Privacy Policy

Last Revised: June 1st, 2019

INTRODUCTION

HanQover.com. (“HanQover”) respects your (“Your”) privacy and is committed to protecting it through HanQover’s compliance with this privacy policy (the “Privacy Policy”).  This means HanQover does not transfer, distribute, disclose, rent or sell any of Your personal information to third parties except as provided for in this Privacy Policy or as specifically consented by You.

HanQover has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws

By using (the word “use” in this Privacy Policy will mean “access or use”) HanQover’s Services, including HanQover’s Services (currently located at hanqover.com ) and App, You expressly consent to HanQover’s collection, use and disclosure of Your personal information in accordance with this Privacy Policy.

This Privacy Policy is incorporated into and subject to HanQover’s Terms of Service. Undefined capitalized terms used in this Privacy Policy have the meanings given to them in HanQover’s Terms of Service.

SCOPE

This Privacy Policy applies to all Personal Information collected, used or disclosed by HanQover from users of HanQover’s Services (“Users”), including You.  “Personal Information” is any information in any form that identifies or can identify an individual and includes any information provided to HanQover.

This Privacy Policy also applies to information that is about You, but individually does not identify You, as described below.

ACCOUNTABILITY

HanQover is responsible for the Personal Information under its possession and control. HanQover has designated a Privacy Officer to be responsible for its compliance with this Privacy Policy and privacy legislation.

INFORMATION HANQOVER COLLECTS

Personal Information

a. Personal Information that HanQover collects includes, but is not limited to:

Registered User Account profile information, including name, e-mail address, address, date of birth, usernames, passwords, phone numbers, and mailing address;

Billing and payment information, including credit card information and bank account details;

Shipping and return information, including mailing address;

Device information, including the type of mobile device to which You have downloaded HanQover’s App;

Geo-location information;

Any other Personal Information that You may provide when You set-up a Registered User Account with HanQover, use the Services, or when you contact HanQover with questions and/or inquiries;

Technical support records;

Service requests and inquiries; and

Any information that HanQover collects from You that is intended to improve and personalize HanQover’s Services.

b. Non-Personal Information

HanQover collects non-Personal Information (“NPI”) about Users when they interact with the Services. For instance, NPI may include, but is not limited to, browser name, type of computer or device, and technical information about a User’s means of connecting to the Services, such as operating system, Internet service provider utilized, and mobile network information.  See the section below entitled “How does HanQover collect, use and share NPI?  How does HanQover use cookies?” for more information.

Please note that Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to You or any of other Users.  Such information by itself or together cannot be tracked to a specific individual’s Personal Information.

HOW DOES HANQOVER USE PERSONAL INFORMATION?

HanQover collects Personal Information for the following purposes:

to provide Services to You and other Users;

to facilitate transactions between You and other Users via the Services;

to create and administer Your Registered User Account, including to authenticate You on log-in;

to verify Registered Users;

to establish and maintain responsible commercial relations and to communicate with You in order to provide the Services. This includes, but is not limited to, communications relating to advertising, promotion, billing and payment, and Registered User Account verification;

permit PayPal payment processor, to provide payment processing services;

to respond to any correspondence You may direct to HanQover;

to understand HanQover’s Users’ needs and preferences;

to enforce HanQover’s Terms of Service;

to provide You with Service or administrative messages;

to meet legal and regulatory requirements;

to prevent, detect and mitigate illegal, fraudulent, or counterfeit activities;

to improve the Services; and

for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.

In addition, we may use Personal Information, on an aggregated de-identified basis, for research purposes to improve the Services.  This aggregated de-identified information does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy.

HOW DOES HANQOVER COLLECT, USE AND SHARE NPI?  HOW DOES HANQOVER USE COOKIES?

HanQover uses NPI in an ongoing effort to better understand and serve the Users of HanQover’s Services, to provide the Services and to improve the content and functionality of the Services. 

For instance, HanQover uses NPI to provide relevant, targeted advertising to Users of the Services, to monitor traffic, and to collect statistical data.

HanQover also conducts research on HanQover’s User demographics and behaviour based on Personal Information the NPI that HanQover has collected. This research will be compiled and analyzed on an aggregated basis and this aggregate does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy.

No NPI by itself, or together with aggregated Personal Information (which, as explained below, is treated as NPI under this Privacy Policy), can be tracked to a specific individual’s Personal Information.

