Effective Date: August 1, 2019
Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.
The Information We Collect About You
We collect information about you directly from you and from third parties as further set out below, as well as automatically through your use of the Grab Properties. We may combine the information that we collect, whether directly from you, automatically, or from social networks for the reasons set out in the How We Use Your Information section below.
Information We Collect Directly From You. We collect information directly from you when you register with us, place an order, request information from us, or otherwise contact us. The type of information that we collect from you depends on your interaction with the Grab Properties, and may include: your name, photo, email address, phone number, current location, destination location, flight information, ordering preferences (including for retail and concessions) and additional information that you may provide to us at our request from time to time. If you make a purchase from us, we will also collect your payment information and billing address.
Information that We Collect About You from Social Networking Sites. You may log into the App or the Website using your Facebook and other social networking site credentials. If you do so, we will request permission from you to access the following information about you: (i) your name; (ii) user ID; (iii) e-mail address; and (iv) profile photo.
Where you use third-party social networking sites, the third-party social networking site controls the information it collects from you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
Information We Collect Automatically.
We automatically collect information about your use of our App through cookies, web beacons and other technologies, including but not limited to:
- your precise location;
- web pages and sites you view;
- advertising and promotions displayed to you;
- links you click;
- pages viewed;
- time within our App and/or our Website;
- referring URL or the webpage that led you to our App and/or Website;
- device-related data, including browser type, domain name, operating system, device type, device model, device identifier, device name, mobile device ID, application ID, browser language, device language, time zone, IP address and IP address fraud history;
- IMEI and MAC address; and
- other statistical or technical information related to your device, your use of the App or Website, or the version of our App or Website that you are using.
Important Note: This App will continue to track your location through beacons and other technologies even when you are not using the App.
Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
Information We Collect About You From Other Sources.
We may obtain information about you from third party sources, such as the companies we work with to provide services to you (i.e., restaurants or other merchants), affiliates, data aggregators or other public databases.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
- To provide our Grab Properties to you, to administer customer accounts, to run our business, to communicate with you about your use of our Grab Properties, to respond to your inquiries, to process and fulfill your orders, to send you updates about your orders (including through push notifications and text messages, at your election) and for other customer service purposes.
- To track your location and proximity to merchants in order to provide services to you.
- To send you push notifications regarding orders placed through the Grab Properties and promotions that you may opt in to.
- To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Grab Properties.
- For marketing and promotional purposes. For example, we may use your information to send you special offers and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us or third party companies in providing you relevant advertising and promotions from us or from third party companies. To better understand how users access and use our Grab Properties, both on an aggregated and individualized basis, in order to maintain and improve our Grab Properties and respond to user desires and preferences, and for other research and analytical purposes.
- To administer a customer or user loyalty program.
- To conduct benchmarking, analytics and statistical analysis.
- If you have granted us permission to post to your Facebook Wall, and/or other social sharing properties.
- For purposes of data integrity and data security.
- To meet legal or regulatory requirements. We are required to comply with certain legal and regulatory requirements and we may process your information in order to comply with those requirements. Occasionally, we may be asked to provide certain information to regulators or law enforcement agencies and we will comply with these requests where legally required or permitted.
How We Share Your Information
We may share your information, including personal information, as follows:
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries.
- Service Providers. We disclose your information to third party vendors, service providers, contractors or agents who perform administrative and operational functions on our behalf, however, if we do so, their use and disclosure of your information will be governed by a contract requiring them to only use and disclose data in accordance with this Policy. We may also share your information with third party service providers to enable those service providers to: (i) process and fulfill your orders; and (ii) review and analyze statistical information pertaining to the Website and/or the App.
Third Parties. We may share your information with third parties for marketing and advertising purposes on our App or on the Website. For example, we may share your information with third parties, such as merchants and airport operators that wish to run an ad promoting their products or services that are available for sale via the Grab Properties, or that wish to encourage you to use the Website or download and use the App. We may also share your information with third parties with whom you place an order, to facilitate fulfillment of your order.
If you would like to know the names of the organizations to which your personal information has been disclosed please send us an email at email@example.com.
In addition, we may process or share your information in the following circumstances:
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. To comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena or to establish, exercise or defend legal claims.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information with third parties to assist us in our own marketing, advertising, research or similar purposes.
Cookies. Cookies (and similar identifiers) are alphanumeric identifiers that we transfer to your device for record-keeping purposes. We use these technologies, among other purposes, to track your in-App and/or Website activities, to assist with log-in and for advertising and marketing purposes (see also How We Use Your Information above). We use both “session cookies”, which disappear from your computer when you exit our App, and “persistent cookies”, which remain on your device even when our App is not in use. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising both on our App and on third-party sites.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Website who disable cookies will be able to browse certain areas of the Website, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. Clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website and/or App to track the activities of visitors, help us manage content, and compile usage statistics. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Plug-ins and Social Media Widgets. The Grab Properties may include social media features and widgets, such as the Facebook Like button and the “Share this” button, as well as other interactive mini-programs that run on the Website and/or App and enable certain features to work (e.g., content sharing and comments). These features may collect your IP address and other usage information. These features are subject to their own privacy policies, not this one.
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies). To learn more or to opt-out of tailored advertising please visit the Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
Our Website and/or App may contain links to third-party websites or allow you to post content to (or transmit content to) third-party websites, including without limitation to perform commercial transactions. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites. You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioral advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see What Choices Do I Have Regarding Use of My Personal Information.
Security of My Personal Information
The security of your personal information is very important to us. We have implemented safeguards designed to protect the information we collect from unauthorized access, use, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or App
Please be aware no data security measures can guarantee 100% security. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or App.
Transferring My Personal Information
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
By submitting your personal information or engaging with the Grab Properties, you consent to this transfer, storage, or processing.
Retaining My Personal Information
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
Access To My Personal Information
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
If we require you to register with us, you may modify personal information that you have submitted by logging into your account and updating your profile information.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at firstname.lastname@example.org to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
– Information protected by solicitor-client privilege.
– Information that is part of a formal dispute resolution process.
– Information that is about another individual that would reveal their personal information or confidential commercial information.
– Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact us at email@example.com.
Copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Website and/or App for a period of time.
Withdrawing My Consent
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at firstname.lastname@example.org. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
What Choices Do I Have Regarding Use of My Personal Information?
To cease the collection of your information by the Website and/or App, you will need to delete the App from your mobile device or log off from the Website (as applicable). Deletion of the App or logging off from the Website will not cease our use of the information that has already been collected by the App or the Website pursuant to this Policy.
This App will send you push notices. You may turn off push notices for this App through the phone settings screen or the App’s settings.
With regard to text messages, after activation, reply with STOP or go into the App’s settings to opt-out. Reply HELP for help. Message & Data rates may apply. The number of text messages you receive may vary based on your account activity.
Children Under 13
Our Grab Properties are not designed for children under 13. No one under age 13 may provide any information to or on the Website or App. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or App, or on or through any of its features/register on the Website or App, make any purchases through the Website or App, use any of the interactive or public comment features of this Website or App, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we discover that a child under 13 has provided us with personal information without verification of parental consent, we will delete such information from our systems. If you believe we might have any information from or about a child under 13, please contact us using the contact information provided below.
Contact Information and Challenging Compliance
If you have questions about the privacy aspects of our Website and/or App or would like to make a complaint, please contact us at email@example.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Website and App. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Website and App.