Privacy Policy
This Privacy Notice (“Privacy Notice”) describe how FOOM Holdings Limited, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “FOOM”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of FOOM’s mobile applications and websites (respectively “Apps” and “Websites”), as well as products, features and other services globally, operated by FOOM (collectively, “Services”).
This Notice applies to our consumers, agents, vendors, suppliers, partners (such as driver, delivery and merchant partners), contractors and service providers (collectively “you”, “your” or “yours”).
“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, birth details, marital status, religion.
We typically collect, use, disclose or otherwise process your Personal Data in accordance with this Privacy Notice with your consent, or in compliance with applicable laws, such as where:
- it is required for us to comply with legal requirements;
- it is required for us to enter into or perform a contract with you; and/or
- for our legitimate interests or the legitimate interests of any other persons, including but not limited to for the purposes set forth in this Privacy Notice.
I. COLLECTION OF PERSONAL DATA
We collect Personal Data about you in the ways listed below. We may also combine Personal Data collected via these various channels:
You provide your Personal Data to us
We collect your Personal Data when you provide it to us. For example, when you:
- complete a user profile or registration forms (such as your name, contact information and other identification information where needed);
- provide information to assess your eligibility to provide services as a FOOM delivery partner;
- sign-up and identity verification for tasks such as taking a selfie, capturing an image of your ID, and scanning QR codes for completing order purposes.
- fill up demographic information in surveys (such as your age, gender, and other information)
When our services are used
Personal Data may be collected through the normal operation or use of our Apps, Websites and Services. Some examples are:
- your location information;
- feedback, ratings and compliments;
- transaction information (such as payment method);
- information about how you interacted with our Apps, Website or Services (such as features used and content viewed);
- device information (such as hardware model and serial number, IP addresses), file and app names and versions, GPS location, IMEI number, and advertising identifiers or any information that may indicate device or app modification);
- personal data you enter in messages when you use our in-app communication features; and
- personal data that may be captured through your interaction with us.
From other sources
We may collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources. Such sources include:
- referral programmes;
- our business partners, such as payment providers and delivery partners;
- financial providers;
- publicly available or governmental sources of data;
- when our users add you as a recipient or beneficiary of any use of our Services;
- when you use our in-app chat; and
- marketing services providers or partners.
Sensitive Personal Data
Some of the Personal Data that we collect may be sensitive in nature. This may include Personal Data pertaining to your national ID information, religious beliefs, and biometric data, as applicable. We collect sensitive Personal Data only with your consent and/or in strict compliance with applicable laws. In the event that you are required to furnish any documentation or information to us for any Purpose which may contain such sensitive Personal Data (which is not required that Purpose), you agree to redact such sensitive Personal Data before providing such documentation or information to us. Additionally, please be assured that all passwords used for our website and app are encrypted.
II. USE OF PERSONAL DATA
FOOM may use your Personal Data for the following purposes set out in the list below. (“Purposes”). Additionally, if you use FOOM in various capacities (for example, if you use multiple FOOM Services, or if you are both a partner and a consumer), we may link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below:
Providing services and features
Your Personal Data will be used to provide, personalise, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:
- engage you to provide you with Services across our various business verticals;
- create, administer and update your account;
- process, manage or verify your eligibility for or application of products, Services, promotions, rewards and subscriptions with FOOM;
- conduct due diligence checks and risk assessments / analysis;
- verify your identity and age (where necessary);
- validate your order and process payments;
- track the progress of your order
- allow you to participate in the loyalty programmes or marketing activities organized by our merchant-partners and/or in collaboration with FOOM;
- personalise your App experience (such as to recommend products and services relevant to you, identify your preferences or otherwise personalise your experience with FOOM);
- make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;
- perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
- protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
- invite you to participate in our surveys and studies;
- enable our partners to manage and allocate fleet resources; and
- fulfil the services to you as a data processor, where you have provided consent to the data controller (i.e. the organisation you had purchased goods or services from, and for whom FOOM is providing services on behalf of) for such services to be rendered.
