- The type of personal information we collect and how we collect it;
- How we use your personal information;
- The parties that we disclose the personal information to; and
- The choices we offer, including how to access and update your personal information.
1. Collection of Personal Information
1.1 What We Collect. The information which we collect includes any information which relates directly or indirectly to you and/or your transactions with us ("Personal Data"), including, but not limited to,
- (for individual) your name, date of birth, age, identification supporting documents (including NRIC or passport number), gender, nationality, race, preferred language, ethnic origin, education or other related qualifications, achievements, occupation, employer, former employer(s), photographs or other images, security recordings, voice recordings, cookies, temperature and location tracking/GPS information,
- (for corporate) name of company, company registration number, address, contact number, email address, details of the person in-charge, shareholders and/or directors, and travel document information;
- (current contact details) current private, home, correspondence and/or business address, telephone and/or mobile phone number(s), fax number and email address (es), and any other form of contact information that can allow us to reach you for communication purposes; and
- (compensation and/or financial standing information) income range, bank account details, transaction currency type, income tax file number, income tax EA Form, Employees Provident Fund (KWSP) yearly and/or current dated member’s statement, bank facilities offer letter(s), bank guarantee(s) details, letter or credit(s) information other relevant information in relation to your financial credit reporting standing check for credit assessment purposes.
1.3 Third Parties. We may also obtain your personal information from third-parties we deal with or who are connected with you and from such other sources where you have given your consent for the disclosure of information relating to you and/or where otherwise lawfully permitted.
1.4 Surveys and Contests. We may request Personal Information relating to you through surveys or contests which we conduct from time to time. Participation in these surveys or contests is completely voluntary and you have a choice as to whether or not to provide the Personal Information we have requested through the survey or contest. Personal Information collected through surveys will be used for the purposes of monitoring or improving the use and satisfaction of the Services. Personal Information collected through contests will be used to notify winners and award prizes.
1.6 You are responsible for informing us about any changes to your Personal Information to enable us to keep your data accurate and current. Kindly inform us as soon as practicable if there are any errors in your Personal Information or if there have been any changes to your personal information.
2. The Purpose
- to deliver notices, services or products to you or provide you with the products and services you request;
- to enter into the necessary agreement and/or contract in relation to the sale and supply of our products and/or services to you;
- to manage your account, including processing bills and providing notifications and our internal record management in the ordinary course of business;
- to communicate with you in general;
- to better understand your preferences;
- to better manage our business and your relationship with us;
- to respond to your questions, complaints,, feedbacks and comments;
- to allow us to contact you for customer service, if necessary;
- to measure interest in and improve our products, Services, and Website;
- to notify you about special offers, products and services that may be of interest to you;
- to customise your experience on our Website;
- to reward you as part of any reward and recognition programme you choose to join;
- to administer any rewards, offers, competitions, and promotions;
- to resolve disputes, collect fees, or troubleshoot problems;
- for post-sales services, such as after-sales maintenance (if any) or customer service related matters;
- to prevent potentially prohibited or illegal activities;
- for credit assessments and other background checks of users as we may determine to be necessary or appropriate;
- to provide you with information on our and/or third party products, services, offers and/or contests which may be of interest to you and in this respect, to contact you via SMS, phone or mobile device, email, fax, mail, websites or browsers, social media and/or any other appropriate communication channels;
- to notify you about benefits and changes to the features of products and services;
- to transfer or assign our rights, interests and obligations under any of your agreements with us (expressly or impliedly);
- to enforce and/or defend any of our rights;
- to record, maintain, keep and update details of all the customers;
- to enforce our Terms and Conditions when you make a booking with us; and
- as otherwise notified to you at the point of collection.
2.2 Payment Information. We use your debit card and/or credit card and such other payment information for the purpose of completing the booking(s) which you make with us.
2.3 Direct Marketing. We want to make it easy for you to take advantage of our offer and promotion. One way we do this is by sending marketing messages to you through email, SMS, fax or post that contain information about your interests and special offers which are available with us. Please note that you can withdraw your consent for us to send marketing messages to you. Please refer to Section 4 herein on how you may set your preferences in relation to such marketing messages.
2.4 Incomplete Personal Data. The failure to supply your complete Personal Information as may be needed, we may unable to provide you with the notices, services and/or products requested, unable to update you on our latest products, services, promotions, events and/or launches and may affect our ability to effect the necessary processes relating to the supply of our products and/or services.
3. With Whom We Share Your Personal Information
3.1 We will not disclose, expose, release, sell or share your Personal Information to third party and any other person, save for the following third parties, some of whom may be located overseas, and as a result, it shall be required for us to transfer your Personal Information overseas:
- for our business proposal or engagement with a 3rd party or 3rd party service provider (including but not limited to Google Analytics), which we engage amongst others for the performance of certain services on our behalf, such as web hosting services, data analysis, marketing, market research, and to otherwise provide you with customer service;
- any entities (in or outside of Malaysia) within the Companies (including but not limited to any related companies, subsidiaries, holding companies, associated companies and outsourcing partners);
- any joint venture with 3rd party or business partners or affiliates to jointly provide services or to organise any event;
- as required or permitted to do so by law;
- any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us;
- for protection against or preventing actual or potential fraud or unauthorised transactions;
- for the payment channel including banks and financial institutions for the purpose of assessing, verifying, effecting and facilitating payment in connection with the Services;
- any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us;
- for any data centre for data storage purposes and the record management;
- any party as required for our Services to protect the our rights including any associate law firms/ advisors, financial institution, professional advisors, or regulatory bodies;
- as required under our corporate proposals including but not limited to acquisition, merger and takeover, consolidation, and corporate reorganisation; and
- as required for our internal process or performing of obligations in connection with the Services.
