PRIVACY POLICY


Snowball Capital Partners Sdn Bhd under the business name of PENANG360 (“PENANG360”) respects and is committed to the protection of your personal information and your privacy. In this Privacy Policy, “we”, “us” and “our” refers to PENANG360, and “you” and “your” includes third parties whose personal data you have provided to PENANG360.

This Privacy Policy explains how we collect and handle your personal information, including your sensitive personal information in accordance with the Malaysian Personal Data Protection Act 2010. Please note that PENANG360 may amend this Privacy Policy at any time without prior notice and will publish the amended or revised Privacy Policy on our website or by email.

1 Personal information

1.1) Type of personal information
Personal information means any information which relates to you or any other third party related to you which was collected or provided to PENANG360 for the purposes stated in Section 2 below.

We process your personally identifiable information which may include your name, NRIC number, contact details, financial and banking account details, information regarding your family, relatives or third party that you provide to us, your preferences in relation to products and services you purchase from us, and location tracking/GPS information.

1.2) Source of personal information
(i) Customer or potential customer: PENANG360 collects your personal information directly from you or indirectly from your legal representatives, agents and/or employer when you, your legal representatives, agents and/or employers send us completed enquiry, application and/or registration forms via various means, including online and physical hardcopies at public venues. Your personal information may also be collected from cookies through the use of our website.

(ii) Vendor, supplier or service provider: PENANG360 collects your personal information directly from you or indirectly from your employer or agencies, when you send us completed enquiry and/or application forms via various means, including online and physical hardcopies. Your personal information may also be collected from cookies through the use of our website.

1.3) Obligatory personal information
All information requested for in the relevant forms is obligatory to be provided by you unless stated otherwise.

Should you fail to provide the obligatory information, we would be unable to process your request and/or provide you with relevant services.

2 Purposes of collecting and further processing (including disclosing) your personal information

(i) Customer or potential customer: Your personal information is collected and further processed by PENANG360 as required or permitted by law and to give effect to your requested commercial transaction, including the following:


• to process your requested products and services;


• to facilitate your participation in any contests or events;


• to administer and communicate with you in relation to our services and/or events;


• to process any payments related to your requested service;


• for insurance purposes;


• to operate our premises in a manner which is physically safe, secure and betting of health and safety requirements;


• for internal investigations, audit or security purposes;


• to conduct and support internal marketing analysis and analysis of customer patterns, choices and engagement with PENANG360’s related companies, subsidiaries, holding companies and affiliate companies;


• to be collected and stored into a central repository that is accessible by PENANG360’srelated companies, subsidiaries, holding companies and affiliate companies;


• to create and deliver personalized products and services that are unique to you to enhance your customer experience;


• to provide you a more seamless customer experience;


• to support research and innovation of our products and services;


• to store and carry out data analytics processes;


• to improve our products and services;


• for matching of points provided by a third party/business partner to advertise and market products and services to you;


• for purposes of collaboration with a business partner to advertise and market products and services to you;


• to comply with PENANG360’s legal and regulatory obligations in the conduct of its business;


• to contact you regarding products, services, upcoming events, promotions, advertising, marketing and commercial materials which we may feel interest you;


• to send you season greetings, special occasion messages or other similar communications;


• to allow third parties to contact you for advertising, promotional or marketing campaigns conducted by any third party entities;


• to ensure that the content from our website is presented in the most effective manner for you and your computer and/or device; and


• for PENANG360’s internal records management, customer relations events and activities, and customer reward program.

(ii) Vendor, supplier or service provider: Your personal information is collected and further processed by PENANG360 as required or permitted by law and to give effect to your requested commercial transaction, including the following:


• to process your account application;


• to assess your credit worthiness;


• to administer and give effect to your commercial transaction;


• to process any payments related to your commercial transaction;


• for insurance purposes;


• for internal investigations, audit or security purposes;


• to comply with PENANG360’s legal and regulatory obligations in the conduct of its business;


• to contact you regarding products, services, upcoming events, promotions, advertising, marketing and commercial materials which we may feel interest you;


• to ensure that the content from our website is presented in the most effective manner for you and your computer and/or device; and


• for PENANG360’s internal records management, customer relations events and activities, and customer reward program.

* Where you have indicated your consent to receiving marketing or promotional updates from PENANG360, you may opt-out from receiving such marketing or promotional material at any time. You may select the “unsubscribe” option provided in PENANG360’s email marketing or you may contact PENANG360at the details provided in Section (6) below.

Data Analytics Processing:


PENANG360 wants to share and consolidate your data into a single platform to be shared across the PENANG360’s ecosystem services. We will use and share your data for analytics and measurement purposes to understand how our products and services are used, to help improve the products and services we offer, to provide you with more personalized products and services, and provide a more seamless customer experience.

