Introduction

This Privacy Notice describes how We, Hero Technology solutions and/or its affiliates (“Hero Super App ”) obtain, collect, store, control, use, process, analyses, correct, update, display, publish, transfer, disclose and protect Your personal data ("Processing of Personal Data"). This Privacy Notice applies to all Users of Our mobile applications (including the Hero Super App, Hero partner, Hero Captain), websites (including hero-jo.com and its derivative sites), features, services and products (collectively referred as the “Applications”), unless covered by a separate privacy notice.

Please read this Privacy Notice thoroughly to ensure that You understand Our data protection practices. We want to make this easier to understand, so We wrote a summary that highlights all the important points. All capitalized terms used in this Privacy Notice shall have the same meaning ascribed to them in the applicable Terms of Use between You and Hero Super App.

Acknowledgment and Consent

By agreeing to the Privacy Notice, You acknowledge that You have read and understood this Privacy Notice and agree to its terms. In particular, You agree and consent for Us to Processing Your Personal Data in accordance with this Privacy Notice.

You may withdraw Your consent to any or all Processing of Your Personal Data at any time by giving Us reasonable notice in writing using the contact details stated below. You may also withdraw Your consent for us to send certain communications through the "opt-out" facility, the "unsubscribe" option available in the messages We send, or using the options available on each communication medium We use to contact You. You must understand and acknowledge that after such withdrawal of consent, You may no longer be able to use the Application or services. A withdrawal of consent by You may result in Us being unable to provide services, deletion of Your account or termination of Your contractual relationship with Us, with all rights and obligations that arise remaining fully fulfilled. Upon receipt of Your notice to withdraw consent for any collection, use or disclosure of Your Personal Data, We will inform You of the likely consequences of such withdrawal so that You can decide if indeed You wish to withdraw consent.

Summary

Personal Data Collection

Our Privacy Notice outlines the collection of Personal Data, which refers to information identifying or capable of identifying an individual or device. This includes but is not limited to name, address, contact details, financial information, biometric data, and more, as dictated by Applicable Laws. The types of data collected depend on the circumstances and nature of the service requested.

We may collect, process, and store various kinds of Personal Data, categorized into different types such as Identity Data, Contact Data, Transaction Data, Financial Data, and more. Additionally, we may utilize aggregated data for statistical or demographic purposes, ensuring anonymity.

In case of incomplete or inadequate provision of Personal Data, we may be unable to fulfill our contractual obligations or provide requested services, as required by law or contract terms.

How We Collect Your Personal Data

Personal Data may be obtained directly from you, your mobile device, or third parties. Data collected directly includes information provided during registration, account creation, usage of our applications, and communication with our customer services. Data collected through application usage encompasses technical data and location data. Additionally, we may collect data from third parties such as agents, vendors, or partners.

We do not mandate or prohibit the use of in-vehicle recording devices, and any data collected through such devices is at the discretion of the Service Provider, with whom we have no control or liability.

Use of Personal Data

We utilize collected Personal Data for various purposes, including user identification, service provision, payment processing, communication, feedback handling, and marketing activities. The specific purposes depend on whether you are a User or a Service Provider.

Disclosure of Personal Data

We may disclose or share your Personal Data with affiliates, partners, government authorities, or third-party service providers for purposes such as service provision, regulatory compliance, legal proceedings, or business transactions. We ensure appropriate protection and confidentiality of your data in accordance with Applicable Laws.

International Transfers

Your Personal Data may be transferred to other countries where our services are accessible to ensure a seamless user experience. We comply with applicable laws and take measures to safeguard data privacy and security.

Protecting Your Personal Data

We employ reasonable efforts to safeguard the confidentiality and security of your Personal Data against unauthorized access, processing, or disclosure. However, we cannot guarantee absolute security due to inherent risks in data transmission over the internet.

Data Retention

Your Personal Data is retained only for necessary periods as required by law or business purposes. We delete or anonymize data when no longer necessary, and you are responsible for maintaining the security of your account details.

PERSONAL DATA THAT WE COLLECT

1.The Types of Personal Data We Collect About You

“Personal Data” means data that identifies or can be used to identify, contact, or locate the person or device to which the data relates. Personal Data includes, but is not limited to, name, address, date of birth, occupation, telephone number, email address, bank account and credit card details, gender, identification (including passport or national identity document) or other government-issued identification, vehicle data, photos, nationality, telephone numbers of Users and non-Users in Your mobile phone contact list, health data, financial related data, biometric data (including but not limited to fingerprint recognition and facial recognition), and other data including as Personal Data in accordance with Applicable Laws. In addition, other data, including personal profiles and/or unique identifiers, are associated or combined with Personal Data, then that data also constitutes Personal Data.

The types of Personal Data that We collect depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.

