Privacy Policy

Hexon Data Sdn Bhd is a privately held company, registered at Companies Commission of Malaysia, an agency under the Ministry of Domestic Trade, Co-operatives and Consumerism under the company registration number 1227841-V (“Hexon Data”, “We, “Our” or “Us”). These Terms of Use (“Terms”) govern the access or use by you, a passenger (“User”, “End User” or “You”) or a public transport provider (“Customer”, “Transit Operator” or “You”), of applications, websites, contents, products, data products, embedded services and services (the “Services”). The Services constitute a real-time public transport mobility platform that provides mobility-as-a-Service to passengers through real-time urban navigation and multi-modal journey planning mobile application (the “JustNaik App”).

Hexon Data is dedicated to protecting Your personal information because it is our very important community principle. We understand clearly that You and Your information is one of Our most important assets, as much as we know that you care how information about you is used and shared. Being formulated in accordance with the Personal Data Protection Act 2010 (Act), this Privacy Policy which is part of Hexon Data’s Terms of Use (“Terms”) explains what information of yours will be collected by Hexon Data when you use the Services and through other interactions and communications you have with us, how the information will be treated, including personally identifying information and how you can control the collection, correction and/or deletion of information. It applies to persons anywhere in the world who use Hexon Data Services (web-based or app) to plan their journey (“Users”) and transit operators, city municipals, drivers, couriers, partner transportation companies, or any other persons who use Hexon Data mobility platform under licence (collectively “Public Transport Providers”). Additionally, it applies to transactions and activities and data gathered through Hexon Data Services.
This Privacy Policy does NOT apply to the practices of companies that Hexon Data does not own or control, or to individuals whom Hexon Data does not employ or manage, including any of the third parties to which Hexon Data may disclose user information as set forth in this Privacy Policy.
We provide this Privacy Policy to help you make an informed decision about whether to use or continue using the Hexon Data Services. We take our obligations regarding your privacy seriously and have made every effort to draft this Privacy Policy in a manner that is clear and easy for you to understand. We will not use or share your information with anyone except as described in this Privacy Policy. By accessing or using the Services, you agree to this Privacy Policy and our Terms of Use. If you do not agree to our practices, please do not use or access our Services.

Hexon Data may obtain the following types of information from or concerning you or your mobile phone device, which may include information that can be used to identify you as specified below (“Personally Identifying Information”):

3.1 Information You Provide

When you download and register with us and use the Services, you generally provide (a) your name, postal address, email address, phone number, user name, password and other registration information; (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications from us; (c) information you provide us when you contact us for help; (d) information you enter into our system when using the Services, such as contact information; and (e) demographic information (i.e., information that You submit, or that We collect, that is not personal information; this may include, but is not limited to, zip code, hometown, gender, username, age/birth date, browsing history information, searching history information, and registration history information. We will also collect the contact information of Your friends, if You choose to connect Your contacts and address book information with JustNaik App and/or JUstNaik Site, and Your login credentials to Your social network accounts, such as Facebook and Twitter, if You choose to connect those accounts with your JustNaik Account. You represent and warrant that You have the authority to provide Us with any such contact information. Demographic information is divided into two categories: (i) non-public information, which consists of ride transaction information; and (ii) public information, which consists of all other demographic information. We may also use your Personal Information you provided us to contact you from time to time to provide you with important information, required notices and marketing promotions. Registration with us is optional. However, please keep in mind that you may not be able to use some of the features offered by the Services unless you register with us.

3.2 Information We Collect Automatically

In addition, We may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Services. When you use our Services, we collect information about you in the following general categories:

(a) Cookies Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive. Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

(b) Web Beacons and Pixels Small graphic images or other web programming code called “web beacons” “clear GIFs” or “1x1 pixels” may be used on the Services or in our emails and may be invisible to you. Web beacons may be connected to your Personal Information, if you have provided it. Web beacons may be used for a various purposes, such as counting visitors to the Services, monitoring how users navigate the Services, counting how many emails that were sent were actually opened, or counting how many times a link was accessed. We do not sell, rent, trade, or otherwise distribute information about you gathered through the web beacons or 1x1 pixels with any third parties, except for third parties who provide us with advertising, marketing, research or analysis services.

