1.0 Your Consent to this Privacy Notice
1.1 The Personal Data Protection Act 2010 (the “Act”), which regulates the processing of personal data in commercial transactions, applies to Shop Hubby Sdn. Bhd. (Company No. 1269451-H) (“our”, “us” or “we”). For the purpose of this written notice (“Privacy Notice”), the terms “personal data” and “processing” shall have the same meaning as prescribed in the Act. We value your privacy and strive to protect your personal data in compliance with the laws of Malaysia. The Company will only collect and use your personal data in accordance with the Act, this Privacy Notice and/or the privacy terms in any agreement(s) that you may have or will enter into with us.
This Privacy Notice explains:
(a) What kind of personal data we collect and how we collect it;
(b) How we use your personal data;
(c) The parties that we disclose the personal data to; and
(d) The choices we offer, including how to access and update your personal data.
1.2 By providing to us your personal data, you hereby consent to the processing of your personal data in accordance with this Privacy Notice.
1.3 If you are a corporation supplying personal data of your directors, shareholders and/or officers to us, please do ensure that you have duly obtained their consent and bring this Privacy Notice to the attention of your directors, shareholders and/or officers whose personal data you are supplying/have been supplied to us.
2.0 Collection of Your Personal Data
2.1 In order to enable us to deal with your inquiries, open and operate an account for you and/or to generally provide you with our advertisement of products and services, we may need to and/or may be required to collect, record, hold, use, disclose and store (i.e. “process”) personal data and financial information about you, including but not limited to personal data –
(a) to establish your personal identification and background; and/or
(b) to establish your financial standing and creditworthiness (where required).
2.2 We may obtain this information from yourself and from a variety of sources, including but not limited to –
(a) through your relationship with us, for example information provided by you while registering an account with us, when taking part in our customer surveys and promotion activities;
(b) through your verbal and written communications with us;
(c) from third parties connected with you subject to your prior consent;
(d) from an analysis of the way you use and manage your account with us;
(e) from any interactions between our co-working space members through community platforms including but not limited to notice board, social media; and/or
(f) from such other sources in respect of which you have given your consent to disclose information relating to you and/or where not otherwise restricted.
3.0 Use and Sharing of Your Personal Data
3.1 Other than as stated above, we may use your personal data for one or more of the following purposes:
(a) to assess your registration of an account with us;
(b) to manage and maintain your account with us;
(c) to manage our business and your relationship with us;
(d) to provide you with information on 3rd party products, services and offers which may be of interest to you;
(e) to improve our designated website and mobile application;
(f) to notify you about benefits and changes to the featured products and services by our collaborating merchants;
(g) to administer offers and promotions;
(h) to respond to your enquiries and complaints;
(i) to improve the quality, efficiency and utilization of our website and mobile application;
(j) to update, consolidate and improve the accuracy of our records;
(k) to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
(l) to conduct research for analytical purposes including but not limited to data mining and analysis of your transactions with us;
(m) to meet the disclosure requirements of any law binding on us;
(n) for audit, compliance and risk management purposes;
(o) to assess financial and insurance risks;
(p) to transfer or assign our rights, interests and obligations under any of your agreement(s) with us;
(q) to protect or enforce our rights to recover any debt owing to us;
(r) for crime detection, prevention and prosecution; and/or
(s) for any other purpose that is required or permitted by any law, regulations and/or guidelines.
4.0 Disclosure Of Your Personal Data
4.1 We may disclose your personal data (to the extent necessary) to the following third parties –
(a) companies and/or organisations that act as our strategic partners, agents, professional advisers and/or any other parties that we may have business or dealings with;
(b) companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions that you have requested;
(c) companies and/or organisations that assist us in providing value added services that you have requested;
(d) your advisers (including but not limited to accountants, valuers, adjustors, auditors, lawyers, financial advisers or other professional advisers) where authorised by you;
(e) any person notified by you as authorised to give instructions or to use the account registered by you on your behalf;
(f) any financial institutions, merchants, VISA International Services Association, MasterCard International Incorporated and other card associations in relation to any credit card and/or debit card issued to you, if applicable; and/or
(g) any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us,
4.2 All parties mentioned in the clause above may in turn disclose your personal data to companies within their group of companies, their affiliates and directors, shareholders, employees of such companies and affiliates, their professional advisers, service providers, strategic partners, regulators and other parties on a “need to know basis” who or which may have business or dealings with them.
