CompAsia Sdn Bhd (“CompAsia”, “we”, or “us”) knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Notice explains how we collect, protect, use and share information about you when you use smartsub.compasia.com (collectively, the “Website”), as well as any of our services, including plug-ins, that we created for the purposes of using the Website or our services (collectively, the “Services”), and whether you access the Website directly or through a third-party website or via one or more of the Services.
We hope this information increases your confidence in CompAsia and enhances your experience with CompAsia. Each time that you use the Services, you signify that you agree to be bound by the Terms and Conditions and this Privacy Notice. If you do not agree to the terms of this Privacy Notice you must discontinue using the Website and the Services.
(A) Notice Of Information We Collect And How We Use It
We collect two types of data about individuals: (1) technical data automatically collected from all visitors to the Website, and individuals that use the Services (“Passive Data Collection”) and (2) information that you or others voluntarily submit to us (“User-Submitted Information”). “Personal Information,” as used in this Privacy Notice, is information that allows the direct identification of an individual, such as a name, National Registration Identity Card (NRIC) Number or email address, and information that is directly combined with such identifying information. Our primary purpose in collecting Personal Information is to provide you with a safe, smooth, efficient, and customized experience. We only collect Personal Information about you that we consider necessary for achieving this purpose.
(B) Passive Data Collection
We automatically track certain information based upon your behavior on the Website. We use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you and our community.
(C) Mobile Device Information
When you use the Website, we receive information about your mobile device (but not the native manufacturer unique identifier for your device) for purpose of tracking unique downloads. We register your device, and may use the identifier to send you push notifications about your transactions with our service.
(D) Log Files
Like most websites, we automatically receive and record certain information about our users’ behavior on our Website and when using our Services. Our servers automatically gather technical information about our Website traffic and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We aggregate this information with other pieces of information to analyze trends, to administer and improve the Services, to track users’ movements around the Website and to make inventory purchasing decisions that will best serve our customer base. Pages of the Website may also use devices that permit us to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
If we directly combine any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Privacy Notice. Otherwise, we use information collected by passive means in aggregated forms.
(E) Clear GIFs
We use clear gifs in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, you may contact us at firstname.lastname@example.org to request that we remove this information from our database.]
(F) Third Party Advertisers
Third party advertising companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this Website and other web sites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third party web beacon to collect this information. These third party cookies do not collect personally identifiable information.
2. User-Submitted Information
In order to use some features of the Website and the Services, including without limitation the use of products from CompAsia, you must first register with us and create a user name and password. During registration you are also required to give truthful contact and demographic information (including name, email address, postal code and phone number) in accordance with our Terms and Conditions. We use this information to contact you about the Products and Services on our Website in which you have expressed interest.
If you subscribe to our Services, we request certain Personal Information from you on our subscription form, when you access the Services from our Website. You must provide contact information (including name, NRIC Number, shipping address, telephone number) and financial information (including debit/credit card number and expiration date).
We use this information for billing purposes and to manage your subscription. If we have trouble processing a request, we will use this information to contact you.
Before your application can be processed, we will require that you review and consent to our terms and conditions.
(C) Surveys Or Contests
We may provide you the opportunity to participate in surveys or contests on our site. If you participate, we will request certain Personal Information. The requested information typically includes contact information (such as name and shipping address) and demographic information.
We use this information to notify contest winners and award prizes, to monitor Website traffic, or to personalize the Website (in the case of anonymous information collected in surveys) and to send participants an email newsletter. By participating in a survey or contest you submit to that activity’s terms and conditions, including providing us with permission, if required, to share your Personal Information with sponsors of that survey and/or contest.
We may use a third party service provider to conduct these surveys or contests, in which case the third party's service providers use of our users’ Personal Information will be governed by its Privacy Notice, which will be made available to users at the time they enroll for the survey or contest.
(D) Third-Party Account Credentials
When you provide us with your third party account credentials, to such services as Facebook and Google, you understand some content and/or information in those accounts may be transmitted into your account with us. However, information transmitted to our Website from your third party account will be covered by this Privacy Notice.
(E) Communication From Us Or The Website
We use your contact information to communicate with you about CompAsia and our marketing partners, as described below.
