1. INTRODUCTION
1.1 Welcome to the SFD Instant Delivery Partner Application (“Delivery Partner App”) run by Qualitrans Courier and Manpower Services, Inc and its affiliates (individually and collectively, the "Company", "we", "us" or "our"). The Company takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our Delivery Partner App, comprising the platforms and software, including the driver mobile device application, we use to facilitate our delivery services (the "Platform"). User refers to any of our third-party service provider delivery partners who provide delivery services to Customers (individually and collectively, “Users”, “you” or “your”). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.
1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number, contact information and/or vehicle information.
1.3 By using the Platform, registering for an account with us, installing, interacting with and/or accessing the Platform, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OR ACCESS THE PLATFORM. If we change our Privacy Policy, we will notify you including by posting those changes or the amended Privacy Policy on the Platform. We reserve the right to amend this Privacy Policy at any time. To the fullest extent permissible under applicable law, your continued use of the Platform shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.
1.4 This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.
2. WHEN WILL THE COMPANY COLLECT PERSONAL DATA?
2.1 We will/may collect personal data about you:
when you register and/or are accredited to be our delivery partner;
when you agree to, accept any of our terms and/or conditions and/or enter into agreement(s) with us regardless of the form and format;
when you register and/or use the Platform, or open an account with us;
when you submit and/or provide documentation or information in respect of your interactions with us, or when you access and/or use the Platform;
when you interact with us and/or our personnel, such as via telephone calls (which may be recorded), online chats, letters, fax, face-to-face meetings, social media platforms and emails;
when you use the Platform or interact with us via the Platform. This includes, without limitation, through cookies which we may deploy when you interact with the Platform;
when you grant permissions on your device to share information with the Platform;
when you carry out transactions, and/or services through the Platform;
when you provide us with feedback or complaints; and/or
when you submit your personal data to us for any reasons.
The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.
2.2 We may collect personal data about you from you, our affiliates, third parties, and from other sources, including without limitation business partners (such as logistics or payment service providers), credit bureaus or scoring agencies, marketing services providers or partners, referral or loyalty programs, other users of the Platform, publicly available and/or governmental sources of data.
2.3 In some situations, you may provide personal data of other individuals to us (such as your family members or friends or persons in your contact list). If you provide us with their personal data, you represent and warrant that you have obtained their consent for their personal data to be processed in accordance with this Policy.
3. WHAT PERSONAL DATA WILL THE COMPANY COLLECT?
3.1 The personal data that the Company may collect includes but is not limited to:
name;
email address;
date of birth;
addresses;
contact details of yourself and your next-of-kin (whose details you have consent to share with us for emergency purposes);
bank account and payment related information;
telephone number;
gender;
vehicle number;
vehicle registration details;
driver’s licence;
vehicle insurance;
government registration documents (if applicable);
information sent by or associated with the device(s) used to access the Platform;
information about your network, including your contact list when you share permissions on your device, and the people and accounts you interact with;
information about your delivery status;
photographs or audio or video recordings;
government issued identification or other information required for our due diligence, know your customer, identity verification, and/or fraud prevention purposes;
your communication preferences and history of communications with us and other third parties;
usage and transaction data (including aggregate data) from your interaction with the Platform;
location data;
any other information about you when you use, access and/or interact with the Platform; and
any other information about you and/or provided by you for any reasons.
3.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify any information provided by you.
3.3 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. Further information on opting out can be found in the section below entitled "How can you withdraw consent, remove, request access to or modify information you have provided to us?". Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Platform. For example, opting out of the collection of location information will cause its location-based features to be disabled.
4. COLLECTION OF OTHER DATA
4.1 As with most websites, mobile applications and online systems, your device sends information which may include data about you that gets logged by a web server when you interact with the Platform. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of computer/mobile device, the characteristics of the computer/mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), information in relation to your access and/or interaction with the Platform and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the Platform remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand the Platform is being used.
