1. INTRODUCTION

1.1 This is the privacy policy (“Privacy Policy”) of semua2ada.com(“semua2ada.com”, “we”, “us”, or “our”). semua2ada.com respects the privacy of individuals with regards to personal data and are committed to the protection of your personal data and compliance of all applicable personal data protection laws and regulations in Malaysia.

1.2 This Privacy Policy applies to personal information about you and/or individuals provided by you, possessed or held by us or that we obtain about you, whether now or in future. This Privacy Policy shall form an integral part of the contract between you and semua2ada.com upon your continuation of use of semua2ada.com’s website (“Website”) and should be read together with our Terms and Conditions of use. Any capitalised terms if not expressly defined herein shall have the same meaning ascribed to them in the Terms and Conditions.

1.3 We will only process your Personal Data (as herein defined) in accordance with the Personal Data Protection Act 2010, the applicable regulations, guidelines, orders made under the Personal Data Protection Act 2010 and any statutory amendments or re-enactments made of the Personal Data Protection Act 2010 from time to time (collectively referred to as the “PDPA”) as well as this Privacy Policy.

1.4 The PDPA requires us to inform you of your rights in respect of your Personal Data that is being processed or that is to be collected and further processed by us, the purposes for the data processing, the parties we disclose or have disclosed the data to and the choices available to you including how to access and correct such Personal Data. The PDPA also requires us to obtain your consent to the processing of your Personal Data. As such, we are committed to protecting and safeguarding your Personal Data.

1.5 By providing your Personal Data to semua2ada.com and/or continuing access and use to this Website and semua2ada.com’s mobile applications, you declare that you have read, understood and accepted this Privacy Policy and consented to us processing your Personal Data in accordance with the manner as stipulated in this Privacy Policy. If you provide personal data of third parties to semua2ada.com, you warrant and represent to semua2ada.com that you have obtained the required consent of the third parties for the processing of the relevant personal data by semua2ada.com in the manner set out herein.

1.6 semua2ada.com reserves the right, at its discretion, to change, vary, modify, add, remove, update and/or amend this Privacy Policy from time to time with reasonable prior notice to you. We will notify you of any amendments via announcements on the Website or other appropriate means. Please check the Website periodically for any changes or amendments to this Privacy Policy. Any changes and/or amendments to this Privacy Policy will be effective immediately upon posting of the revised Privacy Policy. Your continued use of the services and/or access to the Website after the posting of such changes and/or amendments constitute your binding acceptance of such changes and/or amendments to this Privacy Policy.

1.7 If you do not agree to this Privacy Policy or any amendments to this Privacy Policy, we may not be able to render all services to you and you may be required to terminate your relevant agreement with us and/or stop accessing or using this Website.
1.8 This Privacy Policy does not apply to the activities and/or practices of third parties that we do not own or control, including but not limited to any third-party websites, services, and applications that you elect to access through our Website.

2. COLLECTION OF PERSONAL DATA

2.1 The term “Personal Data” means any information in our possession or control that relates directly or indirectly to an individual to the extent that the individual can be identified or are identifiable from that and other information in our possession which shall include without limitation your name, address, telephone number, identification/passport number, date of birth, photograph, email address, household information, bank account details, debit and/or credit card details, and such other information as we deem necessary or appropriate from time to time in connection with your participation in the products and/or services offered/rendered by us. The types of Personal Data collected depend on the purpose of collection. We may “process” your Personal Data by way of collecting, recording, holding, storing, using and/or disclosing it.

2.2 Your Personal Data may be collected from you, either online or offline, during your course of dealings with us in any way or manner including pursuant to any transactions and/or communications made from/with us. We may also collect your Personal Data from a variety of sources, including without limitation, at any events, seminars, conferences, workshops, road shows, customer satisfaction surveys organised and/or sponsored by us, from publicly available sources as well as Personal Data which are provided or made available by any third parties, credit reference bodies, regulatory and law enforcement authorities, for reasons including delivery of our services, performance of conditions of agreements and/or to comply with our legal and regulatory obligations.

3. USE OF YOUR PERSONAL DATA

The Personal Data collected by semua2ada.com may be processed and used, inter alia, for the following purpose*:-

(a) to communicate with you and/or your company;
(b) to establish your identity and background;
(c) to maintain and improve customer relationship;
(d) to assess, process and provide products, services and/or facilities to you;
(e) to respond to your enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings with us;
(f) to provide you with information and/or updates on our activities, products, services, upcoming promotions and/or events offered, organised, managed, facilitated, provided, sponsored and/or participated by us and/or selected third parties which may be of interest to you from time to time;
(g) to conduct research, study, assessment, survey and/or prepare reports/statistics for purpose of semua2ada.com’s business activities;
(h) for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels, in accordance with their consent;
(i) to facilitate your participation in, and our administration of, any events including contests, promotions or campaigns;
(j) to maintain and update internal record keeping;
(k) for internal administrative purposes;
(l) to send you invitation to join our events and promotions and product launch events;
(m) to monitor, review and improve our events and promotions, products and/or services;
(n) to process and analyse your Personal Data either individually or collectively with other individuals;
(o) to share any of your Personal Data with the auditor for our internal audit and reporting purposes;
(p) for audit, risk management and security purposes;
(q) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
(r) for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
(s) to comply with any legal or regulatory requirements applicable to semua2ada.com, and to make disclosure under the requirements of any law, regulation, direction, court order, by-law, guideline, circular or code applicable to semua2ada.com;
(t) to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations; and/or
(u) other lawful business activities of semua2ada.com.