To the extent permitted by Applicable Laws, We may process collect, use, store and transfer different kinds of Personal Data, consist of general and specific/sensitive Personal Data, about You which We have grouped together as follows:

a. Identity Data includes name, username, identity card, taxpayer identification number, user ID, or other identifier, title, date of birth, gender, place of birth, occupation, nationality, photos and/or biometric data.

b. Contact Data includes billing address(es), delivery address(es), email address(es) and its label, phone numbers and phonebook.

c. Eligibility Data includes, in relation to Service Provider, the licenses, approvals and other authorizations permitting You to operate the vehicle and provide transportation or other services, and insurance policy details

d. Transaction Data includes purchases or orders made by You, Your interests, preferences, feedback and survey responses, in relation to Users, the type of service sought, details as to the pick-up and/or delivery, and the type of services that can be accepted at the time.

e. Financial Data includes details of bank accounts and payment cards such as the type of card or payment account used, the name of the issuer of the card or payment account, the name of the holder of the card or payment account, the identification number of the account or payment card, the verification code of the payment card or account, and the expiration date such payment card or account, as applicable, virtual account data, financial history (including but not limited to payment card or account transaction history, payment card or account details, CVV code and mapping and/or status and condition of the payment card or account) , and credit scoring data.

f. Payment Data includes details of payments or transfers made by Users on Our Application, including but not limited to data relating to usage, payments, recipient details (including their account details), payment methods used, payment amounts paid, billing details, and details invoice.

g. Technical Data includes details on Your usage of Our Applications such as identification generated by the Application (user id), in app messages, in app search history, internet protocol (IP) address, data as web pages previously or subsequently viewed, duration of every visit/session, the internet device identity (ID) or media access control address, mobile advertising ID and other device information including information regarding the manufacturer, model, and operating system of the device you use to access the Application and crash logs.

h. Device Data includes device data, including the type of device You are using to access the Application, including hardware model, operating system and version, software, IMEI number, file name and version, language preference, unique device identifier, advertising identifier, serial number, device movement information, and/or mobile network information.

i. Log data includes records on the server that receive data such as device IP address, date and time of access, Application features or pages viewed, Application work processes and other system activities, browser type, and/or third party sites or services that the User used before interacting with the Application.

j. Location Data includes Your real-time geo-location data.

We may create, use, license or disclose Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from Your Personal Data but would not be considered Personal Data as this data will not directly or indirectly reveal Your identity as We will ensure: (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and (ii) the data is then combined with similar data such that the original data forms a part of a larger data set.

2. If You provide incomplete Personal Data

Where We need to collect Personal Data by law, or under the terms of a contract We have with You, and You either choose not to provide that Personal Data or provide Us with incomplete Personal Data when requested, We may not be able to provide services and perform the contract We have or are trying to enter into with You .

3. How We Collect Your Personal Data

The Personal Data which We collect may be provided by You directly or by third parties (for example: when You register for or use the Applications, when You contact Our customer services, or You otherwise provide Personal Data to Us). We may collect data in various forms and for various purposes (including purposes permitted under Applicable Laws)

a. Data obtained from You or from Your mobile device directly

You may give Us Your Identity, Contact, Eligibility, Profile, Financial, and Payment Data, including in situations where requested by Us or where required by Applicable Laws, when interacting with Us directly or by corresponding with Us by post, phone, email or otherwise. This includes Personal Data You provide when You:

i. register and create an account using the Applications;

ii. use the Applications, including if You register as a Service Provider or use the services as a User;

iii. make payments using available methods including but not limited to credit card payments, virtual accounts, bank transfers, electronic money and/or electronic wallet (whether as payer or recipient);

iv. apply as a registered or verified account holder of an electronic money facility;

v. add a source of funds for payment in the Applications;

vi. use the chat features in the Applications; and

vii. give Us feedback or contact Us.

b. Data collected whenever You use the Applications

You may give Us Technical and Location Data whenever You use and/or visit the Applications. Whenever You access the Applications through Your Mobile Device, We will track and collect Your geo-location data in real-time. In some cases, You will be prompted or required to activate the Global Positioning System (GPS) on Your Mobile Device to enable Us to give You a better experience in using the Applications (for example, to give Your data as to how close a Service Provider is to You). You can always choose to disable the geo-location tracking data on Your Mobile Device temporarily. However, this can affect the functionalities available on the Applications.

If You use and/or when a payment or transfer is made through the electronic money and/or electronic wallet facility which is available on Our Application (whether as payer or recipient), We may collect certain Financial, Profile and Payment Data relating to such payments and transfers

In addition, whenever You use and/or visit the Applications, certain data may also be collected on an automated basis using cookies. Cookies are small application files stored on Your computer or mobile device. We use cookies to track user activity to enhance user interface and experience. Most Mobile Devices and internet browsers support the use of cookies; but You may adjust the settings on Your Mobile Device or internet browser to reject several types of certain cookies or certain specific cookies. Your Mobile Device and/or browser would also enable You to delete at any time whatever cookies have previously been stored. However, doing so may affect the functionalities available on the Applications.