3.2 We will only disclose your Personal Information with your consent, and will take reasonable steps to ensure that the third parties to whom we have disclosed your Personal Information are also legally bound to protect the privacy of your Personal Information. We rely on our legitimate business interest to prevent fraud and to protect our rights.
3.3 We may also disclose your Personal Information:
- Where disclosure is necessary to comply with applicable laws, governmental or other regulation or the requirements, orders, directions, instructions or notices of any regulatory authority or legal processes.
- When we believe it is appropriate to investigate, prevent or take action regarding illegal or suspected illegal activities; to protect and defend the rights and properties of the Companies.
4. Opt-in and Opt-out Policy
4.1 We offer you the ability to opt-in to or opt-out from (as the case may be) receiving marketing messages in relation to our products and services or the products and services of third parties by logging into your account on our member portal and changing your preferences, or emailing us at email@example.com.
4.2 While we respect your decision to opt out from receiving marketing information, you understand and accept that this may in some cases impact the availability of services and the quality of services that we may provide to you and may mean that the services provided to you (if possible at all) by us may not be customised for your use, may be less user-friendly and less efficient.
5. Terms Specific to Our Website
5.1 We automatically collect some information about you and your computer when you visit our website, such as your IP address, web browser software (such as Firefox, Internet Explorer or Safari), referring websites, and information about your online activities on our website, such as information viewed and purchases made. One of our goals in collecting this automatic information is to help customise your user experience.
5.3 In addition to the above cookies, we use local shared objects, also referred to as flash cookies, on our website. These are used to enhance your user experience, for example, by storing your user preferences and settings, such as your volume/mute settings, and in connection with animated content on our website. Local shared objects are similar to browser cookies, but can store data more complex than simple text. By themselves, they cannot do anything to or with the data on your computer. Like other cookies, they can only access personal identifiable information that you have provided on our website, and cannot be accessed by other websites.
5.4 Our website may also use web beacons (also known as clear gifs or pixel tags), which are tiny graphics with a unique identifier, similar in function to cookies, that are placed in the code of a web page. We use web beacons to monitor the traffic patterns of users from one page within our website to another, to deliver or communicate with cookies, to understand whether you have come to our website from an online advertisement displayed on a third party website, and to improve website performance. We may also allow our third party vendors to use web beacons to help us understand which emails have been opened by recipients and to track the visitor traffic and actions on our website. This helps us to measure the effectiveness of our content and other offerings.
6. Display of Tailored Advertising on Our Website
6.1 The advertisements you see on our website are served by us or by our service providers. But we also allow third parties to collect information about your activities on our website through cookies and other web technologies. These third parties include (1) business partners, who collect information when you view or interact with one of their advertisements on our website; and (2) advertising networks, which collect information about your interests when you view or interact with one of the advertisements they place on many different websites on the Internet. The information gathered by these third parties is used to make predictions about your characteristics, interests or preferences and to display advertisements on our website and across the internet tailored to your apparent interests. We do not permit these third parties to collect your Personal Information on our website, nor do we share with them your Personal Information.
7. Links to Third Party Websites
7.2 If you have any questions about our website, please email us at firstname.lastname@example.org
8. Terms Specific to Mobile Phone Devices
8.1 When you use a mobile device to access our website, we will collect, use, disclose, transfer and store Personal Information relating to you in the same way and for the same purposes as when you use a computer to access our website. We also collect, use, disclose, transfer and store the following additional information from your use of a mobile device to access our website, in order to optimise our website and minimise data usage:
- The areas of our website which you access through your mobile device, allowing us to refine the arrangement of our website content for compatibility with mobile devices. This information is collected anonymously and we cannot identify you from this.
9. Retention of Your Personal Information
9.2 We will also retain your personal data as may be required under the law or may be deemed necessary. We will always uphold and comply to the obligations as stated under the Act to store and care for your Personal Information.
10. How We Protect Your Personal Information
10.1 We want you to feel confident about using our Platforms and we are committed to protect the Personal Information we collect. We have implemented reasonable administrative, technical, and physical security procedures to help protect the Personal Information you provide to us. For example, only authorised employees are permitted to access your Personal Information and they may do so only for permitted business functions. Such authorised employees will be subjected to disciplinary action on any misuse or unauthorised use of your Personal Information. In addition, we use encryption when transmitting sensitive Personal Information (e.g., credit card details) between your system and ours, and we employ firewalls and intrusion detection systems to help prevent unauthorised persons from gaining access to your Personal Information.
11. Your Rights on Accessing and Correcting Personal Information
11.1 For your information, you have your privacy rights as follow:
- the right to access: you may request from us a copy of your Personal Data that is under the processing of our Website (a fee may be chargeable);
- the right of limitation on processing: you may write to us on how you would like to limit the processing of your Personal Data;
- the right of correction: you may submit a written request to us for the correction, alteration or update any of your Personal Data on our Website; and
- the right to withdraw consent: you may submit a written request to us for the withdraw consent, in full or in part, for us to process your personal data on our Website subject to applicable legal requirements/restrictions, our contractual obligations and a reasonable time frame.
12. Exercising Choices
12.2 Kindly note that in the event you decide to exercise any choices mentioned above, it may have an adverse effect on the products and services provided by us to you in which we shall not be liable for.
14. Contacting Us