4. DISCLOSURE OF PERSONAL DATA

The personal data provided by you to semua2ada.com may, if required, be disclosed to the following third parties:
(a) semua2ada.com’s shareholders and any of its affiliated companies within the group;
(b) Regulatory bodies, government bodies or other authorities if required or authorized to do so to discharge any regulatory function under any law or in relation to any order or judgment of a court;
(c) Parties to whom we have outsourced the performance of operational functions to assist us in processing, administering and/or otherwise fulfilling transactions that you have requested for;
(d) Selected parties within or outside Malaysia including strategic partners that work with semua2ada.com in connection with our business activities or any event or programme;
(e) Authorised agents, contractors and/or third-party service or product providers as may be determined by semua2ada.com to be necessary or appropriate;
(f) External professional advisors and auditors;
(g) Financial institutions for purposes of facilitating payments, if any, and/or maintaining financial records in connection with the business or contract relationship between semua2ada.com and you and/or your company;

5. ACCURACY OF YOUR PERSONAL DATA

You hereby warrant and declare that all your Personal Data submitted or to be submitted to semua2ada.com are accurate, not misleading, updated and complete in all respects for purposes of acquiring or using the relevant products, services and/or facilities, and you have not withheld any Personal Data which may be material in any respect and that we are authorised to assume the accuracy of the Personal Data given by you when processing such Personal Data. You will promptly update us as and when such Personal Data provided earlier to us becomes inaccurate, incomplete, misleading, outdated or changes in any way whatsoever by contacting us at the contact details below. Where specified, it is obligatory to provide your Personal Data to us to enable us to process your application for our products or services. Should you decline to provide such obligatory Personal Data, semua2ada.com may not be able to process your application and/or request or provide you with our products or services.

6.YOUR RIGHTS

Your rights to request for access, update, correct or delete your Personal Data is subject to the exceptions provided under the PDPA and/or any other applicable laws and regulations. A prescribed fee may be applicable to cover the administration costs involved in processing your request to access your Personal Data. However, we have the right to refuse your request to access and/or correct your Personal Data for the reasons permitted under the law. For example, in such cases where the expense of providing access to you is disproportionate to the risks to your privacy, or where the rights of others may also be violated, amongst other reasons.
You have the right at any time to request us to limit the processing and use of your Personal Data (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes).

7. RETENTION OF YOUR PERSONAL DATA

semua2ada.com will retain your Personal Data in compliance with this Privacy Policy and/or the terms and conditions of your agreement(s) with semua2ada.com for the duration of your relationship with us, for such period as may be necessary to protect the interests of semua2ada.com and/or its stakeholders as may be deemed necessary, where otherwise required by the law and/or where required by semua2ada.com’s relevant policies.

8. SECURITY OF YOUR PERSONAL DATA

We endeavour to take all reasonable steps to protect your Personal Data and keep your Personal Data secured. Our site may link to other websites and we are not responsible for their data policies, procedures or their content. We cannot and do not accept responsibility for any unauthorised access or interception or loss of Personal Data that is beyond our reasonable control.

9. TRANSFER OF YOUR PERSONAL DATA

It may be necessary for us to transfer your Personal Data to a third-party service or product providers within or outside Malaysia. You consent to us transferring your Personal Data outside Malaysia in these instances. We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of Malaysia shall not use your Personal Data other than for the intended purposes and to adequately protect the confidentiality and privacy of your Personal Data.

10. PERSONAL DATA FROM MINORS AND OTHER INDIVIDUALS

To the extent that you have provided (or will provide) Personal Data about your family, spouse and/or other dependents, you confirm that you have explained to them that their Personal Data will be provided to, and processed by, us and you represent and warrant that you have obtained their consent to the processing (including disclosure and transfer) of their Personal Data in accordance with this Privacy Policy. In respect of minors (i.e. individuals under 18 years of age) or individuals not legally competent to give consent, you confirm that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their Personal Data in accordance with this Privacy Policy.

11. CONTACT DETAILS

If you have any questions about this Privacy Policy, or have any further queries, or would like to make a complaint or data access or correction request in respect of your Personal Data, you may contact us at the contact details below:

semua2ada.com,