(c) Location-identifying Technologies Additionally, Hexon Data may use GPS (“Global Positioning Systems”) software and other location-based technologies such as “iBeacons” to locate you so we may verify your location, deliver you relevant content based on your location, as well as allow you to share your location to other users as part of the services we provide via the Services. We may determine your approximate and/or exact location information to provide location-based services. In addition to traditional GPS location-based services, some of the retailers and others we work with may install other types of location-tracking technology. These technologies emit a signal that we can use to detect to pinpoint your proximity to those locations (such as how close you are to retail locations and products) or otherwise interact with the Services (such as to send you helpful information, offers, and discounts).

(d) Location Information We may collect and process information about the location of the device from which you are accessing the Service. Location data may convey information about how you browse the Service and may be used in conjunction with personally identifiable information. You can disable location based services in settings associated with the Service; however please be aware that some features of the Service may not function properly if location services are turned off.

(e) Embedded Scripts An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.

(f) Log Data We collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer's Internet Protocol (“IP”) address, app features or pages viewed, app crashes and other system activity, browser type, browser version, referring / exit pages and URLs, the pages of JustNaik Site that you visit, the access date and time of your visit, the time spent on those pages, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, mobile carrier, the third party sites or services you were using before interacting with our Services and other statistics. In addition, we may use third party services such as Google Analytics that collect, monitor, analyze, improve and maintain the Services and to diagnose and fix any Service-related issues.

(g) Device Identifiers. When you access the Service using a mobile device, we collect specific device information contained in your mobile device’s “device identifier”. This device identifier includes information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We may associate this device identifier with your Service account and will use data associated with your device identifier to customize our Services to your device and to analyze any device-related issues.

3.3 Information You Provide About Third Parties

The Services may permit you to provide Personal Information about third parties, such as mailing addresses, email addresses, location data and birth dates. If you use our Services to receive notifications or any other content, we collect certain Personal Information about the recipient (such as name, mailing address, and email address, as applicable). We may share the information regarding your transaction with third parties as necessary to process your transaction. Hexon Data Services may also allow you to import information about third parties through several methods, including directly from your computer or mobile device or from a third-party service (e.g., through Social Media Interactions or by asking you for your login information to your email or other account). If you choose to provide Personal Information about third parties or to import your contacts, we will store that information only in connection with your relationship with us. Unless you consent, we will not store the password you provide if you import your contacts from a third-party source.

When you visit the mobile application, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located within and display a location map. We will not share your current location with other users or partners.

If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application.

We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

We work with certain third parties (including network advertisers, ad agencies, and analytics companies) to help us understand how the Services are being used, such as the frequency and duration of usage. We work with advertisers and third party advertising networks, who need to know how you interact with advertising provided in the Services which helps us keep the cost of the Services low or free. With third-party’s help, we may obtain information regarding traffic and use of the Services and our advertisements on the Services and across the Internet, and to engage in multi-site advertising. Advertisers and advertising networks use some of the information collected by the Application, including the unique identification ID of your mobile device and your mobile telephone number.

These third parties may set and access their own tracking technologies (including cookies, web beacons, and embedded scripts) and may otherwise collect or have access to your Device Identifier, Usage Information and related information about you. These service providers may use that information for their own purposes, including to target advertisements to you, prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you. We may share the Device Identifier and Usage Information about visitors with third party advertising companies, analytics providers and other vendors for similar purposes.

