Web Privacy Policy
This Privacy Policy (“Policy”) is considered an integral part of our Terms and Conditions, and applies to all websites owned and operated by FSS Systems Inc. (hereafter referred to as “Hungr-E”, “We”, or “Us”), including fss-systems.com, hungr-e.com and any other websites, applications, pages, features, or content we own or operate, and to your use of the Hungr-E’s platform and any related Services. Our Privacy Policy is designed to help you better understand how we collect, use, store, process, and transfer your Personal Data when using our Services. “You” as defined in this Privacy Policy may be a Buyer or any other person with Access to Hungr-E’s Platform or Service as defined in the Terms of Service of Hungr-E’s Platform.
Please carefully review this Privacy Policy and our Terms and Conditions. By using our Services, you acknowledge all of the policies and procedures described in the foregoing documents. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy or our Terms and Conditions you should immediately discontinue the use of our Services.
Key Definitions
This Policy applies to Personal Information We collect from you or about you through the following sources:
1. Registration Information. When you create a Hungr-E account by signing up through its website, via a QR Code or via a referral code, and when you contact Customer Care, we collect Personal Information, such as your name, address, date of birth and contact information (e.g. email address and phone number).
2. Third Party Services. If you use third party social networks such as Facebook and Google to sign up with Hungr-E, we may collect, subject to your consent, personal information and other information such as your profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers depending on your privacy settings on the third-party site.
3. Email, text and other electronic messages. This includes our interactions through email, text, and other electronic messages.
4. Information that We Generate. In the course of our interactions with you, we may create Personal Information about you such as, but not limited to, your historical transactions, order frequency, Peso value spent, etc.
5. Customer Service. When you contact Customer Care or correspond with us about our Service, we collect information to: track and respond to your inquiry; investigate any breach of our Terms and Conditions, Privacy Policy or applicable laws or regulations; and analyze and improve our Services.
6. Cookies, Web Beacon, etc.
7. Sensitive Personal Data. We do not seek to collect or process your sensitive personal information in the ordinary course of our business. When it becomes necessary to process your sensitive personal sensitive personal information, we will first obtain your prior express consent before proceeding to collecting or processing your sensitive personal information.
8. Other Types of Information. We continuously work to enhance our Services with new products, applications and features that may result in the collection of new and different types of information. We will update our Privacy Policy and/or obtain your prior consent to new processing, as needed.
1. To fulfill your orders. We use your Personal Information to process and ship your orders, inform you about the status of your orders, correct addresses and conduct identity verification.
2. To provide customer support. When you contact Customer Care, we may use or request Personal Information, including Sensitive Information, as necessary to answer your questions, resolve disputes, and/or investigate and troubleshoot problems or complaints. In some instances, we may be required to process one user’s Personal Information to resolve another user’s dispute or request. For example, if a user reports behavior that violates our Terms and Conditions, we will separately process both users’ Personal Information and respond separately to each individual as appropriate. We will not share your Personal Information with another user without your consent.
3. To provide you with marketing communications. By creating a Hungr-E account, you are agreeing that we may send you product and promotional emails or notifications about our Services, and offers on new products, services, promotions or contests. You can unsubscribe from receiving these marketing communications at any time. To unsubscribe, click the email footer “unsubscribe” link. You may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.
4. To conduct marketing research and actual marketing activities. We use the information you provide described above to also conduct marketing research and conduct marketing activities for the promotion, publication, and create awareness of the Company and its services.
1. Partner Merchants. We share your Personal Information to our Partner Merchants to process your orders and for marketing activities. These Personal Information include your name and other login credentials.
2. Service Providers. We share your Personal Information to Service Providers which are external companies that We use to help Us run our business in the following areas:
a. Delivery. We share your Personal Information such as your name, address, and contact information with our delivery partner to fulfill your orders.
b. Payment Processing. Our payment processor processes certain Personal Information such as your contact information to receive payment of your orders.
c. Cloud Storage, IT, and Security. Our cloud storage providers provide secure storage for information in Hungr-E databases, ensure that our infrastructure can support continued use of our Services by Hungr-E customers, and protect data in the event of a natural disaster or other disruption to the Service. Our IT and security providers assist with intrusion detection and prevention measures to stop any potential attacks against our networks.
Service Providers and their selected staff, are only allowed to access and use your Personal Information only for specific tasks that they have been requested to carry out based on our instructions. They are required to keep your Personal Information confidential and secured.
3. As required by law. Under certain circumstances your Personal Information may be subject to processing pursuant to laws, regulations, judicial or other government subpoenas, warrants, or orders. For example, we may be required to disclose Personal Information in coordination with regulatory authorities in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Hunger-E will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that Hungr-E may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the Hungr-E Terms and Conditions and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Hungr-E, its employees, its users, its clients, and the public.
4. Business transaction. In the event that Hungr-E goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets your Personal Information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Policy.