We may also use features provided by third parties in order to improve our services and content, including assessing, customizing and presenting offers to each User based on interests or visit history. If the User does not want offers to be displayed based on these adjustments, then the User can set it via the browser.

c. Data collected from third parties

We may also collect Your Personal Data from third parties (including Our agents, vendors, suppliers, contractors, partners and any others who provide services to Us, who collect Your Personal Data and/or perform functions on Our behalf, or whom We collaborate with). In such condition, We will only collect Your Personal Data for or in connection with the purposes for which such third parties are engaged or the purposes of Our collaboration with such third parties (as the case may be). Specifically if You register for a payment card or account through the Applications and/or access, add and/or link a payment card or account to the Applications (as applicable in Your country), We may collect certain financial data and financial history of Yours (including but not limited to payment card or account transaction history, payment card or account details and mapping and/or payment card or account status and states) from the issuer of such payment credential or any other third parties.

When You are using the chat features in Our mobile Applications, You will provide Us with phone numbers stored on Your mobile phonebook to enable You in using Our chat features and for other purposes.

e. In-vehicle recording

We do not Mandate or endorse, nor prohibit, the installation or use of in-vehicle recording devices in any vehicles. Where such devices are installed and used in any vehicles, We do not collect any Personal Data from any in-vehicle recordings by such devices, and any collection of Personal Data from such in-vehicle recordings is not being done on Our behalf. The collection of Personal Data from such in-vehicle recordings is solely at the discretion of the Service Provider. We have no control over such collection of Personal Data by the Service Provider and any subsequent use or disclosure by the Service Provider of the Personal Data so collected. Where You are a Service Provider and choose to install and use such in-vehicle recording devices in Your vehicle, it is Your sole responsibility to notify the User of the same. Where You are a User and You have any objection to the use of in-vehicle recording devices within the Vehicle of any Service Provider, You must inform the Service Provider directly and it will be Your personal responsibility to do so.

THE USE OF PERSONAL DATA

4. How We Use Your Personal Data

We may use Personal Data collected for any of the following purposes as well as for such other purposes as are permitted by Applicable Laws (“Purposes”):

a. Where You are a User, We may use Your Personal Data

i. to identify and register you as a User and to create, verify, deactivate or manage your account on Our Application or other hero technology solutions llc applications;

ii. to facilitate or enable any verification as We may in Our discretion consider necessary before the Service Provider provides You with the services or before We register You as a User, including performing Know Your Customer (KYC) and credit scoring (if needed);

iii. to enable Us to provide services, both services that are already available, services that you request, and services that will be available in the future;

iv. to process and facilitate orders and payment transactions made by You, including where applicable, transactions made through any payment card, electronic money and/or electronic wallet, or account available over the Applications;

v. to notify You of any transaction or activities occurred within the Applications or other system linked to Our Applications;

vi. to facilitate account and/or wallet linking, if You initiate account and/or wallet linking feature between Your hero account or hero wallet and other hero super Applications and/or third party platform (as applicable);

vii. to communicate with You and to send You data in connection with the use of the Applications;

viii. to notify You of any updates to the Applications or changes to the services available;

ix. to process, follow up, resolve and respond to complaints, problems, questions and suggestions received from you;

x. to maintain, develop, test, enhance and personalize the Application to meet Your needs and preferences as a User;

xi. to monitor and analyse user activities, behavior, and demographic data including trends and usage of the various services available on the Application;

xii. to process and manage reward points;

xiii. to offer or provide services from our affiliates or partners; and

xiv. to send You direct or targeted marketing communications, advertisement, vouchers, surveys, and information on special offers or promotions as and when such events, promotions, features or launches occur.

b. Where You are a Service Provider, We may use Your Personal Data:

i. to identify You and register You as a Service Provider and create, manage or verify your account on Our Application or other hero super applications;

ii. to facilitate or enable any verification as We may in Our discretion consider necessary before We register You as a Service Provider, including for KYC and credit scoring (if needed);

iii. to enable You to provide services to Users;

iv. to process, facilitate, and complete payments due to You relating to any services You have provided;

v. to communicate with You and send You information in relation to the provision of Your services, including to relay User orders to You and to facilitate Your acceptance of such orders;

vi. to provide You with notification and updates on the Applications or changes to the manner in which services are to be provided;

vii. to provide You with a report in relation to the services that You have provided;

viii. to process and respond to feedback from Users on the services which You have provided;

ix. to maintain, develop, test, enhance and personalize the Applications to meet Your needs and preferences as a Service Provider;

x. to monitor and analyse User activities, behavior, and demographic data including trends and Service Provider responsiveness for the various services available on the Applications;

xi. to process and manage Your reward points (as applicable);

xii. to offer or provide services from Our affiliates or partners (as applicable);

xiii. to send You direct or targeted marketing communications, advertisement, promos, surveys, and information on special offers or promotions as and when such events, promotions, features or launches occur.