Privacy Notice

Foz One and its group of companies, affiliates, subsidiaries, reinvested entities and any other designated companies within its group (collectively, “Foz One” or “we” or “our” or “us”) are committed to protecting and respecting your privacy. This Privacy Notice is required under the Personal Data Protection Act 2010 (“PDPA”) and it explains how we handle your personal data. Please read this Privacy Notice carefully to understand our privacy practices. By visiting our website, