1.1 This is the privacy policy (“Privacy Policy”) of KooDoo (PS Tech Solution Sdn Bhd) and its affiliates (including but not limited to its subsidiaries, related, associated and affiliated companies, whether such companies are residing, situated, carrying on business, incorporated or constituted within or outside Malaysia) (“KooDoo”).
1.2 This Privacy Policy applies to personal information about individuals held by the KooDoo. The KooDoo will only process your Personal Data in accordance with the Personal Data Protection Act 2010, the applicable regulations, guidelines, orders made under the PDPA and any statutory amendments or re-enactments made of the PDPA from time to time (collectively referred to as the “PDPA”) as well as this Privacy Policy.
1.3 The KooDoo reserves the right, at its sole discretion, to modify, update or amend this Privacy Policy from time to time with reasonable prior notice to you. The KooDoo will notify you of any changes via announcements on the KooDoo’s mobile application (“App”) and websites (“Site”) or other appropriate means as determined by the KooDoo. Any changes to this Privacy Policy will be effective upon notice to you. By continuing to use the services and/or access to the Site and/or App after being notified of any changes to this Privacy Policy, you will be treated as having agreed to and accepted those changes.
1.4 You may obtain a copy of this Privacy Policy on https://www.mykoodoo.com/privacypolicy.html or by contacting the KooDoo at the contact details below.
1.5 If you do not agree to this Privacy Policy or any changes to this Privacy Policy, KooDoo may not be able to render all services to you and you may be required to terminate your relevant agreement with the KooDoo and/or stop accessing or using the Site and/or App.
2.1 The term “Personal Data” means any information in the possession of the KooDoo or control of the KooDoo that relates directly or indirectly to an individual to the extent that the individual can be identified or are identifiable from that and other information in the possession of the KooDoo such as name, address, telephone number, NRIC, email address, etc. The KooDoo may “process” your Personal Data by way of collecting, recording, holding, storing, using or disclosing it.
2.2 Your Personal Data may be collected from you during your course of dealings with the KooDoo in any way or manner including pursuant to any transactions and/or communications made from/with the KooDoo. The KooDoo may also collect your Personal Data from a variety of sources, including without limitation, at any events, seminars, road shows, customer satisfaction surveys organised or sponsored by the KooDoo and/or from the cookies used on the Site and/or App.
2.3 In addition, the KooDoo may also receive, store and process your Personal Data which are provided or made available by any third parties, credit reference bodies, regulatory and law enforcement authorities, for reasons including delivery of the KooDoo’s products and/or services, performance of conditions of agreements and/or to comply with the KooDoo’s legal and regulatory obligations.
Your Personal Data may be processed for the following purposes:
(a) to communicate with you;
(b) to provide products and/or services to you;
(c) to respond to your enquiries or complaints;
(d) to process your purchase and/or contest entry;
(e) to provide you with information and/or updates on the present and future developments, other products, services and/or promotions offered by the KooDoo and selected third parties which may be of interest to you from time to time by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
(f) to send you seasonal greetings messages from time to time;
(g) to send you invitation to join the KooDoo’s membership, events and promotions and launch events;
(h) to monitor, review and improve the KooDoo’s membership, events and promotions, products and/or services;
(i) to process and analyse your Personal Data either individually or collectively with other individuals;
(j) to conduct market research or surveys, client profiling activities, planning and statistical analysis within the KooDoo in relation to the KooDoo’s present and future developments, other products and/or services;
(k) to share any of your Personal Data with the auditor for the KooDoo’s internal audit purposes;
(l) to share any of your Personal Data with a third party necessary for the preparation of legal documents or contract to be entered by you with the KooDoo;
(m) to share any of your Personal Data with a third party necessary for the purpose of applying and obtaining insurance policy(ies), where necessary;
(n) to maintain and improve customer relationship;
(o) to maintain and update internal record keeping;
(p) for registration for a user account with the KooDoo;
(q) for internal administrative purposes;
(r) for audit and risk management purposes;
(s) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
(t) for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
(u) for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to the KooDoo;
(v) to enforce or defend the KooDoo’s rights and your rights under, and to comply with, the KooDoo obligations under the applicable laws, legislation and regulations; and/or
(w) for other purposes required to operate and maintain the KooDoo’s business,
(collectively referred to as the “Purposes”), and you agree and consent to the KooDoo using and processing your Personal Data for the Purposes in the manner as identified in this Privacy Policy. If you do not consent to the KooDoo processing your Personal Data for one or more of the Purposes, please notify the KooDoo at the contact details below.
