1.3 “Personal Data” shall mean and/or may include but is not limited to the following: –
a) Your name;
b) date of birth, passport or identity card number;
c) home address, telephone number, facsimile number or email address;
d) photographs or pictures;
e) gender, marital or family status;
f) race, nationality or national, or ethnic origin;
g) education, employment or occupation, or educational, employment or occupational history, year of service, working experience, employers’ details;
h) source of income or financial circumstances, financial positions, activities or history including but is not limited to Your payment history, account activities, account balances, payment and/or deposit balances etc.;
i) litigation records and criminal history including regulatory offence(s);
j) details and background of family members;
k) details of guarantors and legal representatives;
l) details of bank accounts and specimen signature;
m) details of Your transactions with Our Site or KaleTech;
n) any such other necessary information of You;
o) that are, have been and may be collected, compiled and maintained from time to time with and by Our Site or KaleTech through amongst others the following manner:-
i. Your access to the Our Site or KaleTechs web server or Our website/ Mobile App;
ii. Your application form and/or any other forms as provided by You;
iii. transactions between Us and You, its service providers, business partners, affiliates and/or third parties;
iv. Credit Reporting Agencies and Credit Bureau Reports, e.g. CTOS (Convergent Technology Operating System Sdn. Bhd.), RAMCI (RAM Credit Information Sdn. Bhd.) etc;
v. Governmental Agencies, Regulatory and/or Statutory Authorities;
vi. customer surveys; and
vii. publicly available sources.
NOTE: This list is not exhaustive, as the word “include” is used, clauses (a) to (o) do not set out the only information which is Personal Data.
2. Collection of Personal Data
2.1 Our Site or KaleTech will from time to time collect, maintain, obtain, use or disclose Your Personal Data when You provide Your Personal Data or someone else with Personal Data whom You have provided Us with the information (3rd Party”), that is information that can identify You or such 3rd Party to Us in any way or manner, including pursuant to any transactions, agreements and/or inquiries made to Us. We will also receive and store Your Personal Data when You enter the Our Site or KaleTech’s websites such as IP address, web browser software, and referring website including the URL that You just came from. You represent and warrant that You have obtained the consent of such 3rd Party or are otherwise entitled to provide Us with their Personal Data and to view or change their information. You agree to indemnify Us in the event We suffer any loss or damage as a result of Your failure to comply with the same.
2.2 Please be assured that We will not use Your information for any of the purposes, if You have indicated that You do not wish Us to use Your information in this way when submitting the information or at a later stage.
2.4 Information that You will provide to Us, amongst others shall includes the following:
a) You will be asked to provide certain contact information that is necessary for the registering for a User account, including name, address, phone number, email address, job title and department;
b) You will be asked to provide certain identity information, tax registration and/or related information about Your business, such as Your company name, business type and industry, corporate registration details and information about Your business license;
c) If You are successfully certified by KaleTech, as a blogger or an influencer, in addition to the information mentioned above, We may also collect Your live stream videos, Your social media account names and profile photos, and posts or comments made by other users of Our Site;
d) In connection with the facilitation of transactions and payments on Our Site, You will be asked to provide certain banking information. This might include bank account numbers, billing and delivery information, credit/debit card numbers, expiration dates and security code and tracking information from cheques or money orders to facilitate the transaction;
2.5 Information that We collect automatically
a) If You contact Us (such as via Our customer services department chat service, telephone or email), We may record a copy of Your correspondence and may ask for additional information to verify Your identity.
b) We will collect contact details and other information of Users from publicly available sources for the purposes of verifying the Users and performing due diligence on the Users.
c) We will collect details of User activities, transactions and interactions on Our Site.
d) From time to time, We may also collect information about the existing and prospective users, including representative contact names, addresses, phone numbers, fax numbers and email addresses.
e) If You visit Our Site, We will automatically collect certain information from Your device. In some countries, this information may be considered as personal information under applicable data protection laws. Specifically, this information may include IP addresses, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location), browsing patterns and details of how You have interacted with Our Platform and the goods and services available on it. In addition, We gather statistical information about the Platform and visitors to the Platform including, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Collecting this information enables Us to better understand the visitors who come to Our Platform, where they come from, and what content is of interest to them. We use this information for Our internal analytics purposes and to improve the quality and relevance of Our Platform. Some of this information may be collected using cookies and similar tracking technology, as explained further under the section 3 “Cookies Policy” below.
3. Cookies Policy
We use the term “cookies” to refer to cookies and other similar technologies covered by the EU Directive on privacy in electronic communications.
1) What is a cookie?
Cookies are small data files that Your browser places on Your computer or device. Cookies help Your browser navigate a website and the cookies themselves cannot collect any information stored on Your computer or Your files. When a server uses a web browser to read cookies they can help a website deliver a more user-friendly service. To protect Your privacy, Your browser only gives a website access to the cookies it has already sent to You.
3) How are third party cookies used?
4) How do I reject and delete cookies?