4.3 The above shall be subject at all times to any applicable laws (including regulations, standards. guidelines and/or obligations) whether in or outside Malaysia).
5.0 Disclosure for Marketing Purposes
5.1 Our individual entities may contact you about services and offers, which we believe may be of interest to you or benefit you financially.
5.2 You may tell us at any time if you do not wish to receive marketing communications from us or from any of our individual entities by writing to us. Your latest written instructions to us will prevail.
5.3 As for our collaborating merchants or strategic partners, we will only contact you for advertising and marketing purposes of your services/products if required.
6.0 Security of Your Personal Data
6.1 We shall take appropriate measures to protect your personal data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction when processing your personal data except in any of the following situations:
(a) where you have given permission;
(b) where we are required or permitted to do so by law;
(c) where required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over us;
(d) where we may transfer rights and obligations under this agreement; and/or
(e) where we are required to meet our obligations to any relevant regulatory authority.
We shall not accept responsibility for any unauthorised access or interception or loss of personal data that is beyond our reasonable control.
If any part of the mobile application links you to other websites, those websites do not operate under this Privacy Notice and we do not accept any responsibility or liability arising from those websites. We suggest you to read and understand those websites’ privacy notice/policy before you provide your personal data to those websites.
7.0 Data Integrity
7.1 All personal data shall be provided by you voluntarily but however if you do not provide or consent to us processing your personal data, you may not be able to use our designated website or mobile application.
7.2 Personal data supplied by you to us shall be accurate, complete, and not misleading. You shall notify us in writing any changes to the personal data supplied by you to us to ensure the personal data is kept up-to-date.
8.0 Rights to Access
8.1 Subject to any exceptions under the applicable laws, you may at any time request for access to and for correction of your personal data kept by us and contact us with any inquiry or complaint in respect of your personal data as follows –
(a) You may have access to your personal data by making a request via our designated website or mobile application;
(b) We may withhold your access to your personal data in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request;
(c) Where your data access request is successful and you are of the opinion that such personal data held by us is inaccurate, incomplete, misleading or where relevant, not up-to-date, you may make a request to correct such personal data;
(d) You can also assist us to keep your personal data (such as your current mailing address) up to date, as it will enable us to serve you better;
(e) In the event you wish to correct / update your personal data previously provided to us, please write in or notify us at [?].
9.0 Right to Limit Processing Your Personal Data
9.1 You may notify us in writing to withdraw your consent to or limit the processing of your personal data including the extent of the personal data and/or the purposes for which it is being processed in accordance with Clause 3 above and we shall upon receiving your written notice cease or limit the processing of the personal data accordingly.
You may exercise your choice in respect of the disclosure, retention and use of your personal data by contacting us at -
Contact Person : [?]
Address : [?]
Tel : [?]
Email : [?]
10.0 Retention of Your Personal Data
We shall not retain your personal data longer than is necessary for the fulfilment of the purposes as described in Clause 3 above. We shall take reasonable steps to ensure that your personal data is destroyed or permanently deleted if it is no longer required for the purpose for which it was to be processed.
11.0 Enquiries or Complaints
11.1 Should you have any query, concerns or complaints in relation to this Privacy Notice or how we handle your personal data, kindly contact any of the abovenamed persons.
12.0 Third Party
12.1 We may request your assistance to procure the consent of third parties whose personal data is provided by you to us and you hereby agree to use your best endeavour to do so.
13.0 Changes to the Privacy Notice
13.1 We hereby reserve the right to modify and change this Privacy Notice as and when required. Any changes to this Privacy Notice will be published on our designated website and mobile application. You should check this Privacy Notice each time you access to our designated website and mobile application so as to be aware of the most recent applicable version of the Privacy Notice.