California Privacy Policy (Privacy Notice)

Effective Date: March 1, 2021

What is the scope of this Privacy Notice?

The California Consumer Privacy Act of 2018 (CCPA) gives certain consumers that reside in California (“California Consumers”) the right to know what categories of Personal Information GRAB MARKETS LLC including our affiliated entities (referred to collectively as “GRAB MARKETS LLC,” “we,” “our,” or “us”), collects about them and how and for what purposes we use and share that information.

This California Privacy Policy (“Privacy Notice”) provides the information required under the CCPA and applies to both GRAB MARKETS LLCs online and offline activities relating to California Consumers’ Personal Information. This Privacy Notice supplements GRAB MARKETS LLCs Privacy Statement.

As used in this Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information includes, but is not limited to, the categories of Personal Information identified below if such information identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household.

What Personal Information may we collect, use and share about you and for what purposes?

If you are a California Consumer, the following table details what Personal Information we collect, use and share about you:

Categories of Personal Information Collected – We may collect these types of personal Information: Source(s) of Personal Information – Entities or individuals we may collect this information from: Representative Date Elements may include Purpose(s) for Collecting – How we could use this information: Categories of Third Parties – we may share or disclose this information to:
Contact Information You, Your authorized representatives, Third party data aggregators, Registration data Full name, nicknames or previous names; honorifics and titles; mailing address, email address, telephone number, mobile number, contact information, such as authorized users of your account To identify and communicate with you, send transactional messages, send marketing and promotional communications, personal out communications and provide customer service, process payments, market research, for our everyday business purposes Our affiliates, our service providers, third parties who deliver out communications, other third parties including government agencies as (as required by law)
Government issued identification numbers You, third parties such as consumer and credit reporting agencies Social security number, driver’s license number, passport number, other government issued identifiers as may be needed for compliance To identify you, maintain the integrity of our records, customer verification, security and risk management, market research, our everyday business purposes Our affiliates, our service providers, third parties including consumer reporting agencies, our lawyers, auditors, consultants, other third parties as required by law
Unique Identifiers When you interact with us using your New Image account number, third parties such as ad delivery companies who place cookies containing advertising New Image account number, system identifiers, device identifiers, advertising ID, online user ID To identify your device, for record-keeping, for metrics and analytics, track your use of services and website, for market research purposes, to send marketing and promotional communications, for our everyday business purposes Our affiliates, our service providers, third parties who assist with fraud prevention, detection and mitigation, our lawyers, auditors and consultants, other third parties as required by law
Relationship Information You, third parties that provide access to information you make publicly available Education information, professional information, preferences for being contacted To better understand you, design, develop, market, sell and improve services, send marketing and promotional communications, identify prospective customers, market research, for internal business purposes, for our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, our lawyers, auditors and consultants, other third parties required by law
Transaction and interaction Information You, third parties that process transactions for us Customer account information, marketing and add campaign data and history, customer service records, visitor logs To fulfill our business relationship with you, design and improve our services, market research, send marketing and promotional communications, for internal business purposes, risk management, for our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, third parties as needed to complete the transaction you initiated or agreed to, our lawyers, auditors and consultants, other third parties required by law
Inferred and Derived Information We may create inferred and derived data elements by analyzing our relationship and transactional information Propensities, attributes and/or scores generated by internal analytics and used for marketing and advertising Marketing and research, internal business, our every day business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, our lawyers, auditors and consultants, other third parties required by law
Online Technical Information You and from you computer or devices when you interact with our platforms, websites and applications; automatically via such technologies such as cookies, web beacons, when you visit our website or other website; third parties including computer security services and third party advertising network companies and social medial; we may also associate information with you using unique identifiers collected from your devices IPAddress, MAC address, SSIFs or other device identifiers, password, device characteristics, web server logs, application logs, browsing dat, viewing data, first party cookies, third party cookies, preference management including opt-in and opt-out management For system administration, information security, recordkeeping, market research, for our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, our lawyers, auditors and consultants, other third parties required by law
Financial Information You, payment processors and other financial institutions; consumer reporting agencies; third parties that provide security and fraud prevention services; we may infer financial information Bank account number, payment card information, credit reports, credit scores To fulfill our business relationship with you, recordkeeping, risk management, for our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, third parties as needed to complete the transaction you initiated or agreed to, our lawyers, auditors and consultants, other third parties required by law
Geolocation data We may collect this type of information automatically from your mobile device Precise location Provide information or services requested, information security, our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, third parties as needed to complete the transaction you initiated or agreed to, our lawyers, auditors and consultants, other third parties required by law
Children’s data We do not collect personal information directly from children under 16. N/A N/A Other third parties as required by law
Compliance Data You, third parties that help us conduct internal investigations; third parties such as consumer reporting agencies and data aggregators who conduct background screening for is Customer screening records, records relating to complaints and internal investigations, including compliance hotline reports, legal requests, records of privacy and security incidents Comply with applicable law, internal business purposes, and for our everyday business purposes Our affiliates, our service providers, other third parties with whom we have a joint marketing arrangement, third parties as needed to complete the transaction you initiated or agreed to, our lawyers, auditors and consultants, other third parties required by law
Everyday Business Purposes encompasses the Business Purposes (as defined in the CCPA) and the following related purposes for which personal information may be used:

