In compliance with the Personal Data Protection Act 2010 and its related regulations (collectively, "PDPA"), this privacy notice ("Notice") is issued to all users of our website under the domain www.ipivot.biz ("Website") operated by iPivot Sdn Bhd ("the Company, we, our or us"). This Notice sets out how the Company manages information or Personal Data (as defined in Clause 2 (Description of Personal Data) below) and will inform you of your rights with regards to your Personal Data that has been and/ or will be, collected and processed by us.
In accessing or using the Website, you agree to be bound by, and will be deemed to have read, understood, and agreed to the practices and policies outlined in this Notice as updated from time to time. If at any time you disagree with any part of this Notice, please promptly discontinue your access to or use of the Website.
If you access or use the Website on behalf of another individual (such as your child) or an entity (such as your employer), you represent that you are authorised by such individual or entity to (a) accept this binding Notice on such individual's or entity's behalf, and (b) consent on behalf of such individual or entity to our collection, use, and disclosure of such individual's or entity's information as described in this Notice.
This Notice does not apply to third party sites you may access through, or in the course of your use of, the Website. Your rights in relation to those third parties will be governed entirely by the privacy statements or terms and conditions of those third party sites.
We may amend this Notice from time to time without further notice to you. Any such amended Notice will be displayed on our Website and shall take effect immediately upon the replacement of the Notice.
Collection and processing of Personal Data
We have collected and will collect your Personal Data to be processed by us and/ or on your behalf in the course of your present or future dealings with the Company , our subsidiary(ies), associated company(ies) and joint venture partners, including our and their respective shareholder(s), director(s), employee(s), supplier(s), contractor(s) and/ or permitted person(s). Your Personal Data allow us to achieve the Purposes (as defined in Clause 3 Purpose))in connection with our business.
We shall not knowingly collect or attempt to collect your Personal Data through fraudulent, unlawful, or deceptive practices.
Description of Personal Data
For purposes of this Notice, "Personal Data" has the same meaning as set out in the PDPA and generally refers to information that can identify you when taken alone or together with other information.
The Personal Data that we may collect and/or process include, without limitation:
- your name, age, identity card number or passport number;
- address of correspondence, including office address;
- date of birth;
- marital status, details of children and/or guardian(s);
- income range and financial condition;
- contact information, including e-mail address, mobile number; house number, facsimile number, and office number;
- details of employer;
- details of dependants and/or family members;
- lifestyle preferences, race, religion, nationality;
- information of your web browser including your browsing activity on our Website; and
- any other specific documents required for the Purposes (as defined in Clause 3 (Purpose) below).
The purposes for which we collect and process your Personal Data include, without limitation, the following (collectively, "Purposes"):
Identity verification and assessment
- To verify your identity and ascertain the accuracy of any information provided by you;
- To assess your eligibility to use the Website and/or participate in our services;
- To conduct relevant searches and for communicating with relevant Government authorities, credit rating agencies or any third parties;
- For credit assessments and other background checks as deemed necessary or appropriate by us;
Agreements & Arrangements
- For entry into agreements, contracts, memorandums, and/or arrangements in relation to the services provided by us, including, without limitation, investor agreements, issuer agreements, subscription agreements etc;
- To collect any outstanding payments from you under the agreements, contracts, memorandums, and/or arrangements;
- For delivery of notice, documents, forms, and other documents under the agreements, contracts, memorandums and/or arrangements;
- For necessary performance of other obligations under the agreements, contracts, memorandums and/or arrangements;
- For delivery of our services whether present or future;
- To improve our services;
- To understand your needs and preferences to better provide you with our services;
- To enable you to participate in investment and fund raising activities;
- In the case of investors looking to allocate capital, to confirm that you are eligible to make investments through the Website in accordance with relevant legislation;
- For client relationship management procedures which we deem necessary and fit;
- For client profiling activities in connection with our services;
- For communication with you and delivery of information in connection with our services by e-mail, telecommunication means, including telephone calls or text messages or social media;
- For such other purposes in connection with services offered by us;
Internal Record & External (Marketing)
- For marketing of our services to you whether present or future;
- For purposes relating to any of the above, including but not limited to research, benchmarking and statistical analysis;
- For internal record keeping;
- For prevention, hindrance, reporting of any crime including but not limited to fraud, bribery and money laundering;
- For compliance with any legal or regulatory requirements relating to the provision of our services and to make disclosure under the requirements of any applicable law, regulation, direction, court order, order, by-law, guideline, circular, code applicable to us or any associated, subsidiary, related companies of our group;
We may collect such Personal Data through various means including, without limitation, when you:
- voluntarily provide the same to us;
- contact us or request that we contact you;
- access or use the Website;
- access, use, or request for any of our services; and
- interact with any of our employees.
