PDPA

PRIVACY NOTICE
Last Update Date: 1st May 2023

  1. INTRODUCTION
    1. eBen Assist Sdn Bhd, a private limited company incorporated in Malaysia with registered address at Suite 2B-13-3, Plaza Sentral, Jalan Stesen Sentral 5, Kuala Lumpur Sentral, 50470 Kuala Lumpur, Wilayah Persekutuan Kuala Lumpur ("eBen" and references to "we", "us" and "our" are to eBen) collects, holds and processes your personal data. We respect your privacy rights and have therefore developed this privacy notice ("Notice") to inform you about how we collect, use, share and protect your personal information. For the purposes of this Notice, "you" refers to yourself and the other individuals or entities you represent from whom you provide the personal information.
    2. In this notice, "Personal Data" has the meaning given to it in the Malaysian Data Protection Act 2010 ("PDPA").
  2. PERSONAL DATA COLLECTED, HELD OR PROCESSED
    1. In order to provide you with our services, we may need to collect, shop or process the following data
      We may “process” your Personal Data by way of collecting, recording, holding, storing, using or disclosing it.
    2. The Personal Data about you which we may collect via digital channels such as our website, text messages, social media and such other digital platforms (collectively as “Application and Sites”) includes, without limitation to:
      1. Information collected that relates directly or indirectly to you when you register as a registered member or user of our Application and Sites or update an online profile via our Application and Sites or any other website maintained by such other parties which you are redirected to from our Application and Sites, the contents of all printed and electronic forms or documents submitted to us via printed forms and through our Application and Sites;
      2. information input or submitted to online facilities such as search tools and calculators;
      3. personalisation preferences you select as you use our Application and Sites;
      4. information submitted if you participate in survey or competition whether via online or otherwise;
      5. any messages, enquiries or feedback you publish to us thru our Application and Sites or in something manner;
      6. data received independently via way of means of us from different lawful sources;
      7. video or photographs captured throughout stay steaming; and/or
      8. the contents of all paperwork and/or files submitted to and/or accrued via way of means of us and/or the traders withinside the market of our Application and Sites.
    3. Your Personal Data which we may also accumulate consists of the subsequent data:-
      1. identification card/ passport number;
      2. name;
      3. gender;
      4. race and spiritual belief;
      5. occupation;
      6. e-mail address;
      7. smartphone number (consisting of cellular smartphone number);
      8. correspondence address;
      9. transport address;
      10. pictures and/or videos;
      11. own circle of relatives or subsequent of family data;
      12. statistics data (as described withinside the PDPA);
      13. getting in touch preference;
      14. monetary and banking details (consisting of, without limitation, virtual pockets details, public and personal keys with regards to Cryptocurrency and credit score or debit card details);
      15. login credentials which include username and password;
      16. net protocol address; and
      17. statement or opinions.
    4. The listing of Personal Data said above isn't always exhaustive and might consist of different non-public statistics relying on the character of dealings or transaction from time to time.
      1. any messages, enquiries or comments you submit to us via our Application and Sites or in whatever manner;
      2. information obtained independently by us from other lawful sources;
      3. video or images captured during live steaming; and/or
      4. the contents of all forms and/or documents submitted to and/or collected by us and/or the merchants in the marketplace of our Application and Sites.
    5. Your Personal Data which we may collect includes the following information:
      1. identity card/ passport number;
      2. name;
      3. gender;
      4. race and religious belief;
      5. occupation;
      6. email address;
      7. telephone number (including mobile telephone number);
      8. correspondence address;
      9. shipping address;
      10. photographs and/or videos;
      11. family or next of kin information;
      12. sensitive data information (as defined in the PDPA);
      13. contact preference;
      14. financial and banking details (including, without limitation, digital wallet details, public and private keys in relation to Cryptocurrency and credit or debit card details);
      15. login credentials such as username and password;
      16. internet protocol address; and
      17. commentary or opinions.
    6. The list of Personal Data stated above is not exhaustive and may include other personal data depending on the nature of dealings or transaction from time to time.
    7. Personal Data does NOT cover an individual’s “business contact information” such as his/her position, title, business address, business email/ fax number
    8. The PDPA deals with only with the Personal Data of individuals (i.e natural persons), and does not extend to data of companies or corporations.