4. Purpose of Collecting Your Personal Data
4.1 We collect, use and/or process Your Personal Data for the following purposes: –
a) process application(s) submitted by You;
b) verifying Your identity and conducting security, KYC (know-Your-customer) and anti-money laundering diligence and background checks in order to set up User accounts;
d) setting up / administering User accounts, including providing log-in IDs and developing a profile;
e) communicate with You including responding to Your enquiries and/or complaints and resolving disputes;
f) to notify You about important changes/developments in relation to Our Site;
g) facilitating communication between KaleTech and You
h) for the purposes of strategic alliances, cross selling, marketing, and promotions, to other units/department/ entities within Us, Our agents and third parties;
i) to comply with regulatory requirements and provide assistance to law enforcement agencies which may include disclosure, notification and record retention requirements;
j) to administer and/or manage products and services and/or any agreement You have with Us including collecting debts and enforcement of Our rights and obligations;
k) to improve and develop Our services and quality assurance to You;
l) assessing and monitoring account security and transaction risks of Users, to prevent, detect or prosecute cases of fraud/crime, money laundering and comply with legal and regulatory obligations;
m) to maintain Your credit history for present and future reference (if any) and
n) to protect KaleTech’s interests and other ancillary or related purposes.
o) for internal functions such as research and product development, evaluating the effectiveness of marketing and promotion campaigns, market research, statistical analysis and modelling, reporting, audit and risk management and fraud prevention;
p) any purposes in connection with the transactions and/or agreements entered into or to be entered into by You and/or Your principal/employer;
q) to provide new product & services, to potential new customers and subscriber’s identifications including marketing purposes and/or research purposes; and
r) other purposes which We may reasonably deem fit.
4.2 We, including Our personnel will only have access to use only relevant part of Your Personal Data. We endeavour to keep You informed of the latest marketing and promotional offers that We feel would be useful and beneficial to You. We may share Your personal data with other entities within KaleTech, Our agents or strategic partners and other third parties (“other entities”) as We deem fit and You may receive marketing communication from Us or from these other entities about products and services that may be of interest to You. If You do not wish for Us to use Your information in any of the abovementioned way for any of the purpose(s), You may write to Us and notify Us that You would like to withdraw Your consent. Your request will be processed at no fees and We will stop the use of Your information for such purposes as soon as it is reasonably possible to do so. However, please note that there are certain Personal Data information that may be necessary for You to provide, which otherwise may result in KaleTech being unable to provide You with products and/or services.
5. Disclosure of Personal Data
5.1 For purposes as described herein, We may share with and/or transfer Your Personal Data to:
a) Any person under a duty of confidentiality to KaleTech or to companies related or affiliated to KaleTech;
b) Companies related or affiliated to KaleTech;
c) Any credit bureaus, credit reference agencies, debt-collection agencies and/or other parties that assist with debt recovery functions;
d) Any relevant agents, contractors, third party service providers, professional advisors or brokers, on a need to know basis for the purposes of providing their services/advices to Us;
e) Any banking, financial or other institution with which You have or propose to have dealings with;
f) Parties authorised by You;
g) Enforcement regulatory and governmental agencies as permitted or required by law, and/or any other relevant authority as may be authorized by law to obtain such information
h) Any person by whom KaleTech is required by applicable legal, governmental or regulatory requirements to make disclosure;
i) Any person or corporation to whom KaleTech transfers or proposes to transfer any part of its interests, obligations, business and/or operations; and
j) Any other person reasonably requiring the same in order for KaleTech to carry out the activities set out in the above purposes.
5.2 In addition, the collected Personal Data will (occasionally) be transferred to selected third-parties, however these third parties will not use Your personal information for any other purposes than what We have agreed with them. We respect Your personal information and therefore, We will request these third parties to implement adequate levels of protection in order to safeguard Your personal information and We will take steps to ensure that Your privacy rights continue to be protected if We transfer Your information in this way.
5.3 Your Personal Data may also be transferred to, stored in, and processed in a jurisdiction other than Malaysia. You understand and expressly consent that Your Personal Data may be transferred outside of Malaysia to those third parties.
5.4 We may also share Your Personal Data where required by law or where disclosure is necessary to comply with applicable laws, legal processes, or queries from the relevant authorities.
6. Right to Access and Amend/Correct Personal Data
6.1 KaleTech is committed to ensure that the Personal Data that We hold is accurate, complete, not misleading and up-to-date.
6.2 If You would like to review, change or delete the details You have supplied Us with, You may, request to access, amend or make any correction to Your Personal Data by submitting a request in writing to KaleTech to the address stated below.
7.1 The security of Your Personal Data is Our paramount consideration. KaleTech keeps, protects and processes Your Personal Data in a secure manner by maintaining physical, electronic and procedural safeguards in compliance with the law, and KaleTech will, as far as practicable, aim to prevent any unauthorized and/or unlawful/unauthorized access, improper processing of, and the accidental loss, destruction or damage to Your Personal Data. We have implemented technology and policies with the objective of protecting Your privacy and will update these measures as new technology becomes available, as appropriate.
8. Changes to this policy
8.5 We trust that You have read, understand, consent and agree to the terms above mentioned with respect to Our processing of Your personal information and/or data, when You use Our website, products or services.
8.6 If You do not consent and/or require any further clarification to the above, please do not hesitate to contact Us at the below mentioned contact details.
Any queries, complaints and/or request to delete Your Personal Data or if You require any further information / assistance, You may write a request to KaleTech or contact Us via email, facsimile, telephone and/or post to the address as below: –
Kale Technology Sdn Bhd
Tel : +60 18 208 5455
Email : email@example.com