(F) Special Offers And Updates
We will occasionally send you information on Services, products, special deals, and promotions. You can take advantage of promotions by entering the promotion code provided at the time of checkout. Out of respect for your privacy, we present the option not to receive these types of communications. If you would like to opt-out of these emails, you may contact us at email@example.com to request that we remove this information from our database.
We send newsletters, usually by email. If you would like to opt-out of these emails, you may contact us at firstname.lastname@example.org to discontinue newsletters.
(G) Messages About The Service And Your Account
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
Based upon the Personal Information you provide us, we will send you a welcoming email to verify your username and password. We will communicate with you in response to your inquiries, to provide the services you request, to update you on the status of your requests, to manage your account, and to provide the best customer service possible.
3. Disclosure Of User-Submitted Data
(A) COMPASIA Partners
CompAsia engages in marketing and promotional activities with carefully screened brands, or, “Partners,” which we think will appeal to our user base. We may make our user list available to Partners so that you may receive catalogs, product information, or promotions from our Partners. If you choose your information not to be disclosed for the purposes of the Partner’s promotions, please contact us at email@example.com. We also may send or permit Partner promotions via email. You may opt out of such promotional emails or Partner mailings by unsubscribing thru emailing us at firstname.lastname@example.org.
From time to time, Partners may also be provided with non-identifying or aggregate information indicating the demographic information of users on our Website, buying behavior, and opportunities to market to select segments of our customer base indirectly. When we share aggregate user data, we do so in a way that it cannot be linked with a user's Personal Information.
(B) Service Providers
We may provide Personal Information to third parties for their use in performing internal business functions (e.g., mailing, maintenance, security, data analytics, email transmission, CRM, database management services, payment processing or data hosting) on our behalf. These service providers agree to only use your Personal Information in accordance with this Privacy Notice and for no other purpose than to provide us or our Partners with the contracted-for services.
(C) Related Parties
We may share some or all of your Personal Information with our affiliates (including a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us), in which case we will seek to require those affiliates to honor this Privacy Notice.
(D) Credit Scoring
1. By agreeing to CompAsia SmartSub Privacy Notice, you agree and consent to CompAsia and Credit Bureau Malaysia Sdn Bhd (“Credit Bureau Malaysia”) to:
a) conduct credit, property, litigation, trade, CCRIS, DCHEQS, due diligence, identity, compliance risk and any other checks, review, monitoring and verifications which are relevant to your business relationship/credit facility/transaction/potential engagement with CompAsia on yourself under Credit Reporting Agencies (CRA) Act 2010 at any time, for as long as such business relationship/credit facility/transaction/potential engagement continues to exist and/or where any dues owed to CompAsia remain unpaid and outstanding;
b) disclose your information including trade information/account conduct to Credit Bureau Malaysia and/or any registered credit reporting agency/ies;
2. You would also grant consent to Credit Bureau Malaysia & any other registered credit reporting agency/ies under the CRA Act to:
a) procure your CCRIS, DCHEQ and any other credit information from relevant data sources;
b) disclose credit information and other information pursuant to checks, review, monitoring and verifications mentioned in Clause
1(a) above relating to yourself to CompAsia as and when the services of the credit reporting agency/ies is/are used for purposes mentioned above;
c) share any information including trade information as mentioned in Clause 1(b) above to other subscribers of their services;
d) transfer and disclose any credit information relating to yourself to relevant third parties and/or data processor either located within or places outside Malaysia when required.
3. You would agree that;
a) consent wherever mentioned in this letter is irrevocable and shall continue to be valid to the extent it remains consistent with any changes in law and for as long as there is existing business relationship/credit facility/transaction/potential engagement continues to exist and/or any dues owed to CompAsia remain outstanding. For this purpose, your Personal Information shall be disclosed to our contractors i.e. debt-collection agencies and/or other parties that assist with debt recovery functions appointed by us to recover the amount and interest due where necessary;
b) the database of Credit Bureau Malaysia & the relevant registered credit reporting agency/ies may retain credit and trade information relating to you as long as it is consistent with applicable laws and any changes thereto;
c) Credit Bureau Malaysia & the relevant credit reporting agency(s), its respective directors, officers, members, servants or agents are absolved and held harmless from all liability however arising from the abovementioned consent, the exercise of any/all activity stated above by Credit Bureau Malaysia & the relevant credit reporting agency(s) including the subsequent disclosure of any information relating to yourself to the Company.
