The Personal Data Protection Act 2010 (“PDPA”) which regulates the processing of personal data in commercial transactions apply to Curlec Sdn Bhd (“Company”, “our”, “us” or “we”) as a data user. This written notice (“Notice”) is issued to inform you of how we may use and process your personal data. For the purposes of this written notice, the terms “personal data” and “processing” (including other related terms) shall have the same meaning as prescribed in the PDPA.
By providing your personal data to us, using our services and/or products including any software applications or demos made available by us or continuing access to our website at www.curlec.com and/or any other website owned by us, you declare that you have read and understood this Notice and agree to us processing your personal data in accordance with this Notice.
It is obligatory that you supply us with your personal data where relevant. If you fail to supply us with such personal data, we may not be able to process and/or disclose your data for the purposes as provided below.
- Your personal data includes, where applicable:
- Personal details (name, age, gender, identity card number or passport number, and where applicable, corporate entity/organization registration number etc);
- Contact details (home and office address, email address, telephone and handphone number, facsimile number);
- Social media details (Facebook, Twitter, Instagram, LinkedIn, etc);
- Other relevant information which we may require from you to consider your request and/or participation in any of our products and/or services; and
- Information from third parties and information in the public domain (government departments or agencies, public registries, credit reporting agencies, websites, publications, etc).
- Your personal data may be used and processed for one or more of the following purposes:
- To provide products and/or services to you, administer and give effect to your commercial transactions with us, or perform any contract which you or your principal may have entered with us, including preparing any documentation relevant to the aforesaid transactions and contracts
- To communicate with you
- To identify your location
- To enable us to customize our advertising
- To market and promote products and/or services
- To provide you with information about our products and/or services (including by way of SMS, phone call, email, fax, mail, social media or any other reasonable communication channels)
- To send you electronic announcements, seasonal greetings, invitations and newsletters
- For our internal records;
- To identify you (including publishing your name and photograph) when you participate in any events/activities organized by us
- For research, analysis and improvement, including conducting market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services
- For internal investigations, audit or security purposes
- For compliance with legal and regulatory obligations
- To conduct credit reference checks and establish your credit worthiness where necessary;
- To perform our core operational services
- To administer and respond to request, queries, complaints and legal issues
- To facilitate your participation in and our administration of, any events, including meetings, seminars, conferences, talks, road shows, contest, promotions or campaigns
- For any other purpose that is incidental or in furtherance to the above purposes
- Your personal data is collected from various sources, including information from yourself, third parties and the public domain. Your personal data may also be collected:
- Through your usage of our services and/or its interactive tools and services;
- From certain applications and software made available by us, whether in the form of mobile application or otherwise, which you download and install, and which may receive and collect information transmitted from your computing device for the purpose of providing you with our products and/or services;
- Through cookies on our website, website analytics services and other tracking technology; and
- Through meetings, events, seminars, conferences, talks, road shows, and customer satisfaction surveys organised and/or sponsored by us.
- Your personal data may be disclosed to the following parties who, where relevant:
- Our group of companies (including holding company, subsidiaries, associated companies, and related companies as defined in the Companies Act 2016)
- Government agencies, local authorities, non-government agencies
- Our professional advisors (including legal firms and auditors), vendors, suppliers, agents, contractors, service providers (including data centres, storage facilities and records management service providers), training providers, business partners, insurance companies, banks and/or financial institutions, within or outside Malaysia
- Your immediate family members and/or emergency contact person as may be notified to us from time to time
- The general public when you become a winner in a contest, participate in our events, conferences, talks and seminars by publishing your name, photographs and other personal data without compensation for advertising or publicity purposes
- Any third party (and its adviser or representatives) in connection with any proposed or actual reorganisation, merger, sale, consolidation, acquisition, joint venture, assignment, transfer, funding exercise or asset sale relating to any portion of the Company
- Any person under a duty of confidentiality to which has undertaken to keep your personal data confidential
- Such parties as may be required by law, court, regulator or legal process to disclose
- Such parties as may be permitted under the laws of Malaysia
- Our successor in title
- Any other person which we may deem necessary
- While we endeavour to implement technical, physical, electronic and/or procedural security measures to safeguard against the unauthorised or unlawful processing of, destruction or accidental loss of, damage or alteration to, and unauthorised disclosure of your personal data, and will make reasonable updates to our security measure from time to time, please be aware that the internet is not always secure medium. Communications over the internet such as emails are no secure unless encrypted. Your communications may be routed through a number of countries before being delivered. We cannot and do not accept responsibility for any unauthorised access or interception or loss of personal data that is beyond our reasonable control.
- As our information technology storage facilities and servers may be located outside Malaysia (whether for disaster recovery or otherwise), your personal data may be transferred to places outside Malaysia. In addition, your personal data may also be transferred out of Malaysia in connection with any of the above purposes (if applicable). You understand and allow the said transfer of data outside of Malaysia.
- Unless informed otherwise by you, we assume that the information you provide us is accurate, complete, up-to-date and not misleading, and that you have obtained the necessary consent and authorization to disclose such information. To the extent that you have provided (or will provide) personal data about your family member, spouse, other dependents and/or other individuals, you confirm that you have explained (or will explain) to them that their personal data will be provided to, and processed by, us and you represent and warrant that you have obtained their consent to the processing (including disclosure and transfer) of their personal data in accordance with this Notice. In respect of minors or individuals not legally competent to give consent, you confirm that you are the parent or guardian or person who has parental responsibility over them or the person appointed by court to manage their affairs or that they have appointed you to act for them to consent on their behalf to the processing (including disclosure and transfer) of their personal data in accordance with this Notice.
- You have the right to request access to and request correction of your personal data, subject to payment of the fees prescribed in the First Schedule (Regulation 2) of Personal Data Protection (Fees) Regulations 2013. In accordance with the PDPA, we reserve the right to refuse to comply with your request for access or correction to your personal data for the reasons permitted under the law, in which case we will inform you of our refusal and the reason(s) thereto.
- Subject to our right to rely on any statutory exemptions and/or exceptions to collect, use and disclose your personal data, you may contact us with any inquiries or complaints in respect of your personal data (including any request to limit the processing and use of your personal data, for example, to stop receiving marketing and promotional materials or be contacted for marketing purposes), through the following contact details:
Curlec Sdn Bhd
Private Office 57, Level 8, Komune Co-Working,
Vertical Corporate Tower B, The Vertical, Bangsar South City,
No. 8 Jalan Kerinchi, 59200 Kuala Lumpur, Malaysia
Email: email@example.com (copy to firstname.lastname@example.org)
We reserve the right to update and amend this Notice from time to time. We will notify you of any amendments via announcements on our website or other means as we may determine.
- Pursuant to the PDPA, we provide this Notice in both English and Bahasa Malaysia. In case of any inconsistencies between these two, the English version shall prevail.