The NPI collected is used to monitor traffic, provide the Services, and conduct internal research on HanQover’s Users’ to better understand and serve them, including Users’ size, usage patterns, demographics, interests and behaviours.

The Services may automatically receive and store certain types of NPI about Users’ use of the Services and their devices, including IP address, browser type, web pages viewed, date and time, device unique identifier, mobile network information, mobile stored information and files, and device phone number, as well as how users interact with HanQover.  In addition, HanQover uses different types of technology to collect this information, such as log files, embedded scripts, cookies, web beacons, and pixel tags.

The App also may access metadata and other information associated with other files stored on Your device.  This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

The NPI collected by HanQover will not be shared with third parties, except as expressly indicated in this Privacy Policy, or with HanQover’s Affiliates (as defined below), business partners and other third parties to describe HanQover’s Services and for other lawful purposes.

COOKIES

HanQover uses cookies to enhance Users’ experiences.  Users’ web browsers place cookies on their computers for record-keeping purposes and sometimes to track information about them.   Cookies help HanQover accurately understand how many consumers are visiting HanQover’s Website, how often Users visit the Website, what Content Users are most interested in, and how they prefer to interact with Content on the Website.  For example, a cookie will allow HanQover to remember certain things like Your Internet Protocol (IP) address (IP addresses are strings of numbers that identify senders and receivers of information sent across the Internet), Your login information, the time and duration of Your visits, how You navigated through HanQover’s content and where You exited the Website. To save You the time of re-entering Your login information every time You come back to HanQover’s Website, HanQover may link information contained in a cookie to Your email address.  HanQover does not use cookies to retrieve information from Your computer that HanQover did not originally send in a cookie.

HanQover uses Google Analytics which uses cookies to track NPI about traffic and visitors to the HanQover Services in the aggregate to compile statistical reports about the activity on the Services as well as to benchmark the Services to other third parties who also use Google Analytics.  This information is used by HanQover to improve the Services and their functionality. This data may be used to show You advertising on any Google or Google affiliated Services.

You may disable cookies using Your browser’s settings. Please consult Your browser’s help function for information on how to disable cookies.  Note that if You disable cookies, certain features of HanQover’s Services may not function to their fullest potential.

CONSENT

HanQover respects Your privacy and, unless otherwise required by law, HanQover will not collect, use or disclose Your Personal Information without Your prior consent. Your consent may be expressed or implied. You may expressly give Your consent in writing, verbally or through any electronic means.  In certain circumstances, Your consent may be implied by Your actions.  For example, providing HanQover Personal Information to register for HanQover’s Services is implied consent to use such information to provide You the associated Services.

Where appropriate, HanQover will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when HanQover wants to use information for a purpose other than those identified above).  In obtaining consent, HanQover will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by HanQover may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, HanQover shall take into account the sensitivity of the Personal Information and the reasonable expectations of HanQover’s Users.  HanQover will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to HanQover in writing. 

Important Information About Platform Permissions

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without Your consent.  And these platforms have different permission systems for obtaining Your consent. The iOS platform will alert You the first time the App wants permission to access certain types of data and will let You consent (or not consent) to that request.  Android devices will notify You of the permissions that the App seeks before you first use the App, and Your use of the App constitutes your consent. >

LIMITING USE, DISCLOSURE AND RETENTION

As noted above, HanQover does not disclose Your Personal Information to third parties, except as provided for in this Privacy Policy.

When You Lend or Borrow an item via the Services, the Lender or Borrower (as applicable) may receive Your Personal Information for item delivery and return purposes.  Lenders and Borrowers are strictly prohibited from using Your information for anything other than such purposes.

Your Personal Information may be transferred to third party suppliers, contractors and agents (“Affiliates”) who are contracted by HanQover to assist it in providing and developing products, services and/or the Services.  Such Affiliates will only use Your Personal Information for the purposes identified in this Privacy Policy.

We use PayPal for payment processing.  PayPal’s privacy policy is available at paypal.com/my/webapps/mpp/ua/privacy-full.

We also various third party providers for identification verification, such as:

Twilio, for phone number and e-mail verification. Twilio’s privacy policy is available at https://www.twilio.com/legal/privacy; and

Onfido, for driver’s license verification. Onfido’s privacy policy is available at https://onfido.com/privacy/.

