1. Introduction

1.1 This Privacy Policy and Personal Data Notice outlines Malbro Sdn. Bhd. policy and responsibilities in relation to the collection, use, process and disclosure of your personal information.

1.2 By continuing to access and/or use this website(s) or mobile application, you signify that you have read, understood and agreed to be bound by the terms and conditions of this Privacy Policy and Personal Data Notice statement or subsequent amendment thereto in respect of Malbro ’s collection, use, process and disclosure of your personal information.

2. Protection of Personal Information

We are committed to protecting the privacy your personal information and in compliance with the Malaysia Personal Data Protection Act 2010 (“PDPA”).

3. What is Personal Information?

Personal Information may include information concerning name as per identity card, preferred name, personal identification number, age, contact number, residential address/contact address, email address, date of birth, gender, occupation, designation, bank account details, photographs and other personal information necessary for the performance of our services to you directly or indirectly as explained in paragraph 4 below.

4. Dealing with us anonymously or using a pseudonym

Where it is necessary and lawful, you can deal with us anonymously or use a pseudonym if you wish including when you post a consumer or product review or comment on our products and services. However in many instances, if we unable to identify you or if you do not provide us with your personal information we request for, then we may not be able to provide you with comprehensive/complete information of our products or services, respond to your complaints, enquiries, comments and requests, review, posts, or assess job applications.

5. Disclosure of Your Personal Information

5.1 We work together with a number of third parties including our related companies. We have chosen these third parties carefully to keep your personal information safe. We may need to disclose to, or share your personal information with these third parties, some of which may be located overseas, including but not limited to the following:

(a) to our holding company, subsidiaries, associated, affiliates and/or related companies within Malbro group of companies in other jurisdictions.

(b) to third parties such as our authorised agents, representatives, intermediaries, contractors, independent contractors, product dealers/distributors/representatives (including through their online platforms/marketplaces), third party service providers, mobile application service providers, external advisors and consultants to provide services including but not limited to hosting services, programming services, sales and marketing services, legal services, media agency services, maintenance and repair of product services and/or customer contact centre services to us and/or for and on our behalf.

(c) to any social media website(s) or mobile application such as Facebook, Instagram and WhatsApp for the purpose to create customised audiences for targeted marketing; and

(d) where disclosure is otherwise authorised or required by courts, arbitrations, tribunals and regulatory authorities in accordance with laws.

6. Quality and Security of Your Personal Information

6.1 We strike to do our best to protect your personal information and take reasonable steps and efforts to ensure that the personal information we collects are accurate, up-to-date and complete, and when being used or disclosed, relevant for the purpose of the use or disclosure. However, please help us to maintain the quality of your personal information by contacting our Data Protection Officer if you believe that the personal information which Malbro holds about you may be inaccurate, incomplete, out-of-date or irrelevant.

6.2 We have the necessary security measures in place to protect the personal information we hold against misuse, interference and loss, and from unauthorised access, modification or disclosure. We will also take reasonable steps and efforts to ensure that the personal information disclose, transfer or share with our third party service providers is protected at the same level. But unfortunately, the transmission of information via internet is not completely secure and safe. Although we will use best reasonable efforts to protect your personal information, we are unable to guarantee the security of your personal information transmitted through this website(s) or mobile application; any transmission is at your own risk.

6.3 In order to keep your information secure, we hold your personal information in an electronic format on a central database held on secure servers which are owned and operated by our related companies, principally located in Singapore, India, China and/or European Economic Area countries. These companies are subject to Malbro Group’s corporate guidelines on data protection and information security. Our third party service providers who may also hold or host on the servers or platforms information we collect through the use of their services are subject to obligations to ensure the security of the personal information they process on our behalf. We also hold some personal information in hard copy. These documents are held in secure locations within Malbro offices and/or achieve facilities. Malbro restricts access to documents containing personal information to those authorised employees who need it for the purpose of conducting Malbro business in accordance with this Privacy Policy and Personal Data Notice.

6.4 We encourage you to be careful and protect your personal information when use our website(s) or mobile application. In the event of cyber-crime, loss, or damage of your personal information that is beyond our reasonable control, we will not be held responsible for such actions in any manner whatsoever directly or indirectly.

6.5 If we have provided (or you have chosen) a password which allows you to access various parts of our website(s) or mobile application, you are responsible for maintaining the confidentiality of that password. We request you not to disclose the use of the password to any third party in any manner whatsoever directly or indirectly.

6.6 Our security procedures, if necessary, will be continually enhanced as and when new technology becomes available.

6.7 We also committed not sell or rent your personal information with any third parties.

7. Data processing on the website

7.1 Our website(s) or mobile application uses a browser feature known as “cookies”. When you visit our website(s) or mobile application, our web server(s) will automatically record the following information:

(a) date of the access.

(b) time and length of the access.

(c) URL of the linking website or mobile application.

(d) name of your internet service provider.

(e) websites or mobile application you actually visit.

(f) files accessed.

(g) browser type and version.

(h) operating system.

(i) IP address (anonymised).

