Privacy Policy

Effective from: 29 Jan 2021

INTRODUCTION

Subject to the Personal Data Protection Act 2010 (“PDPA”) , this privacy notice (“Notice”) set out on how Topbus (M) Sdn Bhd and/or its subsidiaries, affiliates, associated companies and jointly controlled entities (collectively as “Topbus”, “we”, “us” or “our”) collect, use, process, disclose information about you when you visit, use or interact on our website and/or mobile application (collectively, “Platform”) or such other means connected to the Platforms (including without limit by communicating with our customer service team via chat or email).

Scope

This Notice applies to our visitors, users, customers, passengers, agents, vendors, suppliers, partners, contractors and service providers (collectively “you”, “your” or “yours”).

“Personal Data” is the Personal Data as referred and defined in PDPA, which shall mean any information in respect of commercial transactions, which is:

  • Being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose;
  • Is recorded with the intention that it should wholly or partly be processed by means of such equipment; or
  • Is recorded as part of a relevant filling system or with the intention that it should form part of a relevant filling system,

That related directly or indirectly to a data subject, who is identified or identifiable from that information or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject.

Information Collected

Generally, there are a few methods on how do we may obtain your Personal Data:

  • It could be from you for account registration, completing transactions, deal with customer service: Your name, email address, contact number, social media account, transaction details, payment account, payment cards detail.
  • Or the information automatically collected by our Platform: IP address, geographic data, country, search preferences related to specific searches, browser, and information about your device's operating system, application version, language settings, and pages that have been shown to you, device ID, location of the device (with your consent), and device-specific settings and characteristics.
  • It could be collected through our marketing and promotional activities: Name, email, contact, address.
  • Or it could be from other parties: Email address, name, contact, national ID numbers, race, marital status, and your health or religious beliefs.

Please take note that sensitive Personal Data will only be collected if it is required under the applicable laws and regulations.

Cookies Used

We use cookies, pixels/tags, SDKs, and other similar technologies on our Platform that collect and store certain information about you in order to provide, secure, and maintain the Platform to you. Cookies that may be used include site analytic cookies, preference cookies, targeting cookies and social media cookies.

You may check your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Platform. You may also need to re-enter your information when you re-visit the Platform.

Purposes

We may use, combine, and process the Personal Data collected through the Platform and other parties to:

  • Provide you with the requested products and/or services, such as creating a user account with us, processing and confirming your reservation and/or booking, responding and/or communicating with you about our services, your inquiries, special requests, cancellations, and/or rewards;
  • Respond to questions, comments, and feedback from you;
  • Investigate and address concerns raised by you about the products and/or services;
  • Process the transaction, payments related matters, business analytics;
  • Send you email marketing communications inter alia mobile push notifications, emails, SMS, MMS, and/or phone calls (telemarketing) about products and services that may be relevant to you. You may, however, at any time choose to opt-out of these marketing communications from us pursuant to Section 10 below.
  • Conduct surveys, market researches, and developments or provide you with information about our services on our Platform or other websites you may visit;
  • Maintain and improve the Platform, tailor and enhance the user experience, and for internal training;
  • Monitoring, processing and/or tracking your use of the Platform to provide you with a seamless experience;
  • Protect the security of you and the Platform;
  • Exercising a right or obligation conferred or imposed by law, including responding to request and legal demands;
  • In connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company;
  • For such other purposes as required under the laws and regulations.

(Collectively, “Purposes” or each, a “Purpose”)

Opt-Out

If you wish not to receiving any marketing and promotions related communications, please contact us by sending an email to admin@topbus.express for opting out.

Disclosure

In connection with your visit to our Platform and the use of our services, we may share or disclose your Personal Data as follows:

  • Third-Party Service Providers who provide data processing services to us (for example web hosting), or who otherwise process Personal Data for purposes such as credit card and payment processing, business analytics, customer service, marketing, or distribution of surveys, to facilitate the delivery of online services and advertising tailored to your interests, and/or fraud prevention. Our third-party service providers will only process information as needed to perform their functions. They are not permitted to share or use the information for any other Purpose.
  • Our parent company, sister company, and such other related company to share with you the services that we deem fit to you as well as to enhance your user experience.
  • Business Partners with whom we may jointly offer products or services, or whose products or services may be offered on our Platforms.
  • Business Partners with whom we may jointly offer products or services, or whose products or services may be offered on our Platforms.
  • Where Required or Permitted by Law - such as to protect ourselves against liability, to respond to subpoenas, judicial processes, legitimate requests, warrants, or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary to comply with applicable law. We may also, in compliance with applicable law, disclose your information to enforce or apply the terms and conditions applicable to our services or to protect the rights, property, or safety of Topbus, our users, or others.
  • Business Reorganization - such as part of any sale, assignment, or other transfer of our business, or transition of service to another provider. We will ask for your consent if required by applicable law.
Link

As you could see from our Platform, we have some links on the Platform that link to other websites, sites of third-parties (“Third-Party Site”). You shall take note that our Privacy Notice applies solely to information collected by Topbus and does not apply to Third-Party Site. We are not responsible for the privacy practices or content of those Third-Party Site you are strongly advised to read the privacy policy of such Third-Party Site before submitting any personal information.

Retention

Your Personal Data collected by us will not be deleted immediately from our system and that retention of your Personal Data is subject to the period necessary to fulfil the Purposes outlined in this Privacy Notice and internal company policies. Nonetheless, we will remove your Persona Data from our systems and records and/or take steps to properly anonymize it once we no longer need your Personal Data, unless we are required under the applicable legal or regulatory obligations to keep it; or the Personal Data is required to carry out corporate tasks and achieve our business objectives.

Data Security

We maintain reasonable security measures for both physical, electronic data storage from any accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access. Nonetheless, we would like to highlight that we do not guarantee any absolute security for any data transmission on the internet.

Your Rights

You shall enjoy the following rights related to your Personal Data collected by us:

  • Access: You are entitled at any time to obtain information about your Personal Data that we store, in accordance with applicable law, subject to a reasonable fee for the handling and processing of your requests to access your Personal Data.
  • Rectification: You may request that we rectify any of your Personal Data that is incomplete or incorrect.
  • Deletion: You may request that we delete your Personal Data or account.
  • Restrictions of Processing: You may ask us to cease processing your Personal Data for example if you have objected to the processing and the existence of legitimate grounds is still under consideration.
  • Objection: You may object, at any time, to your Personal Data being processed by us for direct marketing purposes.
  • Revoke Consent: You have the right to withdraw your consent at any time, without affecting the lawfulness of our processing based on such consent before it was withdrawn
  • Other: any other matters reasonably related to your Personal Data.

(collectively be referred to as “Rights”)

Subject to as permitted by the law, we may impose an identity verification procedure on you before you could exercise some of the Rights, failing which, we may reject your request. Reasonable fee may be imposed to process your requests to us.

Minor

Our Platform is not directed to the minor(s) nor does the Platform intended to provide any services to any minor. You hereby warrant and represent that you are not a minor and it is your sole responsibility to take care of your account from any unauthorised access or use of the account by the minors under your care.

Amendment & Updates

Modifications, amendment, updates may be made on this Privacy Notice. Hence, you are advised to review this Privacy Notice periodically for the latest policies and practices. Notification and consent will only be issued to you for material changes to the Privacy Notice that is required under the law. Your continuance to communicate or interact with Topbus signify your acceptance of such modifications, updates, or amendments.

Contact Us

Should you have any queries or feedback about your Personal Data, please do not hesitate to contact us at enquiry@easybook.com, at the following hours:
Contact No. +65 6333 1948
8 am - 6 pm (Monday to Friday)
8 am - 5 pm (Saturday to Sunday)