Safety and security
We use your data to ensure the safety and security of our Services and all users. This includes:
- screening delivery partners before enabling their use of our Services;
- verifying your identity when you log in to FOOM;
- using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
- monitoring compliance with our terms and conditions and policies.
User support
We use Personal Data to resolve user support issues. For example, we may:
- investigate and address concerns;
- monitor and improve our user support responses;
- respond to questions, comments and feedback; and
- inform you about steps taken to resolve user support issues.
Research and development and security
We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services, and facilitate development of insurance and finance solutions.
Legal purposes
We may use the Personal Data we collect for legal purposes, such as to investigate and resolve claims or disputes, detect/prevent/prosecute crime, or as allowed or required by applicable law.
We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.
For example, we may use your Personal Data to:
- comply with court orders or other legal, governmental or regulatory requirements;
- enforce our Terms of Service or other agreements; and
- protect our rights or property in the event of a claim or dispute
- preventing the use of our product by underage individuals (18+).
Marketing and promotions
We may use your Personal Data to send you marketing communications relating to customised products or services (that may be of interest or relevance based on your profile), or FOOM’s partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:
- send you special offers that may be of interest or relevance to you across all of FOOM’s service offerings;
- send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
- notify, invite and manage your participation in our events or activities.
We may communicate such marketing to you by various means, where applicable (including by SMS, Whatsapp, push notification, and by email).
If you wish to unsubscribe to the receiving of such marketing communications, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings. Please note that while you may opt out of marketing or promotion communications, FOOM may still send you account and / or service-related messages (such as two-factor authentication, information on your transactions, rewards, etc.).
User Published Content
If you publish content (such as a review or comment) on FOOM’s platform, it will be shown publicly along with your personal data (such as profile name, uploaded photo(s)), and other information you choose to include in your content.
III. DISCLOSURE OF PERSONAL DATA
We need to share Personal Data with various parties for the Purposes. These parties include:
Other users
For example:
- if you are a customer, we may share your username, pick-up and drop-off locations with our delivery partner fulfilling your service request;
- if you are participating in loyalty programmes or marketing activities organized by our merchant-partners, we may share your Personal Data with them, including your name and contact details;
- if you use our in-app chat service, we may share your FOOM-registered username with the other parties to your chat.
- if you use our payment services, we may share your Personal Data with another individual should you authorise and enable connection of his or her third party service payment method to our payment service for the purposes of enabling your payment on FOOM.
With third parties
With third parties related to your use of FOOM Services
For example:
- if you are a delivery partner, we may share your Personal Data with your customer including your name and photo; your vehicle ;model, number plate, location;
- if you are a delivery partner, we may share your Personal Data with your selected merchant-partner and user, including your name and photo; your vehicle make, model, location and average rating;
With administrators of FOOM accounts that you may use
For example:
- your employer may receive transaction data (tagged as business expenses) when you use your employer’s FOOM for Business account.
- the administrator of any community group to which you link your FOOM account may receive transaction data when you carry out a transaction.
With subsidiaries and affiliates
We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates. The companies in the FOOM group share resources, such as infrastructure and technology with each other to provide you with a consistent, relevant and secure experience when you use our products or Services, and for the Purposes set out in this Privacy Notice.
For example, we do this to make your experience more seamless, such as by automatically completing your registration information from your use of one FOOM Product or Service when you sign up for a new FOOM Product or Service.
With FOOM’s service providers and business partners
We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:
- payment processors and facilitators;
- conducting a background check to ensure absence of any criminal records;
- cloud storage providers;
- document storage and management providers;
- advertising and marketing partners and platform providers;
- data analytics providers;
- research partners, including those performing surveys or research projects in partnership with FOOM or on FOOM’s behalf;
- educational and training institute partners;
- fleet and merchant partners;
- third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
- service providers who perform identity verification services; and
- vehicle solutions partners, vendors or third-party vehicle suppliers.
For example:
- If you requested a service through a FOOM partner or used a promotion provided by a FOOM partner, FOOM may share your Personal Data with that FOOM partner.
With our legal advisors and governmental authorities
We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:
- where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or
- where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).
