Privacy Policy
Last Updated: January 1, 2020

Privacy Policy

FlexPass Privacy Policy explains:

  1. What information we collect and why we collect it
  2. How we use that information
  3. The choices we offer, including how to access and update information.

We’ve tried to keep it as simple as possible, but if you’re not familiar with terms like cookies, IP addresses, pixel tags and browsers, you can refer to key terms below. Your privacy matters to us and applies to you if you use our site in Malaysia, so whether you are new to us or a long-time user, please do take the time to get to know our practices – and if you have any questions please contact us.

Information we collect

We collect information to provide better services to all of our users – from figuring out basic stuff like which language you speak, to more complex things like which activities you’ll find most interesting. We collect information in two ways:

  1. Information you give us
    For example, many of our services require you to sign up for a FlexPass Account. When you do, we’ll ask for personal information like your name, email address, telephone number or credit card.
  2. Information we get from your use of our services
    We may collect information about the services that you use and how you use them, like when you visit us and what activities products you search of. This information includes:
    1. Device information
      We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your Account.
    2. Account information
      Information during account creation such as name, email, photos, payment or billing information which will be used to complete your profile will be collected.
    3. Log information
      When you use our services or view content provided by FlexPass, we may automatically collect and store certain information in server logs. This may include:
      • Details of how you used our service, such as your search queries
      • Telephone, email, and any form of communication between the users, employers, partners and Flexpass
      • Internet Protocol Address
      • Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL
      • Cookies that may uniquely identify your browser or your Account
    4. Location information
      When you use a location-enabled service via your Device, we may collect and process information about your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.
    5. Certain services include a unique application number
      This number and information about your installation (for example, the operating system type and application version number) may be sent to Us when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates. Local storage We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
    6. Cookies and anonymous identifiers
      We use various technologies to collect and store information when you visit our services, and this may include sending one or more cookies or anonymous identifiers to your device. We also use cookies and anonymous identifiers when you interact with services we offer to our partners, such as advertising services or features that may appear on other sites.

How we use information we collect

We use the information we collect from all of our services to provide, maintain, protect and improve them, to develop new ones, and to protect Us and our users. We also use this information to offer you tailored content – like giving you more relevant search results and recommendations of activities and products.

We may use the name you provide for your Account across all of the services we offer that require an Account. In addition, we may replace past names associated with your Account so that you are represented consistently across all our services. If other users already have your email, or other information that identifies you, we may show them your publicly visible Profile information, such as your name and photo. When you contact Us, we may keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements.

We use information collected from cookies and other technologies, like pixel tags to improve your user experience and the overall quality of our services. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer. When showing you tailored activities and products, we will not associate a cookie or anonymous identifier with sensitive categories, such as those based on race, religion, sexual orientation or health.

We may combine personal information from one service with information, including personal information, from other FlexPass services – for example to make it easier to share things with people you know. We will not combine DoubleClick cookie information with personally identifiable information unless we have your opt-in consent.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy. FlexPass may process your personal information on a server located outside the country where you live.

If you leave your employer to join another company that also offers FlexPass, your personal information including your activity data may be transferred to a new account by contacting us. By transferring your information to a new account, your new employer may have access to your previous activity data.

We will not sell your personal information including your name, email, contact number and activity data to a third party without your consent.

Transparency and choice

People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. For example, you can:

  1. Review and Amend certain types of information tied to your Account by using the My Account Page
  2. View and Edit your preferences, such as which categories might interest you, using the My Account

You may also set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it’s important to remember that many of our services may not function properly if your cookies are disabled. For example, we may not remember your language preferences.

Information you share

Many of our services let you share information with others. Remember that when you share information publicly, it may be indexable by search engines. Our services provide you with different options on sharing and removing your content.

We may ask for ratings or feedback at any time and may use any replies to display public ratings and reviews on our website. This may be shared along with your online profile photo provided on online public accounts such as Google or Facebook.

Accessing and updating your personal information

Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

Information we share

We do not share personal information with companies, organizations and individuals outside of FlexPass unless one of the following circumstances apply:

  1. With your consent

    We will share personal information with companies, organizations or individuals outside of FlexPass when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information. We provide personal information to your employer, our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. A specific example of where your personal information is shared is when you are making a booking via our site or app with one of our Partners in which case we will pass over your personal information when required to complete the booking process. Another specific example is your employer has access to your personal information including where and when you take a class through us.

  2. For legal reasons

    We will share personal information with companies, organizations or individuals outside of FlexPass if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

    • Meet any applicable law, regulation, legal process or enforceable governmental request
    • Enforce applicable Terms of Service, including investigation of potential violations
    • Detect, prevent, or otherwise address fraud, security or technical issues
    • Protect against harm to the rights, property or safety of FlexPass, our users or the public as required or permitted by law

    We may share aggregated, non-personally identifiable information and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services.

    If FlexPass is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

    FlexPass complies with the Personal Data Protection Act (PDPA) 2010 of Malaysia for our users.

Information security

We work hard to protect FlexPass and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:

  • We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems
  • We restrict access to personal information to FlexPass employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations

Information security

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, or activities that we display from our Partners sites that may include FlexPass services, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organisations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Enforcement

We regularly review our compliance with our Privacy Policy. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Changes

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

KEY TERMS:

  1. FlexPass Account or Account

    You may access some of our services by signing up for a FlexPass Account and providing us with some personal information (typically your name, email address and a password). This account information will be used to authenticate you when you access FlexPass services and protect your account from unauthorized access by others. You can edit or terminate your account at any time through your Account settings.

  2. Cookie

    A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.

  3. Anonymous identifier

    An anonymous identifier is a random string of characters that is used for the same purposes as a cookie on platforms, including certain mobile devices, where cookie technology is not available.

  4. Server logs

    Like most websites, our servers automatically record the page requests made when you visit our sites. These “server logs” typically include your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

  5. Sensitive personal information

    This is a particular category of personal information relating to confidential medical facts, racial or ethnic origins, political or religious beliefs or sexuality.

  6. Non-personally identifiable information

    This is information that is recorded about users so that it no longer reflects or references an individually identifiable user.

  7. Cookie

    A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.

  8. Pixel tag

    A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies.