COLLECTION OF PERSONAL DATA
The Personal Data that 91 APP may collect includes but is not limited to:
- Name, title, gender, address;
- Email address and/or online passwords;
- Personal identification and/or passport number;
- Telephone number;
- Records of communication with 91 APP;
- Responses to any market surveys and any contests conducted by 91 APP;
- Credit card or debit card information;
- Website usage information;
- Any other information about the User when the User signs up to our Services or website, and when the User uses the Services or website, as well as information related to how the User uses our Services or website; or
- Aggregate data on content the User engages with.
PURPOSE OF PERSONAL DATA COLLECTED
Personal Data that you provided to us voluntarily on our websites and the other related channels may be processed and/or disclosed to our Vendors (as hereinafter defined) for the following purposes (collectively, ‘Purposes’):
- To manage, verify and complete transactions with you or your transactions or communications with third parties via the relevant Services;
- To manage and verify your membership for our customer loyalty scheme (where applicable);
- To direct market our products and/or services to you;
- To understand and analyse our sales, your needs and preferences;
- To develop, enhance, market and provide products and services to meet your needs;
- To respond and deal with enquiries and other customer-care matters and otherwise communicate with you;
- To monitor or record phone calls and customer-facing interactions for quality assurance, training and performance evaluation and identity verification purposes;
- To manage payment, billing, and accounting matters;
- To send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services;
- To enforce our Terms of Service or any applicable end user license agreements;
- 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 our Services;
- To conduct research, analysis and development activities including but not limited to data analysis, surveys, product and service development and/or profiling, to analyse the way of your usage of our Services;
- For our credit control service and/or collection of debts due and owing to us;
- To comply with any regulatory, statutory or legal obligation imposed on us by any relevant authority;
By providing us with Personal Data, you agree that such Personal Data may be transferred, stored and/or processed in a country or territory outside Malaysia and you are deemed consented to any such transfer, storage and/or processing of your Personal Data outside Malaysia. We will however ensure that any party to whom we transfer your Personal Data outside Malaysia provides to such Personal Data a standard of protection at least comparable to the protection under the PDPA. This includes without limitation ensuring that any party coming into contract with the Personal Data outside Malaysia:
- Takes all appropriate measures to ensure such compliance by implementing such Data Standards as may be notified by us to them from time to time and appropriate technical and organisational measures and providing a standard of protection for the Personal Data that is comparable to the protection under the PDPA;
- Protects the Personal Data by making reasonable security arrangements to prevent unauthorised access, use, disclosure or modification.
USAGE AND DISCLOSURE
In relation to our usage of your Personal Data for the Purposes or Additional Purposes, we may disclose your Personal Data to our:
- employees, consultants, temporary workers;
- 91APP Marketplace sellers, who supply and deliver the products or services you ordered through the Website or Apps;
- payment processors, who process your payment on the Website and the Apps;
- logistics providers, such as courier services which will deliver your order to you;
- business partners who separately maintain an account with you for loyalty or point redemption programs;
- business partners or vendors in connection with the processing of any promotion, event or service organised by us;
- professional advisers and consultants;
- agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimization, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of your Personal Data; and
- any other party whom you authorize us to disclose your Personal Data to.
91 APP only discloses Personal Data including but not limited to the following:
- For the primary Purposes for which it was collected; or
- For purposes that a reasonable person will consider appropriate in the circumstances; or
- Where permitted under the PDPA or other applicable law or if required by law.
We do our best to minimize the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose.
RETENTION OF PERSONAL DATA
91 APP will retain your Personal Data for as long as you subscribe, use, register with our Services, purchase or use our products or services and such data is necessarily required or relevant for business or legal purposes.
Your Personal Data shall be stored either in hard copies in our offices or in servers located in Malaysia. It may be necessary to transfer your Personal Data to third party services providers based/located outside Malaysia. By continuing to use the Websites, products and/or Services of 91 APP, you hereby consent to such transfer.
Any Personal Data supplied by you will be retained by us as long as necessary for the fulfilment of the Purposes or as required to satisfy legal regulatory, accounting requirements or to protect our interests. We do not offer any online facilities for you to delete your Personal Data held by us, save and except as provided in paragraph (7) here of.
When Personal Data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such Personal Data is destroyed, permanently deleted or anonymised.
ONLINE TRACKING AND ADVERTISING
Similar with most websites, we may record anonymous information such as IP addresses (where not used to identify a specific individual), time, date, referring URL, pages accessed and documents downloaded, duration of stay or use, type of browser and operating system when you visit our websites. Such information is collected on an aggregate and anonymous basis.
Cookies. Cookies are small files that are placed on your computer when you visit the websites. Cookies may be used to store a unique identification number tied to your computer or device so that you can recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes. For example:
- Cookies can remember your sign in credentials so you do not have to enter those credentials each time you visit website.
- Cookies can help us and the Authorized Third Parties understand which parts of our Websites are the most popular because they help us see which pages and features users access and how much time they spend on the pages. By studying this kind of information, we are able to adapt our Websites better and able to provide you with a better experience.
- Cookies help us and the Authorized Third Parties understand which advertisements you have seen so that you don’t receive the same advertisement each time you visit our Websites.
You may adjust your internet browser to disable cookies. If cookies are disabled, you may still use our Websites but may be limited to certain features.
By accessing and using our Websites and Services, you are deemed consented to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consented to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents.
We will also provide reasonable security arrangements protocols to ensure that your Personal Data is adequately protected and secured. This includes putting in place reasonable measures to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage or alteration of your Personal Data.
OPT-OUT, WITHDRAWAL OF CONSENT
- Opting out or Withdrawing Consent
You may withdraw your consent to our continued use and disclosure of your Personal Data or seek access to your Personal Data (to a reasonable extent and as permitted by the PDPA) at any time by writing to the officer at firstname.lastname@example.org.
In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you and that we may cease such provision accordingly without any liability. We are endeavour to update our records timeously in a reasonable period for any request for consent withdrawal to be processed and reflected in our systems. We will then cease to collect, use or disclose your Personal Data upon such withdrawal unless otherwise permitted or required by the PDPA or any other applicable laws and regulation.
- Right to Access to Personal Data and/or to correct the Personal Data
We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organization is accurate and complete. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of any form changes made by you.
Subject to certain exemptions under the PDPA, 91 APP will grant access to and correct Personal Data as requested by you. If we hold Personal Data about you and you are able to establish that the Personal Data is not accurate, complete and up to date. We may provide reasons for any denial of access or a refusal to correct Personal Data.
Your request to access or amending your Personal Data will be actioned as soon as reasonably possible from the time the access request is received by writing to the officer at email@example.com.
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