobile Application, or by corresponding with us (for example, by email or chat). It  includes information you provide when you register to use the Mobile Application, subscribe  to any of our services, make an web delivery purchase, share data via an App's social  media functions, enter a competition, promotion or survey, or Jollibee reward schemes and  when you report a problem with the Platform. If you contact us, we will keep a record of  that correspondence. 

- Information we collect about you and your device. Each time you use the Mobile  Application we will automatically collect personal data including Device, Content and  Usage Data. We collect this data using cookies and other similar technologies. Please see  our cookie policy [LINK] for further details. 

- Location Data. We also use GPS technology to determine your current location. Some of  our location-enabled services require your personal data for the feature to work. If you wish  to use the particular feature, you will be asked to consent to your data being used for this  purpose. You can withdraw your consent at any time by disabling Location Data in your  settings. 

If you simply browse through our website without registering an account, we do not collect any  of your personal information. 

## 3. Using your information 

Collecting personal data in the Mobile Application helps us to better understand what you  need from us. 

We will only use your personal data when the law allows us to do so. Most commonly we will  use your personal data in the following circumstances: 

- where you have consented before the processing; 

- where the processing is necessary to perform a contract, we are about to enter or have  entered with you;

- where it is necessary for our legitimate interests (or those of a third party) and your interests  and fundamental rights do not override those interests, such as: 

- improve the functionality and performance of the Mobile Application Ordering  Platform; 

- personalise our services to you and offer you services that are similar to your  preferences; 

- tell you about important changes to the Mobile Application Ordering Platform and  related services, and  

- manage customer surveys and questionnaires, which will in any case be subject to  the specific terms and conditions of said surveys and questionnaires. 

- where we need to comply with a legal or regulatory obligation. 

Your personal data is safe with us and will never be released to third party companies for  marketing purposes. 

## 4. Purposes for which we will use your information:

## 5. Marketing communications

We may use your Identity, Contact, Technical, and/or Usage Data of our customers to form  a view on what we think our customers may want or need, or what may be of interest to  them and in doing so we will only send information that is deemed: 

(i) Direct Marketing: These are communications that relevant to their use of our  services and related to similar products belonging to Jollibee that the customer has  previously ordered. The sending of these communications is necessary for our  legitimate interests in growing and developing our business including our products  and services. Jollibee will send such communications provided you do not opt out  to the receiving of said direct marketing communications.  

(ii) Authorised by you: Customers will receive marketing communications from us  if they have consented to the receipt of this information and, in each case, provided  they have not opted out from receiving that marketing.  

We will also ask for express consent before we share personal data with any third party for  marketing purposes.  

You can ask us to stop sending marketing communications at any time from the My Account  menu within the Platform or by clicking in the ‘unsubscribe’ button foreseen at the bottom of  said communications. You may refuse consent for marketing messages without detriment to  any other areas of functionality within the Platform. 

## 6. Data storage 

Your data is stored in an encrypted database and transferred over secure network  connections. We will store your information for as long as your account exists in the Mobile  Application. If your user account is entirely inactive for a period of 12 months or more, we  will delete your account. If you ask us to, or if you delete your account, we will delete the  information linked to your account which can identify you personally, including your profile  photo and personal details in accordance with relevant privacy regulations and our internal  guidelines. 

You may ask us, at any time, to provide to you confirmation that your data is being  processed and access to your personal data. This will generally be provided within 7-21  working days. 

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 data  transmitted to our website; any transmission is at your own risk. Once we have received  your personal data, we will use strict procedures and security features to try to prevent  unauthorised access. We urge you to take every precaution to protect your personal data  when you are on the internet. 

## 7. Disclosing your information 

Your personal data will only be disclosed to those of our employees or workers (which may  include employees or workers at our head office) that have a need for such access for the  purpose for which it was collected.  

We will never disclose your information to anyone outside of Jollibee except: 

- Where it is necessary for the performance of our contract with you, including where you  have asked us to do so or where we need to take steps to enforce any contract which may  be entered into between us

- Where we have your consent 

- Where we are required or permitted to do so by law 

- To other companies who provide a service to us as a processor under the terms of this  privacy policy, such as LimeTray which hosts and provides back-end support for Mobile Application and MPGS via unique identifiers for the purposes of payment and investigation  of any transactional issues. 

- In order to protect the rights, property or safety of our business, our employees and  workers, customers, suppliers and others. This includes exchanging information with other  companies and organisations for the purposes of fraud prevention and credit risk reduction - To any successors in title to our business. 

We require all third parties that process personal data on our behalf to respect the security  of your personal data and to treat it in accordance with the law. We do not allow our third  party service providers to use your personal data for their own purposes and only permit  them to process your personal data for specified purposes and in accordance with our  instructions. 

## 8. Your rights 

Under certain circumstances you have the following rights under data protection laws in  relation to your personal data: 

• Request access to your personal data (commonly known as a "data subject access  request"). This enables you to receive a copy of the personal data that we hold about you  and to check that we are lawfully processing it. 

• Request correction of the personal data that we hold about you. This enables you to  have any incomplete or inaccurate data that we hold about you corrected, although we  may need to verify the accuracy of the new personal data that you provide to us. 

