1. Introduction

1.1 This Privacy Policy elucidates the procedures employed by Thessy Logistics, including its affiliates (referred to as “we,” “our,” “us,” and “Logistics”), in collecting, retaining, processing, transferring, and utilizing your personal data, along with the corresponding rights you possess regarding the processing of personal data. For the purposes of this Privacy Policy, “Thessy Logistics” denotes the specific entity providing services to you on the date you receive this Privacy Policy.

1.2 This Privacy Policy pertains to the following personal data collected about you when you use or access our web applications, mobile applications (collectively referred to as “Applications”), and our website at http://www.thessylogistics.com.

1.3 We operate Applications and a website to function as a platform connecting users of our platform to drivers, including individuals using other modes of transportation. Our goal is to facilitate these drivers in providing on-demand delivery and purchasing services (“Services”). Our Applications and Services are primarily designed for adults. We will not knowingly collect personal data from minors (i.e., individuals who have not reached the age of 18 years or the equivalent minimum age for full legal capacity in the relevant jurisdiction) unless such data has been provided with prior consent from a relevant person (i.e., a person with parental responsibility for the minor). If you, as the relevant person, disclose personal data of a minor under your parental responsibility to us, you hereby consent to the collection and processing of such minor’s personal data and accept and agree to be bound by this Privacy Policy. In the event that we are informed of any collection of personal data from a minor without the consent of a person with parental responsibility, we will promptly delete such personal data.

1.4 This Privacy Policy is applicable to the personal data of (jointly referred to as “you” or “your”):

(A) Visitors: Individuals who visit our website or download or access the Applications without being a User as defined below;

(B) Users: Individuals who: (i) use, request, or receive Services; (ii) contact us through our website, Applications, or by phone or other means of communication; (iii) enter into our contests or competitions; or (iv) subscribe to our updates or blog;

(C) Agents: Representatives of our corporate customers or business partners, such as owners, managers, leaders, or other representatives of a fleet; and

(D) Drivers: Individuals who provide or submit applications to us to provide Services through our Applications individually or through partner companies, whether or not subsequently successfully registered as a driver for Thessy Logistics.

1.5 Before using our website, Services, or Applications, please read and comprehend this Privacy Policy.

2. Sources of Personal Information

2.1 When you visit our website or use our Applications and Services, there is a likelihood that we will request your personal information. Failing to provide this information may impede our ability to offer products, services, or respond to your inquiries. For instance, you might be unable to request delivery services through our website or Applications.

2.2 The collection and processing of personal data include:

(A) Information directly provided by you, such as during account creation via our Applications, participation in competitions, contests, and promotional activities, subscribing to our blog or updates, or contacting us through our website, Applications, or by phone;

(B) Information generated during your use of our website, Services, and Applications. This may include collecting your IP address and device information when you visit our website;

(C) Information obtained from third parties (e.g., third-party agents, other Users, service providers, and business partners). Examples include third-party agents providing additional verification and background information on Drivers, and other Users supplying your name and phone number when booking a vehicle for you.

2.3 Additionally, personal data may be collected through Software Development Kits (“SDKs”) utilized in providing our Services.

2.4 Furthermore, we may collect personal data from Drivers participating in our Driver Referral Program and Driver Campaign (“Drivers’ Programs”) as relevant to processing their requests to enter or participate in these programs.

3. Collection of Personal Data

3.1 The personal information gathered about you includes the following:

(A) For Visitors:

1. IP address or other unique device identifiers.
2. Patterns of usage on our website or the Applications.

(B) For Users:

1. Full name.
2. Email address.
3. Phone number.
4. Residential address.
5. Correspondence history with us.
6. IP address or other unique device identifiers.
7. Payment and banking details.
8. Geolocation.
9. User profile specifics, such as login credentials, passwords, profile picture, saved routes, language preference, preferred drivers’ details, feedback, ratings, compliments, order specifics, type of service used, and referrer and referee details from a User-participated referral program.
10. Usage patterns on Applications or other pertinent data.
11. Personal information voluntarily entered by the User in a free-text box when utilizing our Services.

(C) For Agents:

1. Full name.
2. Email address.
3. Company name.
4. Job title.
5. Phone number.
6. Business industry.
7. Residential address.
8. Correspondence history with us.
9. IP address or other unique device identifiers.
10. Payment and banking details.
11. Geolocation.
12. Agent profile details, including a profile photo.
13. Usage patterns on Applications or other relevant personal data.
14. Copy of ID card or national identification number along with the expiry date.

(D) From Drivers:

1. Driver’s full name.
2. Contact phone number.
3. Email address.
4. Residential address.
5. History of communication with us.
6. IP address or other distinctive device identifiers.
7. Payment and banking details.
8. Geographical location.
9. Driver profile specifics, including login credentials and passwords, profile photo, vehicle image, language preference, feedback, ratings, compliments, and details of participation in a Driver-referral program.
10. Patterns of usage on Applications or other relevant data.
11. Driving license identification number and expiry date.
12. Information necessary for collecting and processing fees.
13. Vehicle details and photo.
14. Vehicle insurance particulars.
15. National identification number and expiry date.
16. Date of birth.

3.2 Our collection of personal data is limited to information reasonably required for the purposes outlined in paragraph ‎4 of this Privacy Policy. We refrain from obtaining personal data that exceeds the necessary scope, ensuring appropriateness and relevance in our data collection practices.

4. Use of Your Personal Data

4.1 We may gather, process, compile, and organize your personal data in the following formats:

(A) For Visitors, Users, and Agents:

1. Records of profile information.
2. Remarks, records, and reports of Services usage, including interactions with customer service.
3. Records of payments related to our Services.
4. Records and reports of Applications usage, encompassing bug reports, competitions or contests, and login sessions.
5. Records of live chat history, feedback, and ratings given to Drivers.

(B) For Drivers:

1. Records of profile information.
2. Records and reports of Services usage, including interactions with customer service, Driver operations, field agents, and third-party service providers.
3. Records of payments related to our Services.
4. Records and reports of Applications usage, including bug reports, competitions or contests, and login sessions.
5. Reports of live chat history and feedback from Users and Agents.
6. Records of deliveries and performance.
7. Records of vehicles, driving permits, vehicle insurance, and vehicle licenses.

4.2 We may process your personal data for the following purposes:

(A) Visitors, Users, and Agents:

1. Provide and maintain our Services, including creating, updating, and maintaining your registered account.
2. Enable transportation and deliveries.
3. Track deliveries.
4. Offer, process, or facilitate payment for deliveries or our Services.
5. Monitor the use of our website, Services, or Applications.
6. Maintain the safety, security, and integrity of our Services, preventing crime and fraud.
7. Personalize your experience on our Applications, understanding preferences and behavior to provide tailored Services.
8. Improve our website, Services, and Applications, including developing new features and functionality.
9. Conduct marketing activities with your consent, allowing you to unsubscribe at any time.
10. Enhance customer service, respond effectively to requests, receive feedback, and provide support.

(7) For Research and Development:

Your personal data will contribute to testing, research, analysis, and assistance with product development and machine learning, aiming to enhance your overall experience.

(8) Compile Aggregate Statistics:

We use your data to compile aggregate statistics about your usage of Services and Applications, aiding in the analysis of your interactions.

(9) Non-Marketing Communications:

We employ your personal data for non-marketing communications related to our Services, such as notifications of changes to our Applications or Services.

(10) Administer Our Business:

Utilizing your personal data, we manage and administer our business, including the maintenance of databases storing personal information.

(11) Legal Proceedings:

We may use your data for legal proceedings or as required by regulators, government entities, official inquiries, or to fulfill our legal obligations.

(12) Direct Marketing:

Subject to obtaining your consent as per applicable laws and as detailed in paragraph ‎14 of this Privacy Policy, we may use your personal data for direct marketing purposes.

(B) For Drivers:

1. Provide and maintain our Services, such as creating, updating, and maintaining your registered account.
2. Enable and notify transportation, orders, and deliveries.
3. Track deliveries.
4. Offer, process, or facilitate payment for deliveries or our Services.
5. Monitor the use of our Services, Applications, and website.
6. Help maintain the safety, security, and integrity of our Services, including screening Drivers.
7. Personalize your experience on our Applications, understanding preferences and behavior to provide tailored Services.
8. Improve our website, Services, and Applications, including developing new features and functionality.
9. Conduct marketing activities with your consent, allowing you to unsubscribe at any time.
10. Enhance customer service, respond effectively to requests, receive feedback, and provide support.
11. Contribute to research and development, testing, analysis, and product development.
12. Compile aggregate statistics and analyze Services, Applications usage, and deliveries, including performance metrics of services provided by the Driver.
13. Non-marketing communications related to our Services, such as notifications of changes to our Applications or Services.
14. Administer our business, including managing and maintaining databases storing personal data.
15. Legal proceedings or as required by regulators, government entities, official inquiries, or to comply with our legal obligations.
16. Direct marketing, subject to obtaining your consent as per applicable laws and as contemplated in paragraph ‎14 of this Privacy Policy.
17. Providing benefits to the Drivers, including the purchase of insurance.

4.3 If we intend to utilize your personal data for purposes not covered by this Privacy Policy, we will inform you, seek your prior consent where applicable, and ensure compliance with applicable laws.

4.4 We are permitted to use your personal data due to one or more of the following reasons:

(A) We have obtained your consent.