Access to your account. We provide access to your Hungr-E data within your Hungr-E account. You can access and download data processed by Hungr-E within your Account Settings and within applicable Reports, Tools, and features. If you lose access to your account or account email address, please contact Customer Care for assistance. If you lose access to your account, in certain circumstances, we may require that you submit additional information sufficient to verify your identity before providing access or otherwise releasing information to you. If you choose not to submit the required documentation, or the information provided is not sufficient for the purposes sought, Hunger-E will not be able to sufficiently verify your identity in order to complete your request. You may access, correct or update most of your Registration Information on your own within your Account Settings. You may be able to correct Self-Reported Information entered into a survey, form, or feature within your account. Please note that you may not be able to delete User Content that has been shared with others through the Service and that you may not be able to delete information that has been shared with third parties.
Marketing communications. As noted earlier, you may be asked to opt-in to receive product and promotional emails or notifications when creating your Hungr-E account. Otherwise, you may view or update your email notification preferences by contacting our Customer care support . You can also click the “unsubscribe” button at the bottom of promotional email communications.
Sharing outside of Hungr-E Services. You may decide to share your Personal Information with friends and/or family members, and/or other individuals outside of our Services, including through third party services such as social networks and third party apps that connect to our website and mobile apps through our application programming interface (“API”). These third parties may use your Personal Information differently than we do under this Privacy Policy. Please make such choices carefully and review the Privacy Policies of all other third parties involved in the transaction. In general, it can be difficult to contain or retrieve Personal Information once it has been shared or disclosed. Hunger-E will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information with others.
Account deletion. If you no longer wish to participate in our Services, or no longer wish to have your Personal Information be processed, you may delete your Hungr-E account and Personal Information within your Account Settings.
Information previously included in a Market Research. As stated in any agreement or consent you have agreed to including our Terms and Conditions, and this Privacy Policy, Personal Information and/or Self-Reported Information that you have previously provided and for which you have given consent to use in a market research cannot be removed from completed studies that use that information, and your de-identified data may still be, used in future market research.
Legal Retention Requirements. Hunger-E will also retain limited information related to your account and data deletion request, including but not limited to, your email address, account deletion request identifier, and record of legal agreements for a limited period of time as required by contractual obligations, and/or as necessary for the establishment, exercise or defense of legal claims and for audit and compliance purposes.
Hungr-E takes serious care of the trust you place in us. Hunger-E, through our Service Provider, implements physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your Personal Information, such as:
1. Database Security. Customer data is stored in a dedicated database. Data access control rules implement complete isolation between customer databases and no access is possible from one database to another,
2. Password Security. Customer passwords are protected with industry standard encryption.
3. Security Security. The Cloud servers that We use are running hardened Linux distributions with up-to-date security patches. Installations are ad-hoc and minimal to limit the number of services that could contain vulnerabilities. Access is limited to essential personnels and is only possible using an encrypted personal SSH keypair, from a computer with full-disk encryption.
4. Physical security. The Cloud servers are hosted in trusted data centers which can only be accessed by data center employees only and with security badges or biometrical security and security personnel on site 24/7.
5. Credit Card Safety. The Service Provider of Hungr-E does not store credit card information in their systems.
Limiting access to essential personnel. We limit access to Personal Information to authorized personnel, based on job function and role.
Incident Management. We maintain a formal incident management program designed to ensure the secure, continuous delivery of its Services, and complies with the data breach reporting standards required under the Data Privacy Act of 2012 (RA 10173). Hungr-E has also implemented an incident management program using industry best practices.
Managing third party service providers. Hungr-E requires service providers to implement and maintain accepted industry standard administrative, physical and technical safeguards to protect Personal Information.
Your Responsibility. Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify Hungr-E of any unauthorized use of your password. Hungr-E cannot secure Personal Information that you release on your own or that you request us to release.
Your information collected through the Service may be stored and processed in the Philippines, or any other country in which Hungr-E or its partners, contractors subsidiaries, affiliates or service providers maintain facilities and, therefore, your information may be subject to the laws of those other jurisdictions which may be different from the laws of your country of residence.
We store your Personal Information in a dedicated database provided by our service provider that uses reasonable security measures to prevent unauthorized access. The security measures are provided in the preceding section of this Policy.
Our relationship with you. We are the “controller” with respect to your Personal Information because we determine the means and purposes of processing your information when using our Services.
Legal bases for processing Personal Information from the Philippines. We describe how we process your Personal Information in this Privacy Policy. We may process your Personal Information if you consent to the processing, to satisfy our legal obligations, if it is necessary to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you, or for our legitimate interests to protect our property, rights or safety of Hungr-E, our customers or others
Direct Marketing. We will obtain your consent where required to send you marketing communications using electronic means. You may withdraw your consent at any time by notifying us through our contact information and Customer Care. We will only contact you by electronic means (email, push notification, SMS, etc.) with information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.
