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: Privacy Policy
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 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:
Purpose/activity Type of data Lawful basis for processing
To install the App and register
you as a new Mobile Application
Ordering Platform user
Identity
Contact
Financial
Device
Your consent
To process mobile application
delivery purchases and deliver
Services including managing
payments and collecting money
owed to us
Identity
Contact
Financial
Transaction
Device
Marketing and
Communications
Location - Your consent (location) - Performance of a
contract with you - Necessary for our
legitimate interests (to
recover debts due to us)
In-store ‘check-in’ (to identify
which store you are in or near to
allow you to pay using Mobile
Application, and to provide an
enhanced visitor experience, for
example, through digital loyalty
cards). Your profile photo is also
used in store to verify your
identity. If you ask us to, we will
update, correct or delete your
profile photo. However, you
must have a profile photo if you
wish to use the Mobile
Application to pay for your
purchases in-store.
Location
Identity (profile photo) - Your consent
To manage our relationship with
you including notifying you of
changes to the Platform or any
Services
Identity
Contact
Financial
Profile
Marketing and
Communications - Your consent - Performance of a
contract with you - Necessary for our
legitimate interests (to
keep records updated and
to analyse how customers
use our products/
Services) - Necessary to comply
with legal obligations (to
inform you of any changes
to our terms and
conditions)
To enable you to participate in
our loyalty rewards schemes
Identity
Contact
Device
Profile
Marketing and
Communications - Your consent - Performance of a
contract with you - Necessary for our
legitimate interests (to
analyse how customers
use our products/Services
and to develop them and
grow our business)
To administer and protect our
business and this Platform
including troubleshooting, data
analysis and system testing, and
to make improvements to the
Platform for the future
Identity
Contact
Device
Location - Your consent (in respect
of Location Data) - Necessary for our
legitimate interests (for
running our business,
provision of administration
and IT services, network
security)
To deliver content and
advertisements to you
To make recommendations to
you about goods or services
which may interest you
To measure and analyse the
effectiveness of the advertising
we serve you
To monitor trends so we can
improve the Platform
To understand how our
customers use the Mobile
Application and how many
customers use the different
functions within the Web
Ordering Platform
Identity
Contact
Device
Content
Profile
Usage
Marketing and
Communications
Location - Your consent (in respect
of Location Data) - Necessary for our
legitimate interests (to
develop our
products/Services and
grow our business)
To provide personalised offers
and analyse which products and
rewards are most likely to
interest you.
Transaction
- Necessary for our
legitimate interests (to
develop our
products/Services and
grow our business)
To contact you
with offers and information
about Jollibee products or
services;
for customer research, e.g. to
help improve our service.
Contact
Marketing and
Communications
- Necessary for our
legitimate interests (to
develop our
products/Services and
grow our business)
## 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 feedback@jfcgrp.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 feedback@jfcgrp.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: feedback@jfcgrp.com
## 12. Contacting us
If you have any queries, please contact us at
Email: feedback@jfcgrp.com