It is obligatory for the KooDoo to collect and to retain your Personal Data unless stated otherwise. If you do not supply the KooDoo with your Personal Data, or do not consent to the above or this Privacy Policy, the KooDoo will not be able to:
(a) to process your purchase of any of the KooDoo’s products and/or services;
(b) communicate with you;
(c) provide you with the KooDoo’s products and/or services requested;
(d) accept and process your entry to any contest;
(e) update you on the KooDoo’s latest products, services and/or promotions; and/or
(f) allow you to access certain sections of the Site and/or App where log in is required,
and you may be required to terminate your agreement or discontinue your business relationship with the KooDoo.
The KooDoo will not disclose any of your Personal Data to any third party without your consent except to the following third parties, for one or more of the above Purposes:
(a) companies within the KooDoo and their respective employees;
(b) your immediate family members and/or emergency contact person as may be notified to the KooDoo from time to time;
(c) successors in title to the companies within the KooDoo;
(d) any party who is involved in connection with corporate exercises, such as a potential or actual sale/disposal of any business or interest of any companies within the KooDoo, merger, consolidation, re-organisation or funding exercise relating to any companies within the KooDoo, or asset sale, or in the event of winding-up of any companies within the KooDoo;
(e) the KooDoo’s business partners and affiliates that provide related products and/or services in connection with the KooDoo’s business for joint promotions and/or contests;
(f) any person under a duty of confidentiality to which has undertaken to keep your Personal Data confidential which the KooDoo has engaged to discharge the KooDoo’s obligations to you;
(g) any party in relation to legal proceedings or prospective legal proceedings;
(h) the KooDoo auditors, consultants, lawyers or other financial or professional advisers on a need to know basis for the purpose of those advisers providing advice to the KooDoo;
(i) any party nominated or appointed by the KooDoo either solely or jointly with other service providers, for purpose of establishing and maintaining a common database where the KooDoo has a legitimate common interest;
(j) data centres and/or servers located within or outside Malaysia for data storage purposes;
(k) payment channels including but not limited to financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to the KooDoo in connection with your purchase of the KooDoo’s products and/or services;
(l) government agencies, law enforcement agencies, courts, tribunals, regulatory bodies, ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities;
(m) any provider of public utility or related services, whether or not governmental owned and/or any corporations approved and established for the provision of utility services and facilities.;
(n) the KooDoo’s contractors or sub-contractors as may be necessary for discharging the KooDoo’s duties and obligations under any document or agreement duly entered by you with the KooDoo;
(o) the KooDoo’s appointed product and/or service providers, suppliers or agents, to discharge or perform one or more of the above Purposes;
(p) any persons, authorities or regulators to whom the KooDoo is permitted or required to disclose to under the applicable laws; and/or
(q) the general public when you become a winner in a contest by publishing your name, photographs and other Personal Data without compensation for advertising and publicity purposes.
The KooDoo aims to keep all Personal Data as accurate, complete, not misleading, up-to-date and reliable as possible. Therefore, the accuracy of your Personal Data depends to a large extent on the information you provide. As such, it is a condition of the KooDoo providing the products and/or services to you that you:
(a) warrant and declare that all your Personal Data submitted or to be submitted to the KooDoo are accurate, not misleading, updated and complete in all respects for purposes of acquiring or using the relevant products and/or services and you have not withheld any Personal Data which may be material in any respect and that the KooDoo is authorized to assume the authenticity and updatedness of the Personal Data given by you when processing the Personal Data submitted by you to the KooDoo (and the KooDoo is not obliged to independently verify any of such Personal Data); and
(b) you understand and agree to, the importance of the need to, update the KooDoo as and when such Personal Data provided earlier to the KooDoo becomes inaccurate, incomplete, misleading, outdated or changes in any way whatsoever by contacting the KooDoo at the contact details below.
7.1 Subject to the exceptions provided under the PDPA, you have the right to request for access to, request for a copy of, request to update or correct, your Personal Data held by the KooDoo. The KooDoo may charge a small fee (such amount as permitted by the PDPA) to cover the administration costs involved in for processing of your request to access your Personal Data.
7.2 In respect of your right to access and/or correct your Personal Data, the KooDoo has the right to refuse your request to access and/or correct your Personal Data for the reasons permitted under the law, such as where the expense of providing access to you is disproportionate to the risks to your privacy, or where the rights of others may also be violated, amongst other reasons.
7.3 You have the right at any time to request the KooDoo to limit the processing and use of your Personal Data (for example, requesting the KooDoo to stop sending you any marketing and promotional materials or contacting you for marketing purposes).
7.4 In addition, you also have the right to inform the KooDoo on your withdrawal (in full or in part) of your consent given previously to the KooDoo subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be effected.
Any of your Personal Data provided to the KooDoo is retained for as long as the purposes for which the Personal Data was collected continues; your Personal Data is then destroyed unless its further retention is required to satisfy a longer retention period to meet the operational, legal, regulatory, tax or accounting requirements of the KooDoo.
9.1 The KooDoo is committed to ensuring that your Personal Data is stored securely. In order to prevent unauthorised access, disclosure or other similar risks, the KooDoo endeavours, where practicable, to implement appropriate technical and organisational measures in accordance with the applicable laws and regulations to safeguard against and prevent the unauthorised or unlawful processing of your Personal Data, and the destruction of, or accidental loss, damage to, alteration of, unauthorised disclosure of or access to your Personal Data.
9.2 The KooDoo will make reasonable updates to its security measures from time to time and ensure the authorised third parties only use your Personal Data for the Purposes set out in this Privacy Policy, and to adequately safeguard your Personal Data.
9.3 The Internet is not a secure medium. However, the KooDoo will put in place various security procedures with regard to the Site and/or App and your electronic communications with the KooDoo.
9.4 Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may be routed through a number of countries before being delivered – this is the nature of the World Wide Web/Internet.
9.5 The KooDoo cannot and does not accept responsibility for any unauthorised access or interception or loss of Personal Data that is beyond the KooDoo’s reasonable control.
The KooDoo’s information technology storage facilities and servers may be located in other jurisdictions outside of Malaysia. Your Personal Data may be transferred to entities outside of Malaysia. This may include, but not limited to, instances where your Personal Data may be stored on servers located outside of Malaysia. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in Malaysia under the laws of Malaysia. You hereby expressly consent to the KooDoo transferring your Personal Data outside of Malaysia for such purposes. The KooDoo shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of Malaysia shall not use your Personal Data other than for that part of the Purposes and to adequately protect the confidentiality and privacy of your Personal Data.
(a) If any part of the Site and/or App links you to other websites, those websites do not operate under this Privacy Policy and the KooDoo does not accept any responsibility or liability arising from these websites.
(b) Likewise, if you subscribe to an application, content or a product from a strategic partner of the KooDoo and you subsequently provide your Personal Data directly to that third party, that Personal Data will be subject to that third party’s privacy policy (if they have such a policy) and not to this Privacy Policy.
(c) The KooDoo recommends you to read and understand the privacy statement/policy posted on those other websites in order to understand their procedures for collecting, processing, using and disclosing personal data and before submitting your Personal Data to these websites.
(d) The App does use third party services that may collect information used to identify you.
Link to privacy policy of third party service providers used by the app
(a) The KooDoo employs an industry standard technology called “cookies”. The cookie is a small piece of information stored on the hard drive of your computer or device for record-keeping purposes, and is used by the KooDoo to track your visits to the Site and/or App. Cookies may be used to save your preferences for your ease and convenience when using the Site and/or App. Third party advertising networks may issue their separate cookies to your hard drive when serving advertisements.
(b) The type of anonymous click stream data collected by the KooDoo through the cookies may include your Internet Protocol address, web browser software, date and time of visit of the Site and/or App, and whether your requests (including search requests and clicking on links to parts of the Site and/or App) were met with successfully. All such information collected through cookies are not Personal Data and you cannot be identified from this information. Such information is only used for the purpose of managing and creating a better user experience and to identify areas for improvement on the Site and/or App.
(c) The use of cookies is now an industry standard, and you will find them used on most major websites. Most browsers are initially set up to accept cookies. If you prefer, you can reset your browser either to notify you when you have received a cookie, or to refuse to accept cookies. You should understand that areas of certain sites will not function properly if you set your browser to not accept cookies.
If you have any questions about this Privacy Policy or would like to make a complaint or data access or correction request, you may contact the KooDoo at the contact details below:
[Personal Data Protection Officer/Legal Officer
Email Address: [email protected]
Last Updated on December 2020