(B) It is necessary to fulfill our contractual obligations with you.

(C) We have legal duties and regulatory obligations to fulfill.

(D) The use of your personal data is necessary for our legitimate interests.

(E) It is required to respond to public health incidents or protect the vital interests of individuals.

(F) We have other legal bases allowed by applicable laws to process your personal data.

4.5 Not all data protection laws are uniform, so the legal bases listed in paragraph ‎4.4 may not apply universally. We process your personal data according to the legal basis permitted by applicable laws in your jurisdiction.

4.6 Your personal data collected by us will not be sold, exchanged, shared, transferred, or provided to a third party for their own direct marketing purposes without your prior consent or other legal bases allowed by applicable laws.

5. Personal Data Sharing and Disclosure

5.1 Our Services necessitate sharing your personal data with other users, including:

(A) Sharing Users’ or Agents’ full name, phone number, personal data from free text boxes voluntarily entered by a User, and pick-up or drop-off locations with Drivers to complete a delivery.

(B) Sharing the Driver’s name, phone number, driver profile information, vehicle details, vehicle picture, and geolocation with Users or Agents after initiating a delivery.

If you are a fleet member, your personal data (e.g., name, phone number, driver profile information, records and reports of Services and Applications usage, payment records, vehicle information) will be shared with the fleet owner or manager.

Exercise caution when disclosing personal data to Drivers, Users, or Agents. We cannot control the actions of other users, and while we do not routinely monitor these interactions, we reserve the right to do so. Therefore, we cannot guarantee that the personal data you share will not be reviewed by unauthorized persons. You acknowledge that your personal data may still be accessed by relevant users even after the completion of delivery, such as viewing transaction records containing your personal data.

5.2 We may share your personal data to facilitate our website, Services, Applications, or for legal reasons with:

(A) Our Internal Stakeholders:

Our employees, officers, or independent consultants.

(B) External Advisors:

Our auditors, external legal, and financial advisors.

(C) Business Partners and Service Providers:

1. IT service and software suppliers.
2. Payment processors and facilitators.
3. Cloud platform service providers.
4. Cloud storage providers.
5. Data analytics providers.
6. Research partners.
7. Marketing and advertising agencies involved in creating advertisements and promotions.
8. Background check and identity verification providers.
9. Vendors assisting in enhancing the safety and security of our website and Applications.
10. Customer service providers.

(D) Insurers and Financial Entities:

Our insurers, bankers, and the insurers of Drivers.

(E) Regulatory Bodies and Government Entities:

Any regulator or government body as required by applicable laws.

(F) Affiliates:

Our subsidiaries, parent companies, and other affiliates to aid in providing Services or conducting data processing on our behalf.

(G) Legal and Safety Disclosures:

Any applicable persons if we believe it is required by applicable laws, legal process, governmental request, or due to safety concerns. This includes exchanging your personal data with other companies or organizations for crime/fraud protection and prevention.

(H) Business Transactions:

Another company in connection with or during negotiations of any merger, sale of company assets, consolidation, restructuring, financing, or acquisition of all or a portion of our business by or into that other company.

5.3 We ensure that third parties are bound by confidentiality obligations before sharing your personal data with those outlined in paragraph ‎5.2 of this Privacy Policy.

5.4 We do not share your personal data with anyone other than as described in paragraph 5.2 of this Privacy Policy. In such circumstances, we will notify you and obtain your consent beforehand if required by applicable laws.

5.5 We do not sell your personal data to third parties and commit to the legitimate and fair use of personal data only within the bounds permitted by law.

6. International Transfer of Personal Data

6.1 Given our global business operations, we collect and transfer personal data on a global scale, which may involve transferring your personal data to locations outside your country/region. Such transfers will adhere to this Privacy Policy and comply with applicable laws. Where required by law, we will ensure that the transfer of personal data meets standards comparable to those under the applicable laws. We will obtain a similar undertaking from any overseas recipient of your personal data if mandated by applicable laws.

6.2 For more details, please reach out to us using the contact information provided in the “Contacting us” section below.

7. Security of Personal Data

7.1 Upon receiving your personal data, we will take all reasonably practicable steps and employ security measures as mandated by applicable laws to ensure its secure storage and protection against unauthorized or accidental access, processing, erasure, loss, or use.

7.2 Your personal data will be kept confidential and secure, disclosed only on a “need-to-know” basis as outlined in this Privacy Policy.

7.3 When outsourcing and entrusting personal data to data processors, we will use contractual and other means to monitor compliance with this Privacy Policy.

7.4 Organizational, physical, and technical security measures aligned with industry standards have been adopted to protect the personal data you provide. Security measures may include SSL certificate signing, TLS encryption, and hashed password storage.