4.2 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more Purposes including, without limitation, to offer services to our customers, for us to ensure that services are provided in a timely manner to our customers or to resolve any issues and/or disputes that may arise from the services.
5. COOKIES
5.1 We or third parties as authorized by us may from time-to-time use "cookies" or other features to allow us or third parties to collect or share information in connection with your interaction and/or use of the Platform. These features help us improve the Platform and help us offer new services and features through the Platform. “Cookies” are identifiers that are stored on your computer and/or mobile device that record data about computer or device, how and when the Platform is used or accessed, by how many people and other activities within the Platform. We may link cookie information to personal data.
5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this you may not be able to use the full functionality of the Platform.
6. HOW DO WE USE THE INFORMATION YOU PROVIDE US?
6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
to consider and/or process your engagement or transaction with us or your transactions or communications with third parties in connection with your use of and/or access to the Platform;
to provide and manage your engagement, user account, and onboarding process;
for identification, verification, due diligence, driver licence and insurance checks or know your customer purposes to ensure that you are legally compliant when providing the delivery services to Customers;
to provide you with access to and use of the Platform for delivery services;
to manage, operate, provide, process and/or administer delivery operations (including delivery status, tips, payment administration, order-specific information, and to analyse and improve efficiency of our delivery services), transactions, interactions and/or communications for and with customers and/or third parties via the Platform;
to manage, operate, provide and/or administer your use of and/or access to the Platform (including, without limitation, remembering your preference), as well as your user account;
to respond to, process, deal with, fulfil, complete a transaction and/or administer delivery services for and with customers and/or third parties and notify you of Platform issues and unusual account actions;
to administer and develop driver events and other initiatives including referral programs;
to enforce our rights under any agreement(s), contract(s) and/or any applicable end user license agreement(s);
to protect personal safety and the rights, property or safety of others;
to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of the Platform;
to ensure the integrity and security of the Platform;
to deal with or facilitate customer service, deal with or respond to any enquiries;
to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your use of the Platform, such as but not limited to communicating administrative information to you relating to the Platform, opportunities to provide delivery services and referral opportunities. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use the Platform, to improve the Platform and/or to enhance user experience;
to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with the Platform;
to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or where we have a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on the Company or on its related corporations or affiliates (including, where applicable, the display of your name, contact details and business details);
to manage, maintain and/or enforce our rights in relation to applicable agreement(s), contract(s) and/or terms and/or conditions entered into, as agreed or accepted by you with us;
to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
to audit the Platform or the Company’s business;
to prevent or investigate any actual or suspected violations, fraud, complaints, unlawful activity, omission or misconduct, whether relating to your use of the Platform or any other matter arising from applicable agreement(s), contract(s) and/or term(s) and/or condition(s) entered into, as agreed or accepted by you with us;
to respond to any threatened or actual claims asserted against the Company or other claim that third parties’ rights have been violated;
to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves the Company as a participant or involves only a related corporation or affiliate of the Company as a participant or involves the Company and/or any one or more of the Company's related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
to conduct automated decision-making processes in accordance with any of the above purposes; and/or
any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”).
6.2 You acknowledge, consent and agree that the Company may access, preserve and disclose your information if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over the Company or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over the Company; (c) enforce the rights of the Company or this Privacy Policy; (d) respond to any threatened or actual claims asserted against the Company or other claim that the rights of third parties have been violated; (e) respond to your requests or enquiries; or (f) protect the rights, property or personal safety of the Company, its users and/or the public.
6.3 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.
7. HOW DOES THE COMPANY PROTECT AND RETAIN INFORMATION?
7.1 We implement a variety of security measures and strive to ensure the security of your personal data on our systems. Users’ personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security.
7.2 We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such personal data. If you cease using the Platform, or your permission to use the Platform is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.