To protect the anonymity of this information, we use an encryption technology to help ensure that these third parties cannot identify you personally. These third parties may also obtain anonymous information about other applications you’ve downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., your zip code), and other non-precise location information in order to help analyze and serve anonymous targeted advertising on the Services and elsewhere. We may also share encrypted versions of information you have provided in order to enable our partners to append other available information about you for analysis or advertising related use. If you would like to opt-out from third party use of this type of information to help serve targeted advertising, please visit the section entitled “Opt-out” below

The Services may integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.

7.1 Community Forums

We may provide you the opportunity to participate and post content publicly through interactive features and through other communication functionality (“Community Forums”). You may choose, through such features or otherwise, to submit or post photographs (which may include metadata), videos, questions, comments, suggestions or other content (collectively, “User Content”). Please note that certain information, such as your name and other Personal Information, may be publicly displayed on Hexon Data Services along with your User Content.

Anything you post to a Community Forum is public -- others will have access to your User Content and may use it or share it with third parties. Information or other content you choose to post or make available in the Community Forums may be viewed, collected and used by others. If you choose to voluntarily disclose Personal Information, that information will be considered public information and this Privacy Policy will not apply to such information. If you submit User Content, it may be published online or offline at any time. In addition, we may use your User Content and any excerpt from your User Content in connection with our advertising, marketing, publicity and promotional activities.

7.2 Social Features

Certain functionalities of the Hexon Data Services may permit interactions between Services and a third-party website or interactive service (“Social Features”). For example, Social Features may enable you to indicate through a third party website or interactive service that you “like” a JustNaik Site or JustNaik App or content available on a JustNaik Site or JustNaik App, or to “share” content from the JustNaik Site or JustNaik App. Social Features may also allow you to upload or download photos to or from your Account on a third party website or interactive service, or to login to one or more of JustNaik Site or JustNaik App using your access credentials for a third party website or interactive service. If you upload photos directly from a third-party website or interactive service, Hexon Data will use those photos only in connection with your relationship with us and will not make those photos publicly available (unless you choose to make those photos publicly available).

If you choose to use Social Features, certain information, which may include your Personal Information, may be publicly displayed, and the third-party website or interactive service used in connection with the Social Features (and its users) may have access to information about you and your use of our Services. Similarly, if you post information on a third-party website or interactive service that references the Services (e.g., by using a hashtag associated with the Platforms in a tweet or status update), your post may be published on the Site in accordance with the terms of the third-party website or interactive service, and we may collect the information in your post.

We may receive information about you from third party providers of Social Features that interact with our Services. For example, if you choose to use Social Features, you allow us to collect (or the third party to share) information about you, including Personal Information, related to your use of the third-party website or interactive service. The third-party website or interactive service may allow you to remove the application or feature, in which case we will no longer collect information about you through JustNaik Site or JustNaik App, but we may retain the information previously collected in accordance with respective third-party privacy policies. In addition, we may receive information about you if other users of a third-party website, feature or application give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your posts, your “connections” web page, profile page, or similar page on a third party social media website, feature or application. The information we collect in connection with Social Features is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party's privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third-party website or service.

7.3 Contact Importers

We may also allow you to import information about yourself or third parties from a third-party website or interactive services. For example, we may allow you to provide your login information to your email account so that the Services may import your contacts or list of persons with whom you have communicated. By providing the login information in your Account in any such situation, you are consenting to JustNaik, or a party on behalf of JustNaik, importing your contacts or list of persons with whom you have communicated for using with JustNaik Services. Unless you consent, we will not store the password you provide if you import your contacts from a third-party source.

7.4 Testimonials

We may post User and Customer testimonials on JustNaik Site, which may contain User Content or Personal Information. We do obtain your consent to post your name along with your testimonial via email prior to posting the testimonial on our Platforms. However, if you wish to request the removal of your testimonial, please contact us at [email protected].