(E) As Required By Law / Certain Business Transactions
We may disclose Personal Information if we have a good-faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law or in connection with an actual or proposed corporate transaction or insolvency proceeding involving all or part of the business or asset to which the information pertains. This may include responding to legal requests from jurisdictions outside of Malaysia, where we have a good faith belief that the response is required by law in that jurisdiction.
(F) To Protect Rights
Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of the Terms and Conditions, or our other agreements; take precautions against liability; protect the rights, property, or safety of CompAsia, any individual, or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; or assist government enforcement agencies.
(G) Co-Branded Sites
In the event that our Website links to other websites that include our branding, this Privacy Notice does not apply to those other websites. Visitors to those websites are advised to carefully read the policies on those individual websites.
(H) Tracking Technologies And Tailored Advertisements / Choices
CompAsia also partners with advertising companies to place our advertising on publisher websites on the Internet. These advertising companies collect anonymous information about your visits to our Website by placing and reading cookies on the device you use to access our web site. The cookies do not collect or use Personal Information. These tracking technologies are used to analyze user behaviors in the aggregate. They are used to analyze and optimize our App or Website, measure conversion, and tailor content to interests.
(I) Links To Other Websites
The Website may contain links to other sites that are not owned or controlled by CompAsia. Please be aware that this Privacy Notice applies only to information collected by CompAsia and we are not responsible for the privacy policies and practices of such other sites. We encourage you to be aware when you leave the Website and to read the privacy policies of each and every website.
(J) Access To Personally Identifiable Information
If your information changes, or if you no longer desire our Services, you may correct, update, delete it or deactivate your account by emailing our Customer Service at email@example.com.
The security of your information is important to us, including, but not limited to, the Personal Information collected via the Website. We use reasonable security measures to protect against the loss, unauthorized access, misuse, alteration and destruction of Personal Information under our control, both during the transmission and once we receive it. This includes, but is not limited to, the use of firewalls and encryption. Although we make good faith efforts to maintain the security of such Personal Information, no method of transmission over the Internet or
method of electronic storage, is 100% secure and we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining this information. We keep Personal Information no longer than necessary for legitimate business purpose or as required by law.
As part of securing personal data stored on our servers, we restrict access to Personal Information to CompAsia employees, contractors and agents who need to know that information in order to operate, develop or improve the Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or the Website or by providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.
If a security systems breach occurs, we may post a notice on our homepage (smartsub.compasia.com) or elsewhere on the Website and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. This notice paragraph applies to users of Services and the Website.
(L) Change Of Ownership
In the event of a change in ownership, or a merger with, acquisition by, or transfer or sale of all or a portion of our assets to, another entity, we reserve the right to transfer all of your Personal Information, including email addresses, to that entity. We will use reasonable efforts to notify registered users of any such transfer to an unaffiliated third party (by a posting on our homepage, or by email to your email address that you provided to us, as chosen by us in our discretion).
The [ Children and Young Person Act ] protects the online privacy of children under 14 years of age. CompAsia and the Website are not directed toward individuals under the age of eighteen (18), and we request that such individuals do not provide Personal Information through our Website. Additionally, we do not knowingly collect or maintain Personal Information from anyone under the age of 18, unless or except as permitted by law. If we learn that Personal Information has been collected from a user under 18 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 18 who has registered on the Website or you believe has otherwise provided Personal Information to CompAsia, please contact CompAsia at firstname.lastname@example.org to have that child’s account terminated and information deleted.
(N) Changes In This Privacy Notice
We may change this Privacy Notice from time to time. The most recent version of the Privacy Notice will always be posted on the Website, with the "Effective Date" posted at the top of the Privacy Notice. We may revise and update this Privacy Notice if our practices change, as technology changes, or as we add new services or change existing ones. If we make any material changes to our Privacy Notice or how we handle your personal information, or we are going to use any Personal Information in a manner that is materially different from that stated in our Privacy Notice at the time we collected such information, we will give you a reasonable opportunity to consent to the change. By using our Website or Services after the Effective Date, you are deemed to consent to our then-current Privacy Notice.
(O) Contact Us/Feedback
If you have questions, concerns or feedback regarding this Privacy Notice, you can contact us at email@example.com