8. DOES THE COMPANY DISCLOSE THE INFORMATION IT COLLECTS TO OUTSIDE PARTIES?
8.1 In conducting our business, we will/may need to use, process, disclose and/or transfer your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, which may be located in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. We endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed for the above-mentioned Purposes. Such third parties include, without limitation:
our subsidiaries, affiliates and related corporations;
contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those parties which provide administrative or other services to us such as mailing houses, other logistics service providers, advertising and marketing partners, telecommunication companies, information technology companies, insurance companies and data centres;
anyone who refers you as a delivery partner (only in relation to the progress/status of their referral incentive, if any);
governmental or regulatory authorities having jurisdiction over the Company or as otherwise permitted under Section 6.2;
a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by the Company about our Users is among the assets transferred; or to a counterparty in a business asset transaction that the Company or any of its affiliates or related corporations is involved in; and
third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.
8.2 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply. Consistent with the foregoing and subject to applicable law, we may use your personal data for recognized legal grounds including to comply with our legal obligations, to enforce our rights, to perform our contract with you or our service provider where applicable, to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights, or where necessary in connection with a legal claim.
8.3 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.
8.4 As set forth above, Users (including any employees, agents, representatives, or any other person acting for such User or on such User’s behalf) in possession of another User’s personal data through the use of the Platform (the “Receiving Party”) hereby agree that, they will (i) comply with all applicable Privacy Laws with respect to any such data, including any collection, processing, storage or transfer of such data; (ii) allow the Company or the User whose personal data the Receiving Party has collected (the “Disclosing Party”) to remove his or her data so collected from the Receiving Party’s database; and (iii) allow the Company or the Disclosing Party to review what information has been collected about them by the Receiving Party, in each case of (ii) and (iii) above, in compliance with and where required by applicable laws.
9. INFORMATION ON CHILDREN
9.1 The Platform is not intended for children under the age of 18. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 18 nor is any part of the Platform directed to children under the age of 18. As a parent or legal guardian, please do not allow such children under your care to submit personal data to the Company. In the event that personal data of a child under the age of 18 in your care is disclosed to the Company, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by this Policy on behalf of such child. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 18.
10. INFORMATION COLLECTED BY THIRD PARTIES
10.1 The Platform uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyse how Users use the Platform. The information generated by the cookie about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Platform, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
10.2 We, and third parties, may from time to time make software applications downloads available for your use via the Platform. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your device’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, if applicable, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by the Company. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.
11. DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES
11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. All personal data or sensitive information you supply is encrypted into our databases on a secure server, to be only accessed as stated above.
11.2 In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Platform. We may also participate in co-branding and other relationships to offer logistics, delivery, e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our Platform) may not be received by us.
11.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).
12. WILL THE COMPANY TRANSFER YOUR INFORMATION OVERSEAS?
12.1 Your personal data and/or information may be transferred to, stored or processed outside of your country for one or more of the Purposes. The Company will only transfer your information overseas in accordance with Privacy Laws.
13. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS TO OR CORRECT INFORMATION YOU HAVE PROVIDED TO US?
13.1 Withdrawing Consent
13.1.1 You may withdraw your consent for the collection, use and/or disclosure and/or request deletion of your personal data in our possession or under our control by sending an email to our Personal Data Protection Officer at dpo.ph@spxexpress.com, and we will process such requests in accordance with this Privacy Policy and our obligations under the Privacy Laws and other applicable law. However, your withdrawal of consent may mean that we will not be able to continue providing the Platform to you and we may need to cancel your existing relationship, deployment, agreement and/or the contract you have with us where applicable.
13.2 Requesting Access to or Correction of Personal Data
13.2.1 If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page on the Platform. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to our Personal Data Protection Officer at dpo.ph@spxexpress.com
13.2.2 We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
13.2.3 We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances.
14. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
14.1 If you have any questions or concerns about our privacy practices, we welcome you to contact us by e-mail at dpo.ph@spxexpress.com.
Last modified: 14 October 2025