We may use Your Personal Information we collected about you to:

(a) Provide, maintain, and improve our Services, including, for example, to facilitate payments (if applicable at your current use of the version), send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users and Customers, develop safety features, authenticate Users and Customers, and send product updates and administrative messages;

(b) Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;

(c) Send or facilitate communications (i) between you as a User and a Public Transport Provider (“Customer”), such as estimated times of arrival (ETAs), or (ii) between you and a contact of yours at your direction in connection with your use of certain features, such as referrals, invites, split fare requests, or ETA sharing;

(d) Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of JustNaik and other companies, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;

(e) Personalize and improve the Services and user experience in relation to the use or access of the Services, including to provide or recommend features, content, social connections, referrals, and advertisements.

(f) Build a profile of your preferences so we can personalise the Services and provide you the relevant information and recommend transport options which match your stated preferences and previous use of the Services;

(g) Disclose to lawful authorities when required to do so by law or where appropriate in our opinion as a responsible company to respond to their request.

We may transfer the information described in this Privacy Policy to, and process and store it in, Malaysia and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Privacy Policy.

We may review all demographic Data. We may use public information to enable other users to search Your profile, to determine whether Your trip details fit other user’s requirements, and to communicate with You. We may use demographic information to tailor JustNaik Services and communications to Your interests. We may also share demographic information with advertisers on an anonymous and aggregated basis (i.e., without telling the advertisers Your identity). One of the reasons We may do this is to increase the likelihood that Our advertisers’ goods and services will appeal to You as a user of the JustNaik Services. Our sharing of demographic information with advertisers is anonymous (i.e., We do not tell advertisers which particular Users are members of which demographic groups), subject to the rest of this Privacy Policy. When You respond to an advertisement, however, We ask You to remember that if that ad that is targeted to a demographic group and You decide to give the advertiser Your personal information, then the advertiser may be able to identify You as being a member of that demographic group.

Hexon Data allows You to access and edit Your personal information. To update Your personal info, click Settings in the JustNaik App or JustNaik Site menu, provided that You have signed up for an Account. Hence, You can view, update and correct Your account information. We will always protect the integrity of sensitive data. Subsequently, Our databases automatically update any personal information You edit in Your profile, or that You request We edit. Information transmitted through boards, chats, polls or through any other means remains in Our databases and become the property of Hexon Data upon submission. Keep this in mind if You decide to communicate personal information through any of these applications.

We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for an indefinite length of time and thereafter may store it in aggregate. If you would like us to delete information that You have provided via JustNaik Services, please contact us at [email protected] and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Services to function properly. You do hereby represent and warrant that You understand and agree that all information submitted by You through Hexon Data becomes the property of Hexon Data and may be used in the sole discretion of Hexon Data in accordance with this Privacy Policy and our Terms.

We do not use the Services to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected] and We will delete such information from our files within a reasonable time.

There are multiple opt-out options for users of this Application: Opt-out of all information collection by uninstalling the Application – You can stop all collection of information by the Services easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. Opt-out from the use of information to serve targeted advertising by advertisers and/or third party network advertisers. You can also request to opt-out via email, at [email protected].

In the event that WhatsApp is acquired by or merged with a third-party entity, we reserve the right to transfer or assign the information we have collected from our users as part of such merger, acquisition, sale, or other change of control. In the (hopefully) unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used. We may also disclose personal information when We determine that such disclosure is necessary to comply with applicable law, to cooperate with law enforcement or to protect the interests or safety of Hexon Data or other visitors to the JustNaik Platform. Whenever personal information is disclosed under this paragraph, We may also disclose Your demographic information along with it, on a non-anonymous basis. All of Our parent, subsidiary and affiliated legal entities and businesses that receive Your personal information or non-anonymous demographic information from Us will comply with the terms of this privacy policy with respect to their use and disclosure of such information.

15.1 Our Security Measures

Your JustNaik Account in relation to your JustNaik App or JustNaik Site is password-protected so that only You and authorized Hexon Data employees have access to Your account information. In order to maintain this protection, do not give Your password to anyone. Hexon Data staff will never proactively reach out to You and ask for any personal account information, including Your password If You share a computer, You should sign out of Your JustNaik account and close the browser window before someone else logs on. This will help protect Your information entered on public terminals from disclosure to third parties.

