1.1. We at Ejen2u International Sdn Bhd (Company No.: 1343460-U), a private company limited by shares incorporated under the laws of Malaysia (the “Company”, “we”, “us” and/or “our”) recognise the importance of privacy and the overall sensitivity of personal data and information. As required under the Personal Data Protection Act 2010 (“the Act”), the purpose of this Personal Data Protection Notice (the “Notice”) is for the adherence of the regulations set forth under the Act and shall at all times act as the official notice of the Company in describing how the Company manages, safeguards, collects, gather, and process your personal data when you appoint and/or engage our services, use or access our website and other digital platforms of the Company and/or interact with us in any capacity which includes through meetings, seminars, conferences, discussions and/or events.

1.2. “Personal Data” or “personal data” generally means any such information and/or data, whether true or not, about an individual who can be identified from that data and other information to which an organisation has or is likely to have access which includes but not limited to identification details, contact details and any other information which may lead to your identification.

1.3. By agreeing to engage our services, submitting your own or another individual’s personal data, registering for an account with us, visiting our website and/or other digital platforms, you and such other individual acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Notice, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS NOTICE, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR WEBSITE.

1.4. We reserve the right to amend and/or update this Notice at any time without prior notice. To the fullest extent permissible under applicable law, your continued use or engage our services, use of website and/or to communicate with us subsequent to any amendments and updates to the Notice shall constitute your acknowledgment and acceptance of the amendments and updates made to this Notice.

 

2.1. The Company will/may collect personal data about you:

2.1.1. when you register and/or engage our services or website and/or other digital platform;

2.1.2. when you submit any form, including but not limited to, application forms or other forms relating to our services, whether via online or physical form;

2.1.3. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;

2.1.4. when you interact and communicate with us, which includes but not limited to, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails.

2.1.5. when you use our electronic services or interact with us via our application or use of services on our website and/or other digital platform. This includes, without limitation, through cookies which we may deploy when you interact with our application or website;

2.1.6. when you carry out transactions through our services;

2.1.7. when you provide us with feedback or complaints; and

2.1.8. when you submit your personal data to us for any other reason.

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

 

3.1. The Company may from time to time collect personal data in the course of our services by which the data is provided by yourself and or your representatives and or by any individual on your behalf in which case, we will assume, until notified otherwise, that you have authorised the disclosure of such data to us.

3.2. The Company may also, from time to time, collect personal data through the access of our website and/or any digital platforms owned and operated by the Company for the purpose of communications, subscriptions and enquiries with regard to our company and/or our services

3.3. Personal data collected will be mainly provided by you, however some personal data may also be collected by us from other available sources which includes but not limited to credit reporting agencies, government department or agencies, public registries, websites, social media, publications, events, seminars and conferences for the purpose rendering our services to you and compliance with legal and regulatory requirements under the laws of Malaysia.

3.4. The personal data that the Company may collect includes but is not limited to:

3.4.1. Name;

3.4.2. Email address;

3.4.3. Date of birth;

3.4.4. Billing address;

3.4.5. Bank account and payment information;

3.4.6. Telephone number;

3.4.7. Gender;

3.4.8. Information sent by or associated with the device(s) used to access our website and/or any digital platform;

3.4.9. Information about your network;

3.4.10. Photographs or audio or video recordings;

3.4.11. Government issued identification or other information required for our due diligence, know your customer, identity verification, or fraud prevention purposes;

3.4.12. Marketing and communications data, such as your preferences in receiving marketing from us and third parties, your communication preferences and history of communications with us, our service providers, and other third parties;

3.4.13. Usage and transaction data, including details about your searches, the advertising and content you interact with on the website or digital platform, and other services related to you;

3.4.14. Location data;

3.4.15. Any other information about the user when the user signs up to engage our services, and when the user uses the services or website and/or digital platform, as well as information related to how the user uses our services or website and/or digital platform; and

3.4.16. Aggregate data on content the user engages with.

3.5. You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. The Company reserve the right at our sole discretion to require further documentation to verify the information provided by you.