  • To provide the information, product or service requested by the individual or as reasonably expected given the context in which with the personal information was collected (such customer credentialing, providing customer service, personalization and preference management, providing product updates, bug fixes or recalls, and dispute resolution)
  • For identity and credential management, including identity verification and authentication, system and technology administration
  • To protect the security and integrity of systems, networks, applications and data, including detecting, analyzing and resolving security threats, and collaborating with cybersecurity centers, consortia and law enforcement about imminent threats
  • For fraud detection and prevention
  • For legal and regulatory compliance, including all uses and disclosures of personal information that are required by law or for reasonably needed for compliance with company policies and procedures, such as anti-money laundering programs, security and incident response programs, intellectual property protection programs, and corporate ethics and compliance hotlines, as well as for compliance with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summons.
  • To exercise or defend the legal rights of GRAB MARKETS LLC and its employees, affiliates, customers, contractors, and agents.
  • To comply with applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws.
  • For corporate audit, analysis and reporting,
  • To enforce our contracts and to protect against injury, theft, legal liability, fraud or abuse, to protect people or property, including physical security programs
  • To de-identify the data or create aggregated datasets, such as for consolidating reporting, research or analytics,
  • To make back-up copies for business continuity and disaster recovery purposes, and
  • For corporate governance, including mergers, acquisitions and divestitures.

Targeted Advertising Disclosure – When You Consent to the Cookie Consent

We use third party advertising companies to place our ads on other websites. One way we do so is by allowing network advertising companies and social media (“Network Advertisers”) with whom we work to place their own cookies on the browser of an individual who visits one or more of our sites and who clicks “accept” on the cookie consent banner on the site. This enables these Network Advertisers to place a cookie on your computer and to receive information (including for example your IP Address, internet tracking data, and advertising IDs) from that cookie that may include information about your visits to this and other websites. This data received by Network Advertisers allows them to measure advertising effectiveness and to provide advertisements on other websites about our goods and services that are tailored to you and that may be of interest to you on these other websites. These Network Advertisers may in turn disclose your cookie data to other network advertisers to allow these advertisers to display ads to you as well. Under CCPA these additional disclosures may be considered a sale of personal information

To revoke your consent or opt-out after you have consented to the cookie consent banner, or to manage your cookie preferences, you can delete the cookies on your browser or use the cookie settings on your browser. All browsers are different, so visit the “Help” section of your browser to learn how to delete the cookies we set in your browser, including the cookie consent, and about cookie preferences and other privacy settings that may be available.

Does GRAB MARKETS LLC “Sell” Your Personal Information?

GRAB MARKETS LLC does not sell Personal Information of California Consumers and will not sell this information unless we modify this Privacy Notice and take the additional steps required under the CCPA.

What are your rights?

If you are a California Consumer you have certain rights with respect to GRAB MARKETS LLCs use and disclosure of your Personal Information:

  • Right of Access | Right to Notice.
    You have the right to request from us:

    • the categories of Personal Information we have collected about you, the categories of sources from which the Personal Information is collected, the business purpose or commercial purpose for collecting the Personal Information, the categories of third parties with whom we share Personal Information, the categories of Personal Information we have shared and the reasons we shared it.
    • a copy of the specific pieces of Personal Information we have collected about you in the preceding 12 months.
  • Right to Deletion
    You have the right to request that GRAB MARKETS LLC delete the Personal Information we collect from you. However, in certain situations we are not required to delete your Personal Information, such as when the information is necessary in order to complete the transaction for which the Personal Information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.
  • Right Not to Be Subject to Discrimination
Should you exercise any of your privacy rights as a California Consumer, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. However, in some circumstances, for example where you have requested or consented to our services that use your Personal Information to provide the service, we may not be able to provide a service if you choose to delete your Personal Information.

To exercise any of these rights, or to designate an agent or authorized representative to act on your behalf, you can contact us through our designated CCPA processes by email us at support@grabmarkets.com or by going to our CCPA Data Subject Rights Management System to submit an electronic form. When you submit a Data Subject Rights request through one of these designated methods, we will use the information you submit and the information we have in our systems (or through the systems of our Service Provider if we use a Service Provider) to try to verify your identity and to match the personal information we have collected about you, if any, to your identity. If we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we cannot validate your identity, we will attempt to contact you to inform you of this issue.

How do you contact us if you have any questions or concerns?

If you have any questions regarding this Notice, you can contact GRAB MARKETS LLCs US Privacy Office at support@grabmarkets.com. Please submit all data subject rights requests through our designated methods either by going to our CCPA Data Subject Rights Management System or by emailing us at support@grabmarkets.com.

This Privacy Notice was last updated March 1, 2021.

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