  3. PURPOSE OF COLLECTION OF PERSONAL DATA
    1. We gather Personal Data for the subsequent functions:
      1. to technique your price for system fees;
      2. verification exams;
      3. to set up with courier carrier gives for transport of the voucher-associated products (if any) redeemed through you;
      4. inner statistical analysis;
      5. to permit us to preserve you published on our brand-new services or products bulletins and upcoming activities through sending to you any updates, new products, unique offers, advertising, promotional materials and/or business materials which we can also additionally sense to be of hobby to you;
      6. to searching for your reviews or remarks approximately our offerings and/or products;
      7. to perform our management, administrative, fine guarantee and criticism coping with sports in a expert and green manner;
      8. marketplace research;
      9. to manage and reply to any queries, requests and issues;
      10. to offer different offerings to decorate and help the connection among us and also you and/or such different men and women or entities represented through you;
      11. to put together and put up any claims or bills to any party or for any audit/exams through any party for anything reason associated with our business;
      12. to permit us and/or our merchants/companions to carry out capabilities or duties as required beneath the legal guidelines, rules, regulations, through legal guidelines and/or guidelines (whether or not or now no longer having the pressure of law) or as required through any governmental and/or non-governmental authorities, organizations or departments or which will make sure compliance with any settlement or file;
      13. for functions linked with the enforcement of our rights or the rights of our merchants/companions pursuant to any letter, settlement and/or file inclusive of looking for criminal and economic advice, taking any initial steps or setting out any criminal action; and/or
      14. to make such disclosures as can be required for any of the above functions or through law; and/or
      15. to put into effect client loyalty programmes, if applicable;
      16. any contest entry, if applicable;
      17. any invitation to sign up for our activities and promotions;
      18. to monitor, review and improve our membership, events and promotions, products and/or services;
      19. to detect, investigate and prevent fraudulent, prohibited or illegal activities;
      20. to maintain and update internal records;
      21. to authenticate credit or debit card information; and or
      22. for any other purposes necessary to operate and maintain our business and/or the functionality and services of our applications and websites;
      (Collectively, “Purpose”).
    2. We may contact you by phone, email, short messaging services, social media or other available forms of communication for the above purposes or to provide important notices. If you do not wish to receive communications from us, you may opt out of receiving these communications.
  4. DISCLOSURE OF PERSONAL DATA
    We will now no longer expose your Personal Data to a 3rd party that isn't always our associated entity unless:
    1. the disclosure is for any of the Purposes for which the facts changed into collected;
    2. you have consented to the disclosure;
    3. For our agent, provider company or contractor, wherein case we are able to require them to reveal and to apply the Personal Data best for the intention of which it was disclosed;
    4. someone worried in a dealing or proposed dealing (consisting of a sale) of all or a part of our belongings and enterprise;
    5. credit score reporting agency;
    6. acquires or needs to acquire, or makes inquiries in terms of acquiring, a hobby in us;
    7. Personal Data so as for such to carry out features or offerings as required via way of means of us;
    8. Personal Data so as for functions of instruction and submission of any claims or bills to any party or for any audit/exams via way of means of any party for something motive associated with our enterprise and/or the Application and Sites;
    9. Personal Data to carry out features or duties as required below the legal guidelines, rules, regulations, via way of means of legal guidelines and/or guidelines (whether or not or now no longer having the pressure of law) or as required via way of means of any governmental and/or non-governmental government, groups or departments or a 3rd party calls for if you want to make certain compliance with settlement or document;
    10. the disclosure is for your own circle of relatives and subsequent of kin;
    11. the disclosure is to applicable debt healing government or groups withinside the occasion of any default in price for our offerings;
    12. the disclosure is to our associated frame corporate, traders or enterprise partner;
    13. the disclosure is to the auditors, consultants, legal professionals or different monetary or expert advisers on a need-to-realize foundation for the motive of these advisers supplying recommendation to us;
    14. the disclosure is to any party in terms of complaints or potential complaints;
    15. the disclosure is to any party nominated or appointed via way of means of us both completely or mutually with different provider providers, for motive of organising and keeping a not unusual place database in which our entity has a valid not unusual place hobby;
    16. the disclosure is to price channels consisting of however now no longer restrained to monetary establishments for motive of assessing, verifying, effectuating and facilitating price of any quantity because of us in reference to your buy of our merchandise and/or offerings;
    17. the disclosure is to the overall public while you come to be a winner in a competition via way of means of publishing your name, images and different Personal Data without reimbursement for marketing and marketing and exposure functions; and
    18. the disclosure is permitted, required or accepted via way of means of or below
  5. MARKETING
    1. We may use your personal information to inform you about new products, services and marketing activities that we believe may be of interest to you. This may include product and service offers, newsletters and general information about us or third parties.
    2. If you do not wish to receive information about such products and services, you can either:
      1. contact us and ask to be removed from the relevant lending list; again
      2. Follow the unsubscribe instructions in any relevant electronic message.
    3. However, opting out will prevent us from sending you Service-related communications, such as: Administrative email notifications related to account settings.
  6. STORAGE AND RETENTION OF PERSONAL DATA
    1. Your personal information may be stored on paper at our office or on servers located in Malaysia or abroad operated by us or our service providers located in Malaysia or abroad.