In the event Your Personal Information is disclosed to a third party pursuant to a business transaction, HanQover will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

Subject to the foregoing, only HanQover’s and HanQover’s Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about HanQover’s Users.   All such employees will be required as a condition of employment to contractually respect the confidentiality of HanQover’s Users’ Personal Information.

HanQover will retain Personal Information for only as long as required to fulfil the identified purposes or as required by law. Personal Information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by HanQover.

HanQover will disclose Personal Information without Your knowledge or consent if HanQover receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If HanQover receives a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, HanQover’s policy is to provide the requested information.

LINKS TO OTHER SERVICES

You may be able to access third-party websites and services through links available on HanQover’s Services.

Any links are provided for Your convenience. HanQover does not have any control over those third-party websites or services and HanQover does not provide any guarantee that the privacy practices of the hosts of those websites or services meet HanQover’s standards.  Your use of such third-party websites or services is at Your own risk and will be governed by the privacy policies of those websites or services and not by this Privacy Policy.  Do not transmit Personal Information using those websites or services without reading the privacy policies governing those websites and services.

NOTE that You may choose to log-in to or register for HanQover’s Services through social media online services (e.g., Facebook).  When You do so, Personal Information from Your social media service account may be shared with HanQover. The information HanQover may receive varies by such services and is controlled by that service.  By associating an account managed by a third party with Your HanQover account and authorizing HanQover to have access to this information, and You agree that HanQover may collect, store, and use this information in accordance with this Privacy Policy. HanQover is not responsible for how those third parties use and share Your Personal Information. Please refer to those third parties’ privacy policies to understand how they use and share Your Personal Information.

You may create links between HanQover’s Services and social media online services.  If You do so, HanQover may be able to publish updates about HanQover’s Services to Your social media service accounts through the links that You establish. You may terminate those links at any time by modifying Your social network account.

You may change the way social media services and HanQover’s Services interact by modifying Your privacy settings in Your social media account. You can also log-out of Your social media account before using HanQover’s Services. For more information, please refer to Your social media services’ privacy policy, which governs Your use of these features.

STORAGE OUTSIDE OF Malaysia

Your Personal Information will not be used or stored by HanQover or HanQover’s service providers outside of Malaysia.  HanQover requires that HanQover’s service providers safeguard Your Personal Information.

CHILDREN AND MINORS

HanQover’s Services are not directed to children under the age of 18 years.  HanQover will not knowingly collect Personal Information about a child under the age of 18.  HanQover does not allow minors (persons who are under the age of majority in their place of residence) to create accounts, or lent or rent any items via the Services.   Without such minors having the express consent of their guardian or parents.

HOW CAN I ACCESS MY PERSONAL INFORMATION?

Upon request, HanQover will provide You information regarding the existence, use and disclosure of Your Personal Information and You will be given access to that information.  HanQover will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. You may challenge the accuracy and completeness of the information and have it amended as appropriate.

NOTE: In certain circumstances, HanQover may not be able to provide access to all of Your Personal Information that it holds.  Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. HanQover will provide the reasons for denying access upon request.

SAFEGUARDS

HanQover protects Your Personal Information by security safeguards appropriate to the sensitivity of the information.  HanQover will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

HanQover’s methods of protection include:

Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to HanQover’s place of business in general and to internal offices as well;

Organization measures, such as security clearances and limited access on a need to know basis; and

Technological measures, such as the use of passwords, firewalls and encryption.

INQUIRIES; CHALLENGING COMPLIANCE

An individual will be able to make inquiries and/or address a challenge concerning compliance with this Privacy Policy to HanQover’s Privacy Officer.

HanQover will maintain procedures for addressing and responding to all inquiries or complaints from HanQover’s Users about HanQover’s handling of Personal Information. HanQover shall investigate all complaints. All inquiries or complaints involving HanQover’s handling of Personal Information or compliance with this Privacy Policy or with PIPEDA shall be directed to HanQover’s Privacy Officer.

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt.  The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If HanQover finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact HanQover’s Privacy Office as follows:

E-mail: contact@hanqover.com

Attention to:

HanQover

Privacy Officer:  Ms. Celine Tan

Malaysia Headquarter / Johor Baharu

GENERAL

HanQover reserves the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on HanQover’s Services and will be effective as of the date of posting.