Privacy Notice
Date of Modification: June 26, 2023
This Privacy Notice (“Privacy Notice”) describes how Lola Digital Sdn.
Bhd., its respective subsidiaries, affiliates, associated companies
and jointly controlled entities (collectively “Lola”, “we”, “us” or
“our”) collect, use, process and disclose your Personal Data through
the use of Lola's mobile applications and websites (respectively
“Apps” and “Websites”), as well as products, features and other
services globally, operated by Lola (collectively, “Services”).
This Privacy Notice applies to our users, merchants, agents, vendors,
suppliers, partners (including but not limited to operators of
kindergartens and playschools), contractors and service providers
(collectively “you”, “your” or “yours”).
“Personal Data” is any information which can be used to identify you
or from which you are identifiable. This includes but is not limited
to your name, nationality, telephone number, bank and credit card
details, personal interests, email address, image, government-issued
identification numbers, biometric data, race, date of birth, marital
status, religion, health information, insurance information,
employment information and financial information.
We typically collect, use, disclose or otherwise process your Personal
Data in accordance with this Privacy Notice with your consent, or in
compliance with applicable laws, such as where:
- It is required for us to comply with legal requirements;
- It is required for us to enter into or perform a contract with you; and/or
- For our legitimate interests or the legitimate interests of any other persons, including but not limited to for the purposes set forth in this Privacy Notice.
- COLLECTION OF PERSONAL DATA We collect (and may combine) Personal Data about you in the ways listed below:
- Complete a user profile or registration forms (such as your name, contact information and other identification information where needed);
- Provide information to assess your eligibility to provide services as LOLA's Merchant, school partner and/or third-party partner (such as your business license, SSM information, certification, school information and background check results);
- Interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
- Participate in contests or events organised by us (such as the pictures, audio, or videos you may submit, which may include images of yourself);
- Verify your identity through various means (such as social media logins, submission of images or independently verified payment card information);
- Fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation and income information); and
- Agree with in-app audio and/or video recording features.
- Your location information;
- Feedback, ratings and compliments;
- Transaction information (such as payment method);
- Information about how you interacted with our Apps, Website or Services (such as features used and content viewed);
- Device information (such as hardware model and serial number, IP addresses, file and app names and versions, GPS location, IMEI number, and advertising identifiers or any information that may indicate device or app modification).
- Referral programmes;
- Our business partners, such as childcare partners, kindergarten partners, payment providers, home childcare partners and transport partners;
- Insurance and financial providers;
- Credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
- Publicly available or governmental sources of data;
- When our users add you as an emergency contact;
- When our users add you as a recipient or beneficiary of any use of our Services;
- When you use our in-app chat/message; and
- Marketing services providers or partners.
- USE OF PERSONAL DATA LOLA may use your Personal Data for the following purposes set out in the list below (“Purposes”). Additionally, if you use LOLA in various capacities (for example, if you use multiple LOLA Services, or if you are both a LOLA partner and a user), we may link your Personal Data collected across your various capacities to facilitate our use of your Personal Data and your use of our Services and for the Purposes described below:
- Engage you to provide you with Services across our various business verticals;
- Create, administer and update your account;
- Process, manage or verify your eligibility for or application of Services, promotions, rewards and subscriptions with LOLA;
- Conduct due diligence checks and risk assessments / analysis;
- Verify your identity and age (where necessary);
- Validate your visit, application, enrolment and process payments;
- Offer, obtain, provide, facilitate or maintain insurance or financing solutions;
- Track the progress of your activities and detect abnormal activities variations;
- Personalise your Apps experience (such as to recommend products and services relevant to you, identify your preferences or otherwise personalise your experience with LOLA);
- Targeting offers and marketing deals to promote and sell goods and services provided directly by LOLA to you;
- Make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys;
- Perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
- Protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
- Enable communications between our users;
- Invite you to participate in our surveys and studies;
- Enable our partners to manage and allocate fleet resources; and
- Fulfill the services to you as a data processor, where you have provided consent to the data controller (i.e. the organisation you had purchased goods or services from, and for whom LOLA is providing services on behalf of or on behalf of LOLA itself) for such services to be rendered.
- Screening service provider and LOLA partners before enabling their use of our Services;
- Identifying unsafe behaviour such as invalidation data, misconduct and acceleration, and providing personalised feedback to LOLA partners;
- Verifying your identity when you log in to LOLA;
- Using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
- Sharing LOLA partners and users of LOLA partners' location and details when the emergency call, message, button or the “Security” feature is activated; and
- Monitoring compliance with our terms and conditions and policies.
- Investigate and address concerns;
- Monitor and improve our user support responses;
- Verifying your identity when you log in to LOLA;
- Respond to questions, comments and feedback; and
- Inform you about steps taken to resolve user support issues.
- Comply with court orders or other legal, governmental or regulatory requirements;
- Enforce our Merchant's and User Terms and Conditions or other agreements; and
- Protect our rights or property in the event of a claim or dispute.
- Send you special offers that may be of interest or relevance to you across all of LOLA's service offerings;
- Send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
- Notify, invite and manage your participation in our events or activities.
- DISCLOSURE OF PERSONAL DATA LOLA may disclose Personal Data to the following parties (including those within and outside Malaysia).
- If you are a user, LOLA may use and share your username, phone number, email address and locations with our LOLA partner fulfilling your Service request;
- If you are a LOLA Partners, we may share your Personal Data with your user or user or parents including your name and photo; your business information, model, number of certification, location and average rating;
- If you are a third party partner, we may share your Personal Data with your selected school partner/merchant and user, including your name and photo; your business information, model, location and average rating;
- If you use our in-app chat, we may share your mobile number and LOLA-registered name with the other parties to your chat.
- If you are a user LOLA, we may share your location and personal information and/or your name with third parties when you use the visit, apply and enroll feature or activate the Emergency Button.
- If you are a LOLA partner, we may disclose your business information number or other personal data to the insurance company and/or to your user for the purpose of submission of insurance claims.
- Payment processors and facilitators;
- Debt collectors;
- Credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
- Background check and anti-money laundering service providers;
- Cloud storage providers;
- Advertising and marketing partners and platform providers;
- Data analytics providers;
- Research partners, including those performing surveys or research projects in partnership with LOLA or on LOLA's behalf;
- Educational and training institute partners;
- Fleet and merchant partners;
- Insurance and financing partners;
- Third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
- Service providers who perform identity verification services; and
- LOLA solutions partners, vendors or third-party suppliers.
- If you requested a service through a LOLA partner or used a promotion provided by a LOLA partner, LOLA may share your Personal Data with that LOLA partner.
- If you have bookings or enrollment from our recommended partners to enroll your kids via LOLA, we may share relevant information (e.g. the status of your account, applicable incentives/promotions, your activity statistics) for collaborative efforts (e.g. create new incentives and benefits for you or improving supply of LOLA school partners).
- Where it is necessary to respond to an emergency that threatens the life, health or safety of a person;
- Where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community);
- Where it is necessary to comply with requirements of the enforcement agency, any authorities to whom LOLA is subject to or any orders of court;
- As is necessary or relevant in relation to any legal process; and/or
- Where required or authorised by law
- RETENTION OF PERSONAL DATA We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data we take steps to have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Privacy Notice, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.
- INTERNATIONAL TRANSFERS OF PERSONAL DATA Your Personal Data may be transferred from country, state and city (“Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”).
- COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS Cookies
- Provide the essential, basic functions of the use of our Websites, Services or Apps;
- Authenticate you, or remember your user preferences and settings;
- Delivering and measuring the effectiveness of advertising campaigns, such as by measuring the number of views or clickthroughs;
- Analyse site traffic and trends;
- Serve you relevant advertisements across other apps and websites owned by other companies (whether by us or by other advertisers); and
- Enhance user interface and experience by generally understanding the online behaviors and interests of users who interact with our Website, Services or Apps.
- PROTECTION OF PERSONAL DATA We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.
- YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA In accordance with applicable laws and regulations, you may be entitled to:
- Inquire about the processing of your Personal Data and be provided with a copy of it;
- In some cases, request the correction and/or deletion of your Personal Data;
- In some cases, request the restriction of or object to the processing of your Personal Data;
- Withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
- Request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and
- Complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment as a result of unlawful processing of your Personal Data.
- AMENDMENTS AND UPDATES
- ACCESS, CORRECTIONS AND QUERIES
You Provide Your Personal Data To Us
We collect your Personal Data when you provide it to us. For example, when you:
When Our Services Are Used
Personal Data may be collected through the normal operation or use of our Apps, Websites and Services. Some examples are:
From Other Sources
When we collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources. Such sources include:
Sensitive Personal Data
Some of the Personal Data that we collect may be sensitive in nature. This may include Personal Data pertaining to your race, national ID information, religious beliefs, background information (including financial and criminal records, where legally permissible), health data, disability, marital status and biometric data, as applicable.
We collect sensitive Personal Data only with your consent and/or in strict compliance with applicable laws. In the event that you are required to furnish any documentation or information to us for any Purpose which may contain such sensitive Personal Data (which is not required for that Purpose), you agree to redact such sensitive Personal Data before providing such documentation or information to us.
When You Provide Personal Data Of Other Individuals To Us
In some situations, you may provide Personal Data of other individuals (such as your spouse, family members, children or friends) to us. For example, you may add them as your emergency contact, when you use the in-app chat or messages or when you add them as recipients or beneficiaries of any use of our Services. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Privacy Notice.
Personal Data Of Minors
As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to LOLA. In the event that such Personal Data of a minor is disclosed to LOLA, you hereby consent to the processing of the minor's Personal Data and accept and agree to be bound by this Notice and take responsibility for his or her actions.
Providing Services And Features
Your Personal Data will be used to provide, personalise, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:
Safety And Security
We use your data to ensure the safety and security of our Services and all users. This includes:
User Support
We use Personal Data to resolve user support issues. For example, we may:
Research, Development and Security
We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services, and facilitate the development of insurance and finance solutions.
Legal Purposes
We may use the Personal Data we collect for legal purposes, such as to investigate and resolve claims or disputes, detect/prevent/prosecute crime, or as allowed or required by applicable law.
We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.
For example, we may use your Personal Data to:
Marketing And Promotions
We may use your Personal Data to send you marketing communications relating to customised products or services (that may be of interest or relevance based on your profile), or LOLA's partners', sponsors' and advertisers' products, services, events or promotions. For example, we may:
If you wish to unsubscribe to the receiving of such marketing communications, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our Apps settings. Please note that while you may opt-out of marketing or promotion communications, LOLA may still send you service-related messages (such as information on your transactions, rewards, etc.).
User Published Content
If you publish content (such as a review or comment) on LOLA's platform, it will be shown publicly along with your personal data (such as profile name, uploaded photo(s)), and other information you choose to include in your content.
These parties include:
Other Users
For example:
With Third Parties
With third parties related to your use of LOLA Services
For example:
With the owner of LOLA accounts that you may use
For example, your employer may receive business data (tagged as visit, enrol or waiting list) when you use your LOLA for Business account.
With holding company, subsidiaries and affiliates
We share Personal Data with our holding company, subsidiaries, associated companies, jointly controlled entities and affiliates. The companies in the LOLA group share resources, such as infrastructure and technology, with each other to provide you with a consistent, relevant and secure experience when you use our Services, and for the Purposes set out in this Privacy Notice.
For example, we do this to make your experience more seamless, such as by automatically completing your registration information from your use of one LOLA's Service when you sign up for a new LOLA Service.
With LOLA's service providers and business partners
We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers (including but not limited to professional and financial service providers) or business partners. This includes:
With our legal advisors and governmental authorities
We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:
Business transfers
We may share your Personal Data with other parties, in connection with any acquisitions, sales, mergers, joint ventures, consolidation, restructuring, financing or any other type of business transactions. Your Personal Data will however remain subject to our obligations made in any pre-existing Privacy Notice that you have agreed to.
When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.
Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.
LOLA, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (collectively, “Cookies”) in connection with your use of the Websites and Apps, which may be persistent or stored only during an individual session on your browsers or devices.
Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may be used for various purposes such as to:
Disabling the collection of cookies on our websites
You have the right to choose to disable, block or deactivate cookies. Please note that however refusal or removal of some cookies could affect the availability, functionality or use of our Website, Services or Apps.
You may adjust your internet browser settings to disable, block or deactivate cookies, delete your browsing history or clear the cache from your internet browser. The settings may be contained within the “History”, “Preferences”, “Settings” or “Privacy” section of your internet browsers, or you may otherwise consult the help section of your internet browser for more information.
Disabling the display of Targeted Ads through our App
We may facilitate the display of targeted advertising on other platforms, such as on other online platforms that you may be a user of. You may be able to limit our use of your Personal Data to display targeted advertisements on behalf of our advertisers, by adjusting your preference through the Apps. Depending on the type of phone and operating software that you are using, you may be granted the option to disable our use of mobile identifiers (such as Apple's IDFA or Google's GAID) and the ability to track you across apps and websites owned by other companies by adjusting the settings available on your mobile devices. Through adjusting the settings on your device, you can typically reset, delete, limit and/or otherwise restrict the use of such mobile identifiers.
Although we will not use your Personal Data to show you such targeted advertisements on other platforms, you may still see generic ads that appear relevant to you. This may be because we have engaged third party advertisers / platforms to display ads to users of specific attributes or demographic makeups who may find them relevant. You may be able to limit seeing these advertisements through managing your preferences on these platforms.
Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.
Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
However, choosing not to share your Personal Data with us, withdrawing your consent to our use of it or to your agreement with our Privacy Notice could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of the Apps or the Services.
After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.
We will screen and verify all requests beforehand. In order to verify your identity and/or authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.
LOLA may modify, update or amend the terms in this Privacy Notice at any time. Such amendments shall be notified to you through the Apps and/ or other appropriate means at least five (5) business days before the effective date. The updated version will be posted on the website www.lola.my. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Apps, Websites or Services, or continuing to communicate or engage with LOLA following the effective date of the modifications, updates or amendments to this Privacy Notice, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.
| Name: | Lola Digital Sdn Bhd (Attention: Legal Department) |
| Address: | Level 23, TRX Tower Spaces Exchange 106, 55188 Tun Razak Exchange Kuala Lumpur |
| Email: | legal@lola.my |
The original of this Notice is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.