 

4.1. The Company or our authorized service providers and advertising partners may from time-to-time use “cookies” or other features to allow us or third parties to collect or share information in connection with your use of our services or website. These features help us improve our website and the services we offer, help us offer new services and features, and/or enable us and our advertising partners to serve more relevant content to you, including through remarketing. “Cookies” are identifiers that are stored on your computer or mobile device that record data about the computer or mobile device, how and when the services or website are used or visited, by how many people and other activity within our website. We may link cookie information to personal data. Cookies also link to information regarding what items you have selected for purchase and web pages you have viewed. This information is used to deliver content specific to your interests, to enable our third-partyadvertising partners to serve advertisements on sites across the internet, and to conduct data analysis and to monitor usage of the services.

4.2. You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this you may not be able to use the full functionality of our website or the services.

 

5.1. Your personal data is collected and processed by us for our business activities which includes but not limited to the following purposes:

5.1.1. to verify your identity;

5.1.2. to communicate with you including responding to your enquiries;

5.1.3. all purposes related to or in connection with our engagement;

5.1.4. to comply with legal and/or regulatory requirements including court orders;

5.1.5. for our day-to-day operations and administrative purposes including file management, billing and collection, audits, reporting, investigations etc.;

5.1.6. for the purposes of enforcing or defending our legal rights and/or obtaining legal advice;

5.1.7. to send you materials or publications including newsletter, articles or updates or information about events, conferences, seminars, talks which may be of interest to you;

5.1.8. to promote, offer or market our services to you;

5.1.9. to send as potential referees that may assist the growth of your business;

5.1.10. to assist in the prevention, detection or investigation of crime or possible criminal activities or for the administration of justice;

5.1.11. for security and internal audit purposes;

5.1.12. for such other purposes as may be directed or consented to by you; and

5.1.13. for all other purposes in relation to or incidental to the above.

 

6.1. The Company will implement a variety of security measures and strive to ensure the security of your personal data on our systems. Your personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security.

6.2. The Company will retain personal data in accordance with the Act and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such personal data. If you cease using the website, or your permission to use the website and/or the services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Notice and our obligations under the Act. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

 

7.1. Under certain circumstances, we may be required to disclose your personal data to third parties. Third parties to whom your personal data may be disclosed by us are as follows:

7.1.1. any persons directed by or consented to by you;

7.1.2. any persons required for the purposes of the legal engagements and/or legal transactions including but not limited to counter parties, other advisors, financial institutions, regulatory bodies etc;

7.1.3. any person for the purposes of compliance with legal and regulatory requirements;

7.1.4. our data processors i.e. third party who we engage to process personal data on our behalf including but not limited to archival storage, data entry service providers, computer backup services, disaster recovery services, banks and financial institutions etc.; and

7.1.5. our professional advisors including but not limited to legal advisors, tax advisors, financial advisors, auditors, insurance brokers etc.

7.2. Further, we may also be required to transfer your personal data outside of Malaysia for the purposes and to such third parties stated in this Notice. The transfer of your personal data outside Malaysia would also be required if you are travelling, residing or based outside Malaysia.

 

8.1. Our Platform uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your device, to help the website analyse how users use the website. The information generated by the cookie about your use of the website and/or any digital platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

8.2. We, and third parties, may from time to time make software applications downloads available for your use via the website or through the services. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your device’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by the Company. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.

 

9.1. We acknowledge that you have the right in deciding the information you wish to provide to us. The provision of the information listed above is voluntary in nature. However, please note that if you do not provide the information above or limit the way such information is to be processed, it may result in us not being able to:

9.1.1. communicate or correspond with you;

9.1.2. undertake the legal engagement or transaction and/or to provide our services to you; and/or

9.1.3. grant you access to our website

 

10.1. WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the personal data confidential. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.

10.2. In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within the website. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our website) may not be received by us.

10.3. We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our website and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

 

11.1. Withdrawing Consent

11.1.1. You may withdraw your consent for the collection, use and/or disclosure and/or request deletion of your personal data in our possession or under our control by sending an email to [email protected] , and we will process such requests in accordance with this Notice and our obligations under the Act and other applicable law. However, your withdrawal of consent may mean that we will not be able to continue providing the services to you and we may need to terminate your existing relationship and/or the contract you have with us.

11.2. Requesting Access to or Correction of Personal Data

11.2.1. You may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. The Company will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to [email protected].

11.2.2. The Company may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

11.2.3. We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in the Act, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances.

11.2.4. We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in the Act, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances.

 

If you have any questions or concerns about our Notice, we welcome you to contact us by e-mail at [email protected].