Business transfers
We may share your Personal Data with other parties, in connection with any acquisitions, sales, mergers, joint ventures, consolidation, restructuring, financing or any other type of business transactions. Your Personal Data will however remain subject to our obligations made in any
pre-existing Privacy Notice that you have agreed to.
IV. RETENTION OF PERSONAL DATA
We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Notice unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Notice, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.
V. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Your Personal Data may be transferred from the country, state and city (“Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”).
When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.
Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.
VI. COOKIES, RELATED TECHNOLOGIES AND ADVERTISING ON THIRD PARTY PLATFORMS
Cookies
FOOM, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (such as software development kits (SDKs), which have similar functions to cookies and which may be installed in the FOOM App to allow partners to collect certain information about your interaction with the FOOM App) (collectively, “Cookies”) in connection with your use of the Websites and Apps, which may be persistent or stored only during an individual session on your browsers or devices.
Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may be used for various purposes such as to:
- provide the essential, basic functions of the use of our Websites, Services or Apps;
- authenticate you, or remember your user preferences and settings;
- delivering and measuring the effectiveness of advertising campaigns, such as by measuring number of views or clickthroughs;
- analyse site traffic and trends;
- serve you relevant advertisements across other apps and websites owned by other companies (whether by us or by other advertisers); and
- enhance user interface and experience by generally understanding the online behaviors and interests of users who interact with our Website, Services or Apps.
FOOM may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes FOOM does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.
Disabling the collection of cookies on our websites
You have the right to choose to disable, block or deactivate cookies. Please note that however refusal or removal of some cookies could affect the availability, functionality or use of our Website, Services or Apps.
You may adjust your internet browser settings to disable, block or deactivate cookies, delete your browsing history or clear the cache from your internet browser. The settings may be contained within the “History”, “Preferences”, “Settings” or “Privacy” section of your internet browsers, or you may otherwise consult the help section of your internet browser for more information. You may also adjust your cookie settings here:
Disabling the display of Targeted Ads on other platforms
We may facilitate the display of targeted advertising on other platforms, such as on other online platforms that you may be a user of.
You may be able to limit our use of your Personal Data to display targeted advertisements on behalf of our advertisers, by adjusting your preference through our Grab App. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Apple’s IDFA or Google’s GAID) and the ability to track you across apps and websites owned by other companies by adjusting the settings available on your mobile devices. Through adjusting the settings on your device, you can typically reset, delete, limit and/or otherwise restrict the use of such mobile identifiers.
Although we will not use your Personal Data to show you such targeted advertisements on other platforms, you may still see generic ads that appear relevant to you. This may be because we have engaged third party advertisers / platforms to display ads to users of specific attributes or demographic makeups who may find them relevant. You may be able to limit seeing these advertisements through managing your preferences on these platforms.
VII. PROTECTION OF PERSONAL DATA
We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.
Nevertheless, please understand that 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 Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.
VIII. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
In accordance with applicable laws and regulations, you may be entitled to:
- inquire about the processing of your Personal Data and be provided with a copy of it;
- in some cases, request the correction and/or deletion of your Personal Data;
- in some cases, request the restriction of or object to the processing of your Personal Data;
- withdraw your consent to the processing of your Personal Data within our possession or control (and where we are processing your Personal Data based on your consent);
- request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and
- complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment as a result of unlawful processing of your Personal Data.
Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, choosing not to share your Personal Data with us, withdrawing your consent to our use of it or to your agreement with our Privacy Notice could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of App or the Services.
After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.
We will screen and verify all requests beforehand. In order to verify your authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.
IX. AMENDMENTS AND UPDATES
FOOM may modify, update or amend the terms in this Privacy Notice at any time. Such amendments shall be notified to you through the Application and/ or other appropriate means at least five (5) business days before the effective date. The updated version will be posted on the website https://www.foom.id. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Apps, Websites or Services, purchase products from FOOM or continuing to communicate or engage with FOOM following the modifications, updates or amendments to this Notice, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.
X. HOW TO CONTACT US
If you have any queries about this Notice or would like to exercise your rights set out in this Notice , please direct your mail to our Customer Service :
Foom Lab Global, Sovereign Plaza Jl TB Simatupang Lt 19 Jaksel
081574309200