We will only share your Personal Information with third parties for marketing purposes with your explicit consent. If you do not want us to use your Personal Information in this way, please contact us through Customer Care. You may raise such objection with regard to initial or further processing for purposes of direct marketing at any time. The withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.
Other marketing activities will happen based on the legitimate interests of Hungr-E. E.g., where we tailor marketing communications or send targeted marketing messages via post, phone or social media and other third party platforms; and in providing existing customers with information (via email or other channels) about similar products and services.
Privacy Rights. You can exercise your privacy rights by following the instructions. We will handle your request under applicable law. When you make a request, we may verify your identity to protect your privacy and security.
1. Right to withdraw consent. To the extent Hungr-E requests and you provide your consent to the processing of your Personal Information, you can withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.
2. Right of access to and rectification of your Personal Information. Our site allows you to access and rectify certain Registration Information within your Account Settings. If you would like to access or rectify any other information, contact Customer Care and we will do our best to assist you without undue delay. We may reject part or all of your request if responding to your request could adversely affect the rights and freedoms of others.
3. Right to erasure (or, “Right to be Forgotten”). As explained under our provisions on Account Deletion, we allow our customers to delete their accounts at any time. You can request erasure of Personal Information that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing to which you previously consented, but later withdrew such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. If we have made your Personal Information public and we are required to erase such Personal Information, we will take reasonable steps, including technical measures, to inform controllers that are processing any links to or copies or replications of your Personal Information of your erasure request. Our assistance with your request for erasure is subject to limitations by relevant data protection laws, available technology and the cost of implementation.
4. Right to Data Portability. If we process your Personal Information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your Personal Information in a structured, commonly used and machine-readable format, and to have us transfer your Personal Information directly to another controller, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of your Personal Information.
5. Right to restriction of our processing. You can restrict our processing of your Personal Information where one of the following applies: (a) you dispute the accuracy of Personal Information processed by Hungr-E (for a period enabling us to verify its accuracy); (b) the processing is unlawful and you oppose the erasure of the Personal Information and request the restriction of its use instead; (c) Hunger-E no longer needs the Personal Information for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims; and (d) you have objected to certain processing relying on legitimate interest, pending the verification whether Hungr-E’s legitimate grounds override your rights. Restricted Personal Information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will notify you if the restriction is lifted.
6. Notification of erasure, rectification and restriction. We will provide notice to each recipient that we disclosed your Personal Information to regarding any rectification or erasure of Personal Information or restriction of processing, unless you initiated the disclosure, we have previously made a statement that we will not provide prior notice, or providing notice proves impossible or involves disproportionate effort. Upon your request, we will share the list of recipients with you.
7. Right to object to processing. Where the processing of your Personal Information is based on consent, contract, or legitimate interests described under the Legal Bases for Processing heading above, you may restrict or object, at any time, to the processing of your Personal Information as permitted by applicable law. We may continue to process your Personal Information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
8. Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you, except as allowed under applicable data protection laws.
9. Retention of your Personal Information. Unless you make a request for us to delete your account or delete certain Personal Information (i.e., User Content, etc.), or unless we have indicated otherwise, or you have previously agreed to a different data retention period, we will store your Personal Information as long as your account is open. If you request to delete your account, we will take the steps described under “Your Choices – Account Deletion” and delete all your Personal Information, unless a longer retention period is required or permitted by law.
The rights described above may be limited by local laws depending on the applicable jurisdiction. Further, your right of access and deletion is not absolute and may not be available if fulfillment of such right would, among other things:
• cause interference with execution and enforcement of the law and legal private rights (such as in the case of the investigation or detection of legal claims or the right to a fair trial);
• breach or prejudice the rights of confidentiality and security of others;
• prejudice security or grievance investigations, corporate reorganizations, future and ongoing negotiations with third parties, the compliance with regulatory requirements relating to economic and financial management; or
• otherwise violate the interests of others or where the burden or cost of providing access would be disproportionate.
Complaints. If you believe that we have infringed your rights, we encourage you to contact us so that we can try to address your concerns or dispute informally. Our contact information is: (02) 8461-3721, Jaime de los Reyes, Data Privacy Officer
We reserve the right to make changes to our practices and this Privacy Policy. Whenever this Privacy Policy is changed in a material way, a notice will be posted as part of this Privacy Policy and on our website for 30 days. After 30 days, the changes will become effective. In addition, all customers will receive an email with notification of the changes prior to the change becoming effective. Hungr-E may provide additional “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. Such notices may supplement or clarify Hungr-E privacy practices or may provide you with additional choices about how Hungr-E processes your Personal Information.
If you have questions about this Privacy Policy and our privacy practices, or wish to submit a complaint, you may reach us through (02) 8461-3721, Jaime de los Reyes, Data Privacy Officer