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PINGSPACE
PRIVACY POLICY                         

 

 

1          Introduction

 

1.1       This Privacy Policy describes how PINGSPACE SDN. BHD. (1244697-W), a company
incorporated in Malaysia, (“PINGSPACE”),
processes, collects, uses, shares and protects your personal data in connection
with our services, PINGSPACE mobile application (“PINGSPACE App”), or website or other platform. This Privacy Policy applies
to both the “online” (e.g., web and mobile services) and “offline” (e.g.,
collection of data through telephone or in person) activities owned, operated,
provided or made available by us.

 

1.2       This Privacy Policy specifically
addresses our obligations under the Personal Data Protection Act 2010 of Malaysia
(“PDPA”) to any users of PINGSPACE’s
services, including (without limitation) any users of the PINGSPACE App,
website or other platform, features or other services, so far as applicable, practicable
and consistent pursuant to such legislation.

 

1.3       Notwithstanding anything herein stated, this
Privacy Policy will apply so far as practicable and consistent with the PDPA.

 

2          Collection, Processing and Other
Usage of Personal Data

 

2.1       “Personal Data” means information
about you, whether such information directly or indirectly relates to you, which
you have provided to PINGSPACE or have allowed to be obtained by PINGSPACE, including,
without limitation, your name, address, nationality, date of birth, NRIC number,
driving license particulars, vehicle particulars, email address, telephone
number, fax number, bank details, credit card details, gender, condition of
your physical or mental health, political opinions, religious beliefs or
beliefs of a similar nature, the commission or alleged commission by you of any
offence, your occupation, photograph(s), or any proof of identity or information
which may identify you, your partner, spouse or family member(s), that has been
or may be collected, stored, used and processed by PINGSPACE from time to time.

 

            2.2       In addition to the Personal Data you
provide to PINGSPACE directly (for example, during your communications with PINGSPACE,
provide services to PINGSPACE and/or when you engage PINGSPACE for PINGSPACE services),
PINGSPACE may also collect your Personal Data from a variety of sources,
including, without limitation, at any events organised or sponsored by PINGSPACE
and/or from the cookies or other browsing data collected via the PINGSPACE website,
PINGSPACE App or other platform.

 

2.3       The provision of your Personal Data is
voluntary. However, if Personal Data is not supplied, or is not satisfactory to
us, PINGSPACE may not be able to (a) communicate with you; (b) provide you the
services you require, (c) fulfil our contractual obligations with you; or (d) provide
you with access to certain sections of the PINGSPACE App or website.

 

2.4       If you are under the age of 18 years old,
you agree, represent and warrant that (a) your parent, guardian, or person with
parental responsibility over you has fully read and agreed to the terms of this
Privacy Policy; and (b) the full and legal consent of your parent, guardian, or
person with parental responsibility over you has been obtained for the
processing, collection, use and sharing of your personal data by PINGSPACE, as
provided under this Privacy Policy.

 

3.         Purposes of Processing

 

3.1       PINGSPACE may use and process your
Personal Data for purposes relating to its business, transportation, delivery
of goods or services, logistics, communications, payments, financial services
and other activities of PINGSPACE and the PINGSPACE network which shall include,
without limitation, the following (“Purposes”):

 

3.2       Where you are an actual or potential purchaser
of products on our online store/platform:

 

(a)            
to process, manage, verify and complete
transactions with you;

(b)            
to fulfil our contractual obligations;

(c)            
to allow you to browse and use the
services offered on the PINGSPACE App, our website or other platform, features
or other services, regardless of whether or not you are a registered user on
the same;

(d)       to deliver on any transactions you have
requested;

            (e)        where you have requested to, or have
actually, downloaded and used the PINGSPACE App, or any other PINGSPACE applications,
to process your request, to deliver the PINGSPACE App to you and to provide you
a licence for the use of the PINGSPACE App;

(f)        to process, manage or verify any
application by you for subscription to the PINGSPACE network and to provide you
the benefits offered to subscribers;

(g)       to validate your bookings and process
payments relating to any services you have requested;