For example, we analyze data about your choice and preferences in relation to the products and services you purchase from us to send you targeted advertisements and promotional materials. We also process data about the ads you interact with to help us and advertisers understand the performance of various ad campaigns.

3 Disclosure of personal information

3.1) Entities within PENANG360
Your personal information provided to us is processed by and disclosed to entities (in or outside of Malaysia) within PENANG360 (including related companies, subsidiaries, holding companies, associated companies and outsourcing partners) for the purposes stated in Section 2 (Purposes of collecting and further processing (including disclosing) your personal information) above.

PENANG360 will ensure that:

(i) access to your personal information is restricted to staff who are contractually required to process your personal information in accordance with their respective job requirements.

3.2) Classes of third parties
Your personal information may be disclosed to relevant third parties (in or outside of Malaysia) as required under law, pursuant to relevant contractual or business relationships, our service providers, or for the purposes stated in Section 2 (Purposes of collecting and further processing (including disclosing)your personal information) above (or directly related to those purposes).

3.3) Advertisers, business partners or other third party entities.
Your personal information (including your sensitive personal data) may be disclosed or provided to advertisers, business partners or other third party entities and their advisers/representatives (in or outside of Malaysia) for purposes of any advertising, promotional or marketing campaigns conducted by any third party entities.

In the event of a potential, proposed or actual sale of business, disposal, acquisition, merger or re-organization (“Transaction”), your personal information may be required to be disclosed or transferred to a third party as a result of the Transaction. You hereby acknowledge that such disclosure and transfer may occur and permit PENANG360 to release your personal information to the other party and its advisers/representatives.

(i) Customer or potential customer: Your personal information may be disclosed to the following classes of third parties:


• Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretary, consultants, contractors, professional advisors, service providers, printing companies, contractors, conference/training/event organizer, other advisers, and etc.);


• Our business partners or affiliates who may jointly provide the service requested for;


• Law enforcement agencies, including the local police; and


• Relevant governmental authorities statutory authorities, local council and industry regulators.

(ii) Vendor, supplier or service provider: Your personal information may be disclosed to the following classes of third parties:


• Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretary, printing companies, contractors, conference/training/event organizer, other advisers, and etc.);


• Law enforcement agencies, including the local police; and relevant governmental authorities, statutory authorities, local council and industry regulators.

Transfer of your personal data outside Malaysia:

It may be necessary for us to transfer your personal information outside of Malaysia if any of the third parties mentioned in section 3 (Disclosure of personal information) above including our service providers or business partners who are involved in providing any services to us are located or have processing facilities in countries outside of Malaysia.

You consent to us transferring your personal information outside Malaysia to such third parties and for the purposes set out in section 2 (Purposes of collecting and further processing (including disclosing) your personal information).

We shall take necessary steps to ensure that any such third parties are contractually bound to protect your personal information and that they can only process your personal information under our instructions.

4 Websites

4.1) Links to other sites
Links to other sites is provided for your convenience and information. These sites may have their own privacy statement in place, which we recommend you review if you visit any linked websites. We are not responsible for the content on the linked sites or any use of the site.

4.2) Location enabled products or applications
Location enabled products or applications transmit your location information to us. We do not use the information sent or provided other than to provide the service you request. Location enable features are opt-in and you have control over your participation and can turn these services off at any time or uninstall them.

Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve you through improved products, services, and revisions to the mobile applications. This collected information will not identify you to us. It may, however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download.

4.3) Cookies
A cookie may be used in the processing of your information. A cookie is a text file placed into the memory of your computer and/or device by our computers. A copy of this text file is sent by your computer and/or device whenever it communicates with our server. We use cookies to identify you. We may also collect the following information during your visit to our website and/or the fully qualified domain name from which you accessed our site, or alternatively, your IP address:

(i) the date and time you accessed each page on our website;


(ii) the URL of any webpage from which you accessed our site (the referrer);and


(iii) the web browser that you are using and the pages you accessed.

Some web pages may require you to provide a limited amount of personal information in order to enjoy certain services on our websites (system login credentials, email address and contact, etc.). These personal information will only be used for its intended purposes only, i.e. to respond to your message or deliver the requested services.

5 Right to access and correct personal information

You have the right to access and correct your personal information held by us(subject always to certain exemptions). We will make every endeavor to ensure your personal information is accurate and up to date therefore we ask that if there are changes to your information you should notify us directly.

6 Limiting the processing of personal information, further enquiries and complaints

If:

(i) you would like to obtain further information on how to limit the processing of your personal information;


(ii) you have any further query; or


(iii) you would like to make a complaint in respect of your personal information, you may contact :

PENANG360 Customer Service
Email Address: hello@penang360.my

For information of all other businesses, please submit your enquiry at https://penang360.my/contact-us

This Privacy Policy was last updated on 8 March 2022. 

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