7.2 This information is collected via cookies and active components (e.g. JavaScript) which Malbro uses to follow the preferences of our visitors and optimize our website(s) or mobile application accordingly. Malbro does not attempt to identify you using this information.

7.3 You can reset your browser either to notify you when you receive a cookie, or to refuse to accept cookies. Please note that certain areas of most sites may not function properly if you reject a cookie. Some expire at the end of each session and some remain for longer so that when you return to our website(s) or mobile application, you will have a better user experience. We uses cookies to personalize content we send to you and to make our marketing more relevant.

7.4 We also allowed Facebook and/or Instagram and/or WhatsApp and/or Google to use third party cookies on our website(s) or mobile application to target advertising to you when you visit our website(s) or mobile application and other social media accounts platforms.

7.5 To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit, www.allaboutcookies.org.

7.6 In order to help us design our website(s) or mobile application appropriately, we may collect usage data relating to your visit to our website(s) or mobile application using analytics cookies and other technologies. As part of this, we record the mouse movements and clicks of randomly selected users of our website(s) or mobile application. Your IP address is anonymised as a matter of course. The resultant log of your use of our website(s) or mobile application is randomly analysed so that we can derive potential improvements for our website(s) or mobile application.

7.7 We use our third party service providers, Mouseflow ApS, Flaesketorvet 68, 1711 Copenhagen, Denmark for the purpose of collecting this usage data.

7.8 We do not conflate the resultant usage profiles with your name or any other details that could disclose your identity, such as your e-mail address. Under PDPA, we are permitted to process data in this context with your consent. The usage data is deleted three months after the date on which it is collected.

7.9 Opt-out: Please use Mouseflow’s opt-out website via the following link if you wish to prevent this usage data being collected: https://mouseflow.com/opt-out.

7.10 Our website(s) or mobile application may also use other web analytics tools and technologies to facilitate the purchase of our products you wish to buy including by connecting you to products available on authorised dealers/distributors/retailers/representatives website(s) or mobile application (including through their online platforms/marketplaces) and to understand your purchasing and other activities on our authorised dealers/distributors/retailers/representatives website(s) or mobile application (including through their online platforms/marketplaces), in connection with our products and services.

7.11 Our website(s) or mobile application may include links to other websites or other mobile application which are not covered by this Privacy Policy and Personal Data Notice and for which Malbro has no responsibility. Further we shall not be held responsible for any data entry errors caused by registration or transmission of your personal information provided by you.

8. Newsletter/Updates

Our website(s) or mobile application provides the option of subscribing to our newsletter/updates for marketing and advertisement news on our products and services, offers and promotions. If you subscribe to receive our newsletter/updates, and therefore consent to these being sent to you, your details are solely used in order to send you the newsletter/updates.

9. Direct Marketing and Opting-Out

9.1 Depending on how we collect your personal data and/or interact with you, we may, with your consent where required, communicate with you (e.g. via email, push notification and/or text message (SMS), telephone or via social media account messaging) marketing and advertisement news on our products and services, offers and promotions.

9.2 Occasionally, we may carry out surveys to help us to understand and identify our customers’ needs and preferences, and to improve our product, services and our website(s) or mobile application. You have the right to participate in such surveys or chose not to participate at your discretion.

10. Your Right to access, complete, correct, update, and transfer your Personal Information

10.1 You may generally access on request personal information which Malbro holds about you, and you may request for corrections, updates, transfers, erase, delete destroy, suspend, anonymise and/or transfers of your personal information which you believe is inaccurate, out-of-date, incomplete, irrelevant or misleading.

10.2 To make such request, please contact our Data Protection Officer on the details below. We may need to ask you a few questions in order to verify your identity before we can respond to your request. If we are unable to provide access to, or correct or update your personal information, we will inform you in writing of our reasons and how you may take the matter further if you are not satisfied with our decision.

11. Changes to Privacy Policy and Personal Data Notice

Malbro reserves the right to update this Privacy Policy and Personal Data Notice from time to time to reflect changes to our information handling practices or legal obligations in accordance with PDPA. Any changes will be effective from the date that they are posted on this website(s) or mobile application. Please check frequently to see any updates or changes to this Privacy Policy and Personal Data Notice.

12. How long MALBRO will keep your Personal Information

We will take reasonable steps and efforts to ensure that we will keep your personal information for the duration of the contractual obligations or as required by the relevant laws.

13. Protection of minors

If you are below age of majority (i.e. below 18 years old), please do not send any of your personal information to us without consent from your parents or legal representatives.

14. Language

This Privacy Policy and Personal Data Privacy terms is drawn up in the English language and it may be translated into Bahasa Malaysia. In the event of any conflict, the English version shall in any event prevail.

15. Contact Details for questions relating to your Personal Information

15.1 If you have any questions about how Malbro handles your personal information, or if you are concerned that we may have breached your privacy and wish to make a complaint, please put your complaint in writing and send it by mail or email to our Data Protection Officer using the details below. We will investigate your complaint and will notify you of a decision in relation to your complaint as soon as practicable after it has been made.