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Privacy Policy

Introduction


Welcome to the privacy policy of Link Page Sdn. Bhd. (Company No.: 1377943-T), a company incorporated in Malaysia under Companies Act 2016 with its registered address at A-28-3A, Dataran 3 Two, No. 2, Jalan 19/1, 46300 Petaling Jaya, Selangor Darul Ehsan (“Company”).


We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.



  1. Important information and who we are


Purpose of this privacy policy


This privacy policy aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up as user OR purchase a product or engage any service through the website.


This website is not intended for user aged below 18 and we do not knowingly collect data relating to children.


It is important that you read this privacy policy together with any other privacy policy we may provide from time to time when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.


Controller


Link Page Sdn. Bhd. (Company No.: 1377943-T) is the controller and responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this privacy policy).


If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our customer service via email at: customerservice@linkpage.com.my


You have the right to make a complaint at any time to the Commissioner, for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner so please contact us in the first instance.


Changes to the privacy policy and your duty to inform us of changes


We keep our privacy policy under regular review. This version was last updated on 1 December 2020.


It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


Third-party links


This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.



  1. The data we collect about you


Personal data, or personal information, has the same meaning as ascribed to them by Section 4 of the Personal Data Protection Act 2010.


We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:-


  • Identity Data includes but not limited to first name, maiden name, middle name, last name, username or similar identifier, marital status, title, date of birth and gender.


  • Contact Data includes but not limited to billing address, delivery address, correspondence address, email address and telephone numbers, facsimile numbers.


  • Financial Data includes but not limited to bank account and payment card details.


  • Transaction Data includes but not limited to details about payments to and from you and other details of products and services you have purchased from us or through the website.


  • Technical Data includes but not limited to internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.


  • Profile Data includes but not limited to your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.


  • Usage Data includes but not limited to information about how you use our website, products and services.


  • Marketing and Communications Data includes but not limited to your preferences in receiving marketing from us and our third parties and your communication preferences.


Where applicable, we also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.


If you fail to provide personal data


Where we need to collect personal data by law, or under the terms of a contract or agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the contract or agreement we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.



  1. How is your personal data collected?


We use different methods to collect data from and about you including through:


  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:-


  • apply for our products or services;

  • create an account on our website;

  • subscribe to our service or publications;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey; or

  • give us feedback or contact us.


  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, where applicable, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.


  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:-


Technical Data from the following parties:


    1. analytics providers;


      1. advertising networks; and


      1. search information providers.


  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.


  • Identity and Contact Data from data brokers or aggregators.


  • Identity and Contact Data from publicly available sources.



  1. How we use your personal data


We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:-


  • Where we need to perform the contract or agreement we are about to enter into or have entered into with you.


  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.


  • Where we need to comply with a legal obligation.


Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.


Purposes for which we will use your personal data


We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer or user

(a) Identity

(b) Contact

Performance of a contract or agreement with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract or agreement with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Notifying you about changes to our features and/or functions of our website

(c) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract or agreement with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers or users use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract or agreement with you

(b) Necessary for our legitimate interests (to study how customers or users use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers or users use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)


Marketing


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms where you can view and make certain decisions about your personal data use:-


Promotional offers from us


We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.


Third-party marketing


We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.


Opting out


You can ask third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you by the third parties OR by contacting the third parties to opt-out or unsubscribe their marketing messages at any time.


Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.


Cookies


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.


Change of purpose


We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.


If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.



  1. Disclosures of your personal data


We may share your personal data with the parties set out below for the purposes set out in the table above.


  • Internal Third Parties (hereinafter defined).


  • External Third Parties (hereinafter defined).


  • Specific third parties listed in the table above.


  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.


We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.



  1. Data security


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.



  1. Data retention


How long will you use my personal data for?


We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.


To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.



  1. Your legal rights


You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.


What we may need from you


We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


Time limit to respond


We try to respond to all legitimate requests within Five (5) working days. Occasionally it could take us longer time if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.



  1. Glossary


LAWFUL BASIS


Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.


Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.


THIRD PARTIES


Internal Third Parties

Other companies associated with, owns or owned by the Company and acting as joint controllers or processors and who provide IT and system administration services and undertake leadership reporting.


External Third Parties


  • Service providers acting as processors based in Malaysia who provide IT and system administration services.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.


  • Inland Revenue Board & Customs, regulators and other authorities acting as processors or joint controllers based in Malaysia who require reporting of processing activities in certain circumstances.

© LinkPage 2020. All rights reserved.

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