    2. In general, we will keep your personal data for the period necessary to provide the requested service. The personal data you provide will be kept for as long as necessary to fulfil the purposes set out in paragraph 3 above, or to comply with legal, regulatory and/or accounting requirements, or to protect our interests. We will keep it for as long as we need it. We will take all reasonable steps to ensure that your personal information is destroyed or completely deleted when it is no longer needed.
  7. PURPOSE OF COLLECTION OF PERSONAL DATA
    Your personal data held by us may be modified, altered, replaced, and subject to applicable laws, including, but not limited to, all applicable laws, directives, regulations, and similar enacted under or in connection with any law. will be kept confidential in accordance with all applicable laws. sometimes enabled.
  8. SECUARITY OF PERSONAL DATA
    1. Access to personal data is limited to those employees who are expressly required to perform their duties.
    2. We will endeavour to keep the personal information we hold about you secure and take all reasonable steps to protect your personal information from loss, misuse or unauthorized alteration. All personal data you provide to us electronically is stored on our secure servers. Our employees are obliged to respect the confidentiality of all personal data stored by us.
    3. However, if you provide your Personal Data to us via the internet, we cannot guarantee that your Personal Data is completely secured. So while we strive to protect such Personal Data, we cannot ensure or warrant the security of any Personal Data transmitted to us and you do so at your own risk. Once any Personal Data comes into our possession, we will take reasonable steps to protect that information from misuse and loss and from unauthorised access, modification or disclosure.
  9. 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 represent and warrant that you have obtained their consent to provide their Personal Data to us and they consent to their Personal Data being processed in accordance with this Notice and, with respect to minors (i.e. individuals under 18 years of age) or any individuals not legally competent to give consent, you consent on their behalf (and you confirm that you have the authority to do so).
  10. RIGHTS OF ACCESS TO PERSONAL DATA
    1. Under the PDPA, you have the right of access to your Personal Data held by us and may request that we to correct any of your Personal Data that is inaccurate, incomplete or out-of-date, subject to any applicable legal restrictions and contractual conditions.
    2. If you wish to request access to your Personal Data or if you wish to correct Your Personal Data, you may Contact Us (please refer to Paragraph 13 of this Notice).
    3. However, where:
      1. the access impacts on the privacy of others;
      2. the request for access is frivolous or vexatious;
      3. there are existing or anticipated legal proceedings; or
      4. such access can be denied under law or by a law enforcement agency, we may not be able to provide you with access to the Personal Data we hold about you.
    4. If we deny your request for access, we will let you know the reasons for such denial. We may also charge a fee to cover the reasonable costs we incur in processing your request.
  11. WEBSITE & COOKIES
    1. To ensure we are meeting the needs and wants of our website users, and to develop our online services, we may collect aggregated information by using cookies or similar electronic tools.
    2. Cookies are small amounts of information sent from a web server to your computer. These cookies are used to retain login and location information in order to make your experience more convenient and personal. We do not use cookies to track your internet activity before or after you leave our website. No other company has access to our cookies.
    3. External links
      1. If any part of the Application and Sites links you to other websites, those websites do not operate under this Notice and we do not accept any responsibility or liability arising from those websites.
      2. Likewise, if you subscribe to an application, content or a product from a strategic partner of us and you subsequently provide your Personal Data directly to that third party, that Personal Data will be subject to that third party’s privacy notice (if such third party has a privacy notice) and not to this Notice.
      3. We recommend you to read and understand the privacy notice posted on those other websites in order to understand their procedures for collecting, processing, using and disclosing personal data and before submitting your Personal Data to those websites.
  12. CHANGES TO OUR PRIVACY NOTICE
    We reserve the right to amend this Notice from time to time without prior notice. We advise that you check this Notice at our Application and Sites on a regular basis.
  13. COMPLAINT RESOLUTION
    We are committed to constantly improving our procedures so that your Personal Data is treated appropriately. If you feel that we have failed to deal with your Personal Data in accordance with this Notice, please speak to us so that we have an opportunity to resolve the issue to your satisfaction.
  14. CONTACT US
    If you wish to request access to your Personal Data or if you wish to correct Your Personal Data or if you have any query about this Notice or if you wish to withdraw your consent to us for processing of your Personal Data for the Purposes as set out in Paragraph 3 above or for the transfer of your Personal Data to the parties stated in Paragraph 4 above, please contact us by writing to our support team at Suite 2B-13-3, Plaza Sentral, Jalan Stesen Sentral 5, Kuala Lumpur Sentral, 50470 Kuala Lumpur, Wilayah Persekutuan Kuala Lumpur or sending an email to enquiry@ebenassist.com
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