(h)       to use cookies to enhance our processes,
advertising, notifications, authentication, security and compliance, analytics
and preference management;

(i)              
to communicate with you, including,
without limitation, to provide response(s) to you (which may be automated), calculate
estimates, and to provide you with assistance in relation to our services;

(j)        to process your Personal Data for
marketing and market research purposes, or to involve you in other commercial
or promotional campaigns, and to send you newsletters relating to any products
or services offered by us, which may be in partnership with third parties; and

(k)       to manage relations with PINGSPACE’s third-party
service providers,

 

3.3       Where you are a Despatcher (person
picking up and delivering goods ordered by purchaser), PINGSPACE’s agent, merchant,
vendor, supplier, partner, contractor or service provider:

 

(a)        to process, manage, verify and complete
transactions with you;

(b)       for the purposes of engaging you to
provide services or in order to fulfil our contractual obligations with you;

(c)        to allow you to browse and use the
services offered on the PINGSPACE App, our website or other platform, features
or other services, regardless of whether or not you are a registered user on
the same;

            (d)       where you have requested to, or have
actually downloaded and used the PINGSPACE App, or any other PINGSPACE
applications, to process your request, to deliver the PINGSPACE App to you and
to provide you a licence for the use of the PINGSPACE App;

(e)        to use cookies to enhance our processes,
advertising, notifications, authentication, security and compliance, analytics
and preference management;

(f)        to facilitate or enable any checks and
other requirements as may be required by PINGSPACE in order to engage you;

(g)       to process payments relating to any
products or services you have provided;

(h)       to provide personalised feedback to you,
so that you are able to identify specific areas for improvement;

(i)        to assess safety and quality;

(j)        to communicate with you in relation to
the provision of our or your services;

(k)       to use your personal data for marketing
and market research purposes, or to involve you in other commercial or
promotional campaigns, and to send you newsletters relating to any products or
services offered by us, which may be in partnership with third parties; and

(l)        to manage relations with PINGSPACE’s
customers, users of PINGSPACE’s website, the PINGSPACE App or other platforms,
or other third-party service providers,

 

3.4       General:

 

(a)        to analyze and improve our services, or
to guarantee the quality of our services;

(b)       to respond to your requests, complaints,
or other communications;

(c)        to communicate with you for any of the
purposes listed in this Privacy Policy;

(d)       for management and control of our internal
activities, including, without limitation, administrative purposes, such as
auditing, data analysis, and database records;

(e)        to direct market our products and/or
services to you;

(f)        for purposes of detection, prevention
and prosecution of any crime, offence, or illegal activity;

(g)       to comply with any contractual, regulatory,
statutory or legal obligation imposed on us by any relevant authority including
accounting and tax obligations, and product warranties;

(h)       to manage insurance risk;

(i)        to manage the loss and/or destruction of
data, or unauthorized use of or access to data;

(j)        to publish on PINGSPACE channels any
images or videos made during promotional or other public events; and

(k)       to exercise our right to take legal
action or furnish evidence or other information in relation to any legal matter,

 

and you
agree and consent to PINGSPACE using, storing, transferring and otherwise processing
your Personal Data for the Purposes and in the manner as identified in this Privacy
Policy. If you do not consent to PINGSPACE
processing your Personal Data for the purposes listed in this Clause 3, please
notify PINGSPACE using the contact details provided in Clause 5 below.

 

3.5       Please
note that if you communicate your withdrawal of your consent to our use,
disclosure or processing of your Personal Data for the purposes and in the
manner as stated above, or request the deletion or anonymity of personal data,
we may not be in a position to continue to provide our products or services on
our online platform to you or perform on any contract we have with you, and we
will not be liable in the event that we do not continue to provide the services
to, or perform our contract with you.