• Request erasure of your personal data. This enables you to ask us to delete or remove  personal data where there is no good reason for us continuing to process it. You also  have the right to ask us to delete or remove your personal data where you have  successfully exercised your right to object to processing (see below), where we may have  processed your personal data unlawfully or where we are required to erase your personal  data to comply with local law. Please note, however, that we may not always be able to  comply with your request of erasure for specific legal reasons which will be notified to you,  if applicable, at the time of your request. 

• Object to processing of your personal data where we are relying on a legitimate interest  (or those of a third party) and there is something about your particular situation which  makes you want to object to processing on this ground as you feel it impacts on your  fundamental rights and freedoms. You also have the right to object where we are  processing your personal data for direct marketing purposes. In some cases, we may  demonstrate that we have compelling legitimate grounds to process your personal data  which override your rights and freedoms. 

• Request restriction of processing of your personal data. This enables you to ask us to  suspend the processing of your personal data in the following scenarios: (a) if you want  us to establish the data's accuracy; (b) where our use of the data is unlawful but you do  not want us to erase it; (c) where you need us to hold the data even if we no longer require  it as you need it to establish, exercise or defend legal claims; or (d) you have objected to  our use of your data but we need to verify whether we have overriding legitimate grounds  to use it. 

• Request the transfer of your personal data to you or to a third party. We will provide to  you, or a third party you have chosen, your personal data in a structured, commonly used,  machine-readable format. Note that this right only applies to automated information which 

you initially provided consent for us to use or where we used the information to perform a  contract with you. 

• Withdraw consent at any time where we are relying on consent to process your personal  data. However, this will not affect the lawfulness of any processing carried out before you  withdraw your consent. If you withdraw your consent, we may not be able to provide  certain products or services to you. We will advise you if this is the case at the time you  withdraw your consent. You can ask us to stop sending you marketing messages at any  time by following the “unsubscribe” (or similar) links on any marketing message sent to  you or by contacting us at any time. Where you opt out of receiving these marketing  messages, this will not apply to personal data provided to us as a result of a purchase,  product/service experience or other transactions. 

To obtain a copy of the information we hold about you, or to exercise and of your other rights  at any time, please email us at mobileapp@jollibeebrunei.com. Please confirm any details to help us  identify and locate your information. If any of the details are incorrect, let us know and we  will amend them. 

You will not have to pay a fee to access your personal data or to exercise any of your other  rights. However, we may charge a reasonable fee if your request is clearly unfounded,  repetitive or excessive. Alternatively, we may refuse to comply with your request in these  circumstances. 

We may need to request specific information from you to help us confirm your identity and  ensure your right to access your personal data (or to exercise any of your other rights). This  is a security measure to ensure that personal data is not disclosed to any person who has  no right to receive it. We may also contact you to ask you for further information in relation to  your request to speed up our response. 

We try to respond to all legitimate requests within one month. Occasionally it may take us  longer than a month if your request is particularly complex or you have made a number of  requests. In this case, we will notify you and keep you updated. 

You also have the right to make a complaint at any time to mobileapp@jollibeebrunei.com. 
## 9. Changes to our policy 

This policy replaces all previous versions and is correct as of [20 February 2023]. We  reserve the right to change the policy at any time. 

## Third party links 

The Mobile Application may, from time to time, contain links to and from the websites of our  partner networks, advertisers and affiliates. Please note that these websites and any services  that may be accessible through them have their own privacy policies and that we do not accept  any responsibility or liability for these policies or for any personal data that may be collected  through these websites or services, such as Contact and Location Data. Please check these  policies before you submit any personal data to these websites or use these services. 

## 10. Cookies And Other Similar Technologies 

A cookie is a small file which asks permission to be placed on your computer's hard drive.  Once you agree, the file is added, and the cookie helps analyze web traffic or lets you know  when you visit a site. Cookies allow web applications to respond to you as an individual. The  web application can tailor its operations to your needs, likes and dislikes by gathering and 

remembering information about your preferences. 

We use traffic log cookies to identify which pages are being used. This helps us analyze  data about web page traffic and improve our website in order to tailor it to customer needs.  We only use this information for statistical analysis purposes and then the data is removed  from the system. We use the basic cookies based on the browser. For example, if you are  using a Google Chrome, Google will capture those default cookies. f you, however, want to  delete cookies from your browser or device, we suggest that you use the option to delete  cookies and other site and plug-in data, including data stored on your device from your  browser settings normally found in browsing history. 

Overall, cookies help us provide you with a better website by enabling us to monitor which  pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.  Most web browsers automatically accept cookies, but you can usually modify your browser  setting to decline cookies if you prefer. This may however prevent you from taking full  advantage of the website. 

Cookie Description 

Analytics cookie: A first party browser-based cookie allows the site to measure audience  behavior. There is no personally identifiable information stored in these cookies. 

## 11. How you can withdraw consent 

Once you provide consent by selecting "YES", you may change your mind and withdraw  consent at any time by contacting us at the contact details set out below but that will not  affect the lawfulness of any processing carried out before you withdraw your consent.  

Email: mobileapp@jollibeebrunei.com 

## 12. Contacting us 

If you have any queries, please contact us at  

Email: mobileapp@jollibeebrunei.com