This Privacy Notice (“Notice”) explains the way we Process the Personal Information that we collect from you in the course of providing Services to you. We will protect and maintain your privacy in accordance with this Notice. This Notice forms part of and shall be read together with all other terms and conditions applicable to the Services that you use. This Notice is applicable only if you are a natural person.
In the event of any conflict between the English and other language versions, the English version shall prevail.
In this Notice:-
The meaning of general words is not limited by specific examples introduced by “including” or “for example” or “such as” or similar expressions.
“Personal Information” means any information in our possession or control that relates directly or indirectly to you (or any other individual) to the extent that you (or the other individual) are identified or identifiable from that information or from that and other information in our possession.;
“Process” includes the handling of Personal Information such as collecting, recording, holding, storing, using and disclosing.
“Services” means any service including membership scheme or products offered by KotaSAS
“KOTASAS” means Tanah Makmur KotaSAS Sdn Bhd (1036705-T) and its Joint Venture partner Wawasan Intact Properties (Pahang) Sdn Bhd (1316426-P);
“KOTASAS Site” means KOTASAS websites including social media, WAP portal, mobile applications and any other sites or portals that we own or operate.
Agreement to Processing of your Personal Information
By providing your Personal Information or obtaining the Services or by visiting or using the KOTASAS Sites, you acknowledge and consent to your Personal Information being Processed by us and disclosed to third parties according to this Notice.
If you provide Personal Information about someone other than yourself (for example about your family members if you have acquired and is responsible for a Service that they will use), we rely on you to inform them that you are providing their Personal Information to us and to ensure they have consented to you giving us their information. By giving their Personal Information, you are regarded to have obtained their consent for disclosure of their Personal Information to us.
Types of Personal Information we collect
The Personal Information we collect depends on the types of products and services you use or subscribe to. The information we collect include:
- your name, profile pictures, photos or avatar, date of birth, nationality, gender, race, marital status, address, email address, phone number, preferred language;
- your particulars of identity documents including NRIC or passport number;
- your bank account and/or payment card details;
- your personal interests and preferences for particular products, services or lifestyle activities when you tell us what they are or when we assume what they are based on how you use our Services;
- your financial information such as your income, income tax or credit history to establish your financial standing, creditworthiness or suitability for any of our products and services applied for (if required);
We also collect and Process details of your usage of our Services including:-
Obligatory or voluntary Personal Information
Your Personal Information that we collect may be obligatory or voluntary. The information which are required in the registration or application form (marked with *) including forms via the KOTASAS Sites, are examples of obligatory information that you need to provide to enable us to Process your application and subsequently provide Services to you. Other obligatory information includes the information referred to above under “Types of Personal Information we collect”. Such Personal Information is collected automatically and if you do not agree to provide such obligatory information we will not be able to or continue to provide the relevant Services or we may limit the provision of the relevant Services.
Sensitive Personal Information
We generally do not require sensitive Personal Information about you for the provision of Service to you unless required by applicable laws. If you do not want sensitive Personal Information collected, please do not submit it. “Sensitive Personal Information” includes any Personal Information as to the physical or mental health or condition, political opinions, religious beliefs or other beliefs of a similar nature, the commission or alleged commission of any offence.
Ways of Collecting Personal Information
Your Personal Information is collected through various methods and channels directly from you, automatically when you use the KOTASAS Sites or Services through cookies and other similar technologies, from our own records of how you use our Services or from third parties, including:
- When you complete a KOTASAS registration or application for Services, service order , direct debit form or similar forms, whether online or otherwise;
- When you use our services;
- When you ask us for more information about a product or service or contact us with a question or complaint;
- From third parties like credit reporting agencies, fraud prevention agencies, law enforcement agencies, financial institutions and other government entities;
- From merchants and other business partners and distribution channels with whom you interact in connection with the Services or KOTASAS Sites,
- From publicly available sources of information like market research providers and business directories;
- When you visit the KOTASAS Sites, online store, Facebook page and other pages that we own and manage;
- When you visit external pages through our portals;
- When you submit your Personal Information through the KOTASAS Sites;
- When you enter any contests or promotions or respond to our surveys or questionnaires or request information from us;
- When you contact KOTASAS by phone. These calls may be recorded for training, quality and business purposes;
- From parties that we nominate or appoint either solely or with other service providers, for purposes of establishing and maintaining a common database where we have a legitimate common interest.