7.5 You are responsible for keeping your Applications password confidential and must not disclose it to third parties. Notify us immediately if you suspect compromise of your password or record.

7.6 While we employ security measures for data transmission, we cannot guarantee the complete security of personal data transmitted to the Applications. Any transmission is at your own risk.

8. Retention of Personal Data

8.1 Personal data collected will not be retained longer than necessary for the purposes stated in paragraph ‎4 of this Privacy Policy, unless otherwise required or permitted by applicable laws.

8.2 If your Applications account remains inactive for three years or has been closed upon your request (“End Date”), your personal data will be retained for the purposes stated in paragraph 4 of this Privacy Policy or as permitted by applicable laws. Extended retention may occur if necessary for contractual or legal obligations, or with your consent.

8.3 At the end of the retention period, personal data, app-related data, and account-related information will be deleted. Physical documents containing personal data will be securely destroyed.

8.4 Our data processors will retain personal data only for the period necessary to fulfill the purposes stated in paragraph ‎4 of this Privacy Policy, ensuring compliance with applicable laws. Deletion will occur unless prohibited by law.

9. Your Rights

9.1 We respect your legal rights concerning your personal data. The following outlines your legal rights and the measures we undertake to safeguard them. Note that not all data protection laws are uniform, and these rights may not apply universally.

(A) Right to Information and Access: You have the right to obtain information about the processing of your personal data and access the personal data we hold about you.

(B) Right to Rectify: You can request the correction of your inaccurate or incomplete personal data.

(C) Right to Erasure, Block, or Anonymize: In certain circumstances, you can request the erasure, blocking, or anonymization of your personal data. Please note that legal entitlements may permit us to retain it.

(D) Right to Data Portability: In some instances, you have the right to receive some personal data in a structured, machine-readable format and request its transmission to a third party, where technically feasible.

(E) Right to Withdraw Consent: You can withdraw your consent to our processing of your personal data, with exceptions outlined in applicable laws.

(F) Information on Refusing Consent: You have the right to be informed about the possibility of refusing consent and its consequences.

(G) Right to Object and Restrict Processing: You can object to, and request the restriction of, processing your personal data in certain circumstances, subject to legal entitlements.

(H) Right to Request Data History: You can request a history of your collected personal data.

(I) Protection from Automated Processing: You have the right not to be subject to a decision based solely on automated processing.

(J) Right to Lodge a Complaint: You have the right to file a complaint with the competent authority if you believe your rights have been violated by us.

9.2 Technical measures will be in place to enable you to control the use of your personal data. Besides exercising some rights through your Applications account, you can contact us using the details in the “Contacting us” section below to exercise all your rights.

10. Cookies

Refer to our Cookie Policy for details.

11. Third-Party Links

11.1 At our discretion, we may include links to third-party products or services on our website or Applications.

11.2 These third-party websites have their separate privacy policies and user terms that must be reviewed before use.

11.3 We do not assume responsibility for the content and activities of these third-party linked websites or their products and services.

11.4 We seek to protect our website and Applications’ integrity and welcome feedback on these third-party links.

12. Changes to Our Privacy Policy

12.1 We may update this Privacy Policy in response to legal, technical, or business developments. We will inform you of significant changes and obtain consent if required by applicable laws. Check the “last updated” date for the latest version.

12.2 Review this Privacy Policy periodically. Continued use of our website, Applications, or Services implies acceptance of changes or updates. Failure to consent means denial of access to our Applications or Services.

13. Contact Us

13.1 For any comments, queries, complaints, data access requests, or data correction requests related to your personal data, contact us at: http//www.thessylogistics.com

14. Direct Marketing

14.1 If we provide Services or interact in a business capacity, we may directly market our website, Services, or Applications. For personal interactions, your personal data may be used for direct marketing.

(A) Personal Data Used:

(1) Your name

(2) Your email address

(3) Your phone number

(4) Your address

(B) Direct Marketing Activities Include:

(1) Newsletters and blog updates

(2) Promotions of website, Services, or Applications

(3) Contests or competitions

(4) Updates on website, Services, or Applications

(5) Surveys related to website, Services, or Applications

(6) Event invitations

(7) Festive greetings

(8) Advertisements of website, Services, or Applications

(9) Loyalty program with gifts

14.3 We will not use this data for direct marketing without your consent. Request cessation of direct marketing by calling us at +852 3701 3701 or replying with “unsubscribe” to any communication from us.

15. Language Versions

In case of discrepancies, the English version prevails.

APPENDIX 1: JURISDICTION SPECIFIC TERMS – UNITED KINGDOM

Personal data may be used for direct marketing in categories including on-demand delivery services, loyalty programs, co-branded partner services, and charitable contributions, provided in collaboration with Thessy Logistics entities and third-party partners.