We may also obtain your personal data from booking forms, registration forms, online forms, agreements that you have signed, name cards or any identity materials that you have distributed voluntarily; and business directory(ies) or listing(s) that you have subscribed to share your information, etc.
Use and Disclosure to Third Parties
Generally, your personal data with us will be kept confidential. However, we may disclose your Personal Data and you hereby consent and authorize us pursuant to the Personal Data Protection Act 2010 to disclose your personal data to the following categories of third parties (collectively, "Third Parties") for any Purpose or as we otherwise deem necessary and appropriate:
- our associated, subsidiary, related companies of the Company;
our business partners including online business affiliates, retailers, distributors, agents ormerchants that provide, supply, distribute or deal in general with our services in connection with our business and in relation to our programs;
any investors, agents, representatives and/or nominees registered or affiliated with us;
our auditors, business consultants, accountants, lawyers or other professional advisers and/or consultants as we deem necessary and appropriate;
our sub-contractors or third party service or product providers as we deem necessary or appropriate, including third party marketing companies or entities;
any relevant Government authorities and credit rating agencies as we deem necessary or appropriate; and
(g) any person to whom we are compelled to or required under law or in response to a local or state or federal authority, industry regulator, enforcement agency, statutory authority, court of laws, tribunal, arbitration centre, commission or council or association legally authorized by law.
These Third Parties will treat your Personal Data as confidential, in accordance with this Notice and with all applicable data protection principles and will process such Personal Data only for the Purposes and within the terms set out herein.
We are responsible for the Personal Data under our control and will take every measure we can to provide a comparable level of protection for Personal Data passed to Third Parties in relation to the services we provide. We will also compile, use and disclose aggregated non-personally identifying information collected through the Website to improve our services and/or business.
It is obligatory for you to supply your personal data to us in the most accurate manner. Failing this, we are unable to process your personal data on your behalf and for the Purposes and all relationships created or to be created between us shall then be terminated and cease to be in effect immediately. If you do not provide us with any of the information we request, or withdraw your consent to us collecting and using your Personal Data, we may also not be able to provide, or continue providing you with, access to or use of the Website.
Right to request access to Personal Data
You are entitled to request access to your Personal Data that is processed by us with reasonable notice.
Right to request correction of Personal Data
You are entitled to request the correction of your Personal Data that is held by us with reasonable notice. With respect to this, you may:
- request for us to correct and/ or update your Personal Data that is inaccurate, incomplete or out-of-date; and
- request for us to retain your Personal Data only as long as necessary for the fulfillment of the Purposes.
Rights to limit processing of your Personal Data
You are entitled to limit our processing of your Personal Data by expressly withdrawing in full, your consent given previously, in each case, including for direct marketing purposes subject to any applicable legal restrictions, contractual conditions and within a reasonable time period.
Contact to make inquiries and complaints regarding Personal Data
If you intend to exercise your rights in Clause 7 (Your Rights) or to make inquiries or complaints regarding your Personal Data, our policies, procedures in relation to processing your Personal Data, you may contact the relevant department as follows:
Attention : Compliance Officer
Contact No. : +603 2201 6302
E-mail address : email@example.com
Postal address : SO 17-1, Menara 1, Strata Office KL Eco City, No.3, Jalan Bangsar, 59200 Kuala Lumpur.
You may visit our Website to learn more about this Notice. This Notice is also available in the Malay language. If there is any inconsistency between the English and Malay version, the English version of this Notice shall prevail.
If any of these terms should be determined to be illegal, invalid or otherwise unenforceable by reason of the laws of any state or country in which these terms are intended to be effective, then to the extent and within the jurisdiction which that term is illegal, invalid or unenforceable, it shall be severed and deleted and the remaining Notice shall survive, remain in full force and effect and continue to be binding and enforceable.
This Notice is governed by and shall be construed in accordance with the laws of Malaysia. Any dispute arising out of or in connection with this Notice shall be subject to the exclusive jurisdiction of the courts of Malaysia.