Purpose of Collecting and Processing Personal Information
We Process your Personal Information for purposes which are necessary or related to the provision of our Services including the following:-
- to Process your application to become a member or customer;
- to verify your identity or to assess your creditworthiness by conducting appropriate checks;
- to provide the Services to you;
- to protect and defend our rights or property and the interests of our customers or others;
- to establish and maintain a common database of our customers with other service providers or with parties nominated by us;
- to keep you informed generally about our new products and services and to contact you with offers or promotions based on how you use our products and services;
- to provide the relevant service or product to you,
- to inform you about products and services offered by other companies (including offers and discounts that we have specially negotiated for our customers) that we think may interest you;
- to send public service announcements or seasonal greetings messages either on our behalf or on behalf of third parties whom we think may interest you;
- carry out research and statistical analysis on customer use of our products and services to develop new products and services;
- to comply with regulatory requirements and to provide assistance to law enforcement, judicial or other government agencies;
- to train our staff and manage quality assurance;
- if required or authorized by or under any law or by the order of a court; and
- to manage and improve our Services and KOTASAS Sites;
- for all other purposes in relation to or incidental to the above.
Classes of Third Parties Who May Have Access to Your Personal Information
In the course of providing you with our Services, your Personal Information may be disclosed to certain third parties that KOTASAS works with. Some examples of these third parties are: –
- Credit providers or credit reporting agencies or fraud prevention agencies;
- Our business partners, strategic partners, service and content providers and contractors who are involved in delivering any part of our Services to you;
- Our dealers and agents that work with us to provide our Services or that market and sell our products and services;
- Our professional advisors including lawyers, accountants, tax advisors and auditors, on a need to know basis;
- Parties that we appoint or with other service providers to establish and maintain a common database where we have a legitimate common interest;
- Law enforcement bodies to assist in their functions, Courts of law or as otherwise required or authorised by law;
- Regulatory, government bodies or other authorities if required or authorized to do so to discharge any regulatory function, under any law or in relation to any order or judgment of a court or for the purpose of detection or prevention of crime, unlawful activities or fraud or for the apprehension or prosecution of offenders, or for an investigation relating to any of these
Security of Personal Information
We will implement all appropriate measures to ensure the security and confidentiality of your Personal Information. We will take steps to ensure that the third parties who receive the Personal Information will protect your privacy, keep your Personal Information secure and Process it in accordance with applicable law. We will enter into appropriate contracts with the third parties, which set out sufficient guarantees in respect of the technical and organisational security measures governing the Processing of your Personal Information and ensuring that the third parties take reasonable steps to comply with those measures.
Retention of Personal Information
We will only retain your Personal Information for as long as necessary to fulfil the purpose(s) for which it was collected or to comply with any legal, regulatory and internal requirements. We will take all reasonable steps to ensure that all personal data is destroyed or permanently deleted if it is no longer required for the purpose for which it was collected and Processed.
You will be receiving marketing communications about products and services based on your preferences and interests from us and our selected merchants and strategic partners which includes promotions, marketing materials and information on future events. If you do not intend to receive or continue receiving these marketing communications or should you change your mind in relation to your previous decision, you may opt-out of such marketing communications by contacting us via the contact details provided below. Please note that if you opt out, we will stop sending you marketing communications, but we will continue sending you communications that relate to the Services we provide to you.
Link to Third Party Sites and Services
This Notice applies solely to KOTASAS Sites. If any part of KOTASAS’s Sites links you to third party sites and services, those other sites and services do not operate under this Notice and we do not accept any responsibility or liability arising from those other sites and services. Any Personal Information that you make available on such third party sites or for the subscription of such third party services will be subject to the relevant third party’s privacy notice (if any) and not to our Notice. Before disclosing your Personal Information on such third party site or subscribing to such third party services, you should check that third party’s privacy notice.
Your Obligation to Provide Accurate and Complete Personal Information
You are responsible for providing accurate and complete information to us about yourself and any other person whose Personal Information you provide us and for updating this Personal Information as and when it becomes incorrect or out of date by contacting us.
Revision to Privacy Notice
This Notice may be revised from time to time and the updated version shall apply and supersede any and all previous versions. If we make any changes to this Notice, we will post the changes on www.kotasas.com . If you continue to use the Services after such posting, you will be regarded as having agreed to those changes. If you do not agree to such changes, you may terminate your membership with us or inform us in writing to firstname.lastname@example.org