We will use appropriate industry standard technical and organizational security measures in connection with the data collection, storage, processing and transfer of your Content that are designed to protect the integrity of that Content and to guard against unauthorized or unlawful access to, alteration, disclosure or destruction of, use of, or processing of such Content, Personal Information, username, password, transaction information and data stored on our end.

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. JustNaik Services has security measures in place to protect against the loss, misuse and alteration of the information under Our control. Your information may be transferred to and maintained on computer networks which may be located outside of the state, province, country or other governmental jurisdiction in which You reside, and the country or jurisdiction in which these computer networks are located may not have privacy laws as protective as the laws in Your country or jurisdiction.

The JustNaik Site may contain links to other web sites. We are of course not responsible for the privacy practices of other web sites. We encourage Our Users to be aware when they leave the JustNaik Site to read the privacy statements of each and every web site that collects personally identifiable information. This Privacy Policy applies solely to information collected by the JustNaik Services.

15.2 Risks Inherent in Sharing Information

Although we allow you control over where you share your Content and what information is included in your Profile and take reasonable steps to maintain the security if the information associated with your account, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you share your Content and we are not responsible for third party circumvention of any privacy settings or security measures on the Service.

The Service is controlled and operated from facilities in Malaysia. Hexon Data makes no representations that the Services are appropriate or available for use in other locations. You access or use the Services from other jurisdictions (or who allow their End Users to do so) do so of your own volition and are responsible for compliance with all applicable Malaysia and local laws and regulations, including but not limited to export and import regulations. You must comply with all domestic and international export laws and regulations that apply to your distribution or use of our Services. These laws include restrictions on destinations, users and end use. If You are located outside of Malaysia, You agrees that Hexon Data may transfer, store and process Customer Content in locations other than Your residing country. Hexon Data complies with Personal Data Protection Act 2010 and any other applicable legislation relating to data protection regarding the collection, use, and retention of personal data. The export and re-export of Content via the Services may be controlled by Malaysia Export Administration Regulations or other applicable export restrictions or embargo. The Services may not be used in any country that is subject to an embargo by Malaysia and You may not use the Services in violation of any export restriction or embargo by Malaysia or any other applicable jurisdiction. In addition, You must ensure that the Services are not made available for use by persons or entities blocked or denied by the Malaysia government.

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by placing a prominent notice on our official website and informing you via email or text message. You are advised to consult this Privacy Policy periodically for any changes, as continued use is deemed approval of all changes. You can check the history of this policy on our website where available.

By using the Services, you are consenting to our processing of User Provided and Automatically Collection information as set forth in this Privacy Policy now and as amended by us. "Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in Malaysia.

Hexon Data values any feedbacks you may have concerning the structure or content of this site or our Services. Your constructive feedbacks will be kept on file for planning purposes, so that our future upgrades to the Services can incorporate the wishes of our Users and Customers. Your e-mail comments will be kept solely for the purposes of future planning and will not be integrated into any of our consumer databases. We will not disclose your e-mail addresses or any personal information they may contain, to anyone outside Hexon Data. Should you wish to view your comments at any time please contact us at [email protected]. Hexon Data may provide feedback facilities on our JustNaik Site or JustNaik App to allow users to provide input into the future development of the Services. The provision of personal details on feedback is optional. Users may provide personal details for the purpose of receiving a reply to their feedback. This information will only be used for the purpose for which it was provided. We will not add your email address or name to any mailing list.

Hexon Data may publish aggregated information about feedback on JustNaik Site, but will ensure that this aggregated information cannot be used to identify individual users.

If You have any questions about this Privacy Policy, the practices of Hexon Data, or Your dealings with Hexon Data, You may contact Us at: [email protected].