The Personal Data Protection Act 2010 (as may be amended from time to time, hereinafter referred to as the “Act”), which regulates the processing of personal data in commercial transactions, applies to LepasKunci- WONDERFUL GLOBAL (M) SDN BHD and our related companies (hereinafter collectively referred to as “LepasKunci”, “our”, “us” or “we”). For the purpose of this personal data policy, the terms “personal data” and “processing” shall have the meaning prescribed in the Act
This Privacy Statement describes our gathering, storing, dissemination and processing practices in respect of personal data of individuals.
This Privacy Statement applies to all operations and business units of LepasKunci, including but not limited to its holding company, related and subsidiary companies. To the extent any operations or business unit of LepasKunci already has a data protection Privacy Statement in place; this Privacy Statement shall supersede and replace any such notice.
Please read this Privacy Statement to understand how we use and process the personal data we have collected or may collect from you.
By providing your personal data and/or using our site, you are consenting to this Privacy Statement and the collection, use, access, transfer, storage and processing of your personal data described in this Privacy Statement as modified from time to time by LepasKunci.
If you are under 18, you should ensure that you obtain the consent of your parents or legal guardian before using our services and/or products. If you are a firm, corporation or entity supplying personal data of your partners, directors, shareholders, employees, officers and/or other persons to us, please do ensure that you have obtained their consent and bring this Privacy Statement to their attention.
PRIVACY STATEMENT EXPLAINATION
This Privacy Statement sets out:
What kind of personal data is being processed;the purposes for which the personal data is being or is to be collected and further processed;
The source of that personal data;
You’re right to request access to and to request correction of your personal data and how to contact us with any inquiries or complaints in respect of the personal data;
the persons to whom we disclose or may disclose your personal data;the choices and means that you may limit the processing of your personal data, including personal data relating to other persons who may be identified from that personal data;
Whether it is obligatory or voluntary for you to supply the personal data; andwhere it is obligatory for you to supply the personal data, the consequences to you if you fail to supply the personal data.
TYPE OF PERSONAL DATA
Personal data refers to all information that relates directly or indirectly to you, including any sensitive personal data and expression of opinion about you. Sensitive personal data refers to any personal data as to your physical or mental health or condition, your political opinions, your religious beliefs or other beliefs of a similar nature, the commission or alleged commission by you of any offence or any other personal data as may be determined by law from time to time.
The personal data collected by us may include (but is not limited to) the following:
• Contact information – e.g. your name, date of birth, identification number (such as NRIC or passport number), gender, nationality, race, address, contact number, fax number, email address.
• Billing information – your credit card information and bank account detailsthe status of the services you have acquired from us or subscribed to – e.g. account number, account balance, account activities, payment history
• Transaction information – e.g. information requested by you from our services, such as status of traffic summons, driving licences, bankruptcyyour personal interests and preferences to help us tailor offerings of our services and products which would suit you best.
If need arises, we will obtain explicit consent from you to process sensitive personal data. We may however process personal data without your consent in limited circumstances as permitted by law.
USE OF PERSONAL DATA
We may collect and process personal data from you or from the third parties, for one or more of the following purposes:
• to verify your identity
• to assess and process your application(s) /request(s) for our services
• to provide you with the information and/or services you have requested from LepasKunci and/or its designated representatives and/or business partners and ancillary matters thereto
• to administer and manage our services
• to investigate, process and resolve any service issues, complaints, communications or other enquiries that you may submit to us regarding our services
• to assess and/or verify credit worthiness
• to keep in contact with you and provide you with any information you have requested, services and/or products offered by us and/or changes thereto, by our service providers and/or business partnersto maintain and develop our services, products, business systems and infrastructure
• to manage staff training and quality assurance
• to produce data, reports and statistics which shall be anonymised or aggregated in a manner that does not identify you as an individual
• to investigate, respond to, or defend claims made against, or involving LepasKunci or any other partners and associates organizations
• to conduct marketing activities
• to maintain records required for security, claims or other legal purposes
• to detect and prevent fraudulent activity
• to comply with legal and regulatory requirementsfor any other purposes that is required or permitted by any law, regulations,guidelines and/or relevant regulatory authorities
SOURCE OF PERSONAL DATA
We may collect personal data from customer application form, registration at or visit to websites owned and/or operated by LepasKunci, registration for a specific service provided by us, use of our services, participation in our survey, entry in competitions, contests, promotions, programmes organised by us, request for information regarding our product, commencement of any business or commercial relationship with us and/or any communication made with us.
We may also obtain your personal data from:
third parties we deal with or are connected with you (e.g. credit reference agencies or financial institutions)government or other regulatory authorities who have the power and/or authority to disclose such information (e.g. PDRM, Insolvency Department, JPJ)such other sources where you have given your consent for the disclosure of information relating to youwhere otherwise lawfully permitted.
REQUEST FOR ACCESS AND CORRECTION OF PERSONAL DATA
You shall provide and maintain accurate, complete and current data required to register with LepasKunci. You represent and warrant that all information furnished to LepasKunci from time to time through its website or otherwise is correct, validly issued and legally binding on you
You will be liable for any loss that results from any failure to notify LepasKunci of such a change as a result of undue delay, your gross negligence or fraud. Where you fail to inform of any change in its address, LepasKunci shall be discharged from all liabilities upon sending of any notice or document to the last known address.
In the event you may need to provide us with personal data relating to third parties (e.g. spouse or children or where you are the designated person in charge (from an organisation or company) for dealing with us, if you are acquiring and are responsible for a service and/or product that they will use), you confirm that you have (i) obtained their consent or otherwise entitled to provide their personal data to us and for us to use accordingly, and (ii) informed them to read this Privacy Statement.
LepasKunci reserves the right at any time to satisfy itself as to your identity and personal details provided including for the purposes of preventing fraud and/or money laundering and pending verification; we may withhold your access to your personal data. In addition, at the time of your application or at any time in the future, you authorise LepasKunci to perform identity verification checks directly or using relevant third parties.
LepasKunci aims to maintain LepasKunci’s services in a manner that protects information from accidental or malicious destruction. Because of this, after you correct, change or update information from LepasKunci’s services, LepasKunci may not immediately delete residual copies from LepasKunci’s active servers and may not remove information from our LepasKunci’s systems.
Your access to most services and content are password protected. Therefore, you are solely responsible for your username and password to access the services and content. You must remember to log off from your account and close the browser window after use so that no unauthorized party can have access. You must not, at any time, divulge your password to any third party
DISCLOSURE OF PERSONAL DATA
We will process personal data for the following reasons and may disclose to the following third parties:
• to provide, maintain, protect and improve all or any of our services and to develop new ones
• for internal and marketing purposes of LepasKunci
• companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions and providing you with services that you have requested or subscribed for
• to companies, corporations and/or entities that act as LepasKunci’s service providers, gateway providers, agents, contractors and/or professional advisers
• law enforcement agencies, government agencies and/or to detect, prevent, or otherwise address fraud, security or technical issues
• our business partners and other parties for purposes that are related to the purpose of collecting and using your personal data set out in this Privacy Statement
• LepasKunci will share personal data with other parties, companies, organizations or individuals outside of LepasKunci when LepasKunci has your consent to do so subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to the LepasKunci.
LepasKunci shall be entitled to retain all data and information supplied by you for the use of LepasKunci, notwithstanding the termination or suspension of our services to you.
We are committed to safeguarding your privacy. However, no data transmission over the internet can be guaranteed to be 100% secure. Accordingly, despite LepasKunci’s efforts to protect your personal data, LepasKunci cannot ensure or warrant the security of any information you transmit to us, or to or from our online products or services. All such transmission of information is carried out at your own risk. However, once we receive your transmission, we will make reasonable efforts to ensure its security in our systems.
Whenever we send you any information, we will include instructions on how to unsubscribe and a link to do so. If you do not wish to receive further information of a similar nature, you may e-mail us. If you do not wish to receive any information of any kind from us at all, you may e-mail us.
WHETHER OBLIGATORY TO PROVIDE PERSONAL DATA AND CONSEQUENCES OF NOT PROVIDING
Where indicated (e.g. on our website, registration/application forms), it is obligatory to provide your personal data to us to enable us to process your application for our services. Should you decline to provide such obligatory personal data, we may not be able to process your application or provide you with our services.
(a) Cookies are small text files or text identifiers that are downloaded to your computer or device when you visit our Site and/or use our Platform. Your browser sends these cookies back to the Site and/ or Platform every time you re-visit the Site and/or the Platform, so it can recognize you and can then tailor what you see on the screen. The cookies themselves cannot collect your personal data, or any information or files stored on your computer or device.
LINKS TO OTHER SITES
TRANSFER OF YOUR PERSONAL DATA OUTSIDE MALAYSIA
It may be necessary for us to transfer your personal data outside Malaysia if any of our service providers or strategic partners (“overseas entities”) who are involved in providing part of our services are located in countries outside Malaysia or if you use the services from a country other than Malaysia. You consent to us transferring your personal data outside Malaysia in these instances. We shall take reasonable steps to ensure that any such overseas entities are contractually bound not to use your personal data for any reason other than to provide the services they are contracted by us to provide and to adequately safeguard your personal data.
RIGHTS TO MAKE CHANGES
LepasKunci reserves the right at any time and at its sole discretion to revise, change, alter or vary the contents of our website and/or terms and conditions of use and/or the Privacy Statement as herein contained. The continued use of the website following any such revision, change, alteration of variation shall constitute the acceptance of, and agreement to be bound by such revision, changes, alteration and/or variation.