 

4.         Storage
and Retention of Personal Data

 

4.1       PINGSPACE may engage other companies,
service providers or individuals to perform functions on PINGSPACE’s behalf, in
Malaysia or in any other country, and consequently may provide access or
disclosure to your Personal Data to the third parties such as those listed
below (this list is not exhaustive), who may store, use, collect, share and/or otherwise
process your Personal Data:

 

(a)
       parent companies, subsidiaries
and/or affiliate companies of PINGSPACE;

(b)       authorised agents, distributors,
suppliers, contractors and third-party service providers of PINGSPACE for any
of the Purposes contemplated at Clause 3 above;

(c)
       storage facility providers;

(d)       external professional advisors and
auditors, including, without limitation, banks, credit institutions, lenders,
operators of centralized information systems, insurance companies and
consultants; and/or

(e)        governmental departments and
authorities.

 

4.2       PINGSPACE stores your Personal Data
either in hard copies in our offices or in servers located in Malaysia or
outside Malaysia. It may be necessary to transfer your Personal Data to third-party
service providers based or located, partly or wholly, outside Malaysia. By
continuing usage of PINGSPACE App, website or services of PINGSPACE or PINGSPACE
network, or without any notice by you to prevent such transfers, you hereby
consent to such transfer.

 

4.3       PINGSPACE will retain any Personal Data
supplied by you as long as necessary for the fulfilment of the Purposes stated
in Clause 3 above or as is required to satisfy legal, regulatory, or accounting
requirements or to protect our interests.

 

4.4       PINGSPACE is not responsible or liable
for the collection, use, maintenance, sharing, disclosure, or other processing
of Personal Data and information by any third-party through your engagement of
PINGSPACE, provision of services to PINGSPACE, usage of the PINGSPACE App,
websites or other platform, or services, and you acknowledge that such data and
information are controlled by the third-party in accordance with that third-party’s
privacy policy, and you will fully indemnify PINGSPACE in respect of any claim
arising from the same.

 

4.5       Save
and except as provided in Clause 5 below, we do not offer any online facilities
for you to amend or remove your Personal Data held by us.

 

5.         Access
& Correction Requests and Inquiries

 

            5.1       Subject to any exceptions under the PDPA,
you may at any time hereafter request for access to, or for correction or
rectification of your Personal Data (including personal data relating to other
persons who may be identified from your Personal Data) or limit the processing
of your Personal Data (including personal data relating to other persons who
may be identified from your Personal Data), or seek further information from PINGSPACE
by contacting:

 

PINGSPACE SDN. BHD.

(Company No. 1244697-W)

Contact

:

 Data
Protection Officer

Address

:

Plot 18 & 19, Medan Bayan Lepas, Bayan Lepas
Industrial Park, 11900 Penang

Telephone

:

017-4279663

E-mail

:

[email protected]

 

5.2       Any individual who intends to exercise
the abovementioned rights shall make a written request to PINGSPACE together
with the prescribed fee as applicable (such fee shall be solely and finally
determined by PINGSPACE from time to time). PINGSPACE shall, subject to
exemptions, comply with the request and/or take reasonable steps not later than
twenty-one (21) business days from the date of receipt of such request.

 

5.3       In respect of your right to access and/or
correct your Personal Data, PINGSPACE has the right to refuse the your requests
to access and/or make any correction to your Personal Data for the reasons permitted
under law, such as where the expense of providing access to you is
disproportionate to the risks to your privacy.

 

6.         Data
Security and Integrity

 

6.1       The security, integrity and
confidentiality of your Personal Data is of the highest importance to PINGSPACE.
Once any Personal Data comes into our possession, PINGSPACE will take
reasonable steps to protect that information from misuse and loss and from
unauthorised access, modification or disclosure.

 

6.2       However, please be informed that despite
the fact that PINGSPACE endeavours to use the most up-to-date technology and
methods as commercially viable to protect your Personal Data, no security
measures or encryption protocols, no matter how stringent, are perfect or
impenetrable.

 

 

 

 

7.         Disclaimers

 

7.1       PINGSPACE may update this Privacy Policy
from time to time and you should read it carefully each time you download or
use the PINGSPACE App, website or other platform or services, or when you
engage with PINGSPACE by any other means. By
continuing to access or use the PINGSPACE App, website or other platform or
services when such changes are made, or by engaging with PINGSPACE by any other
means, you agree to the revised Privacy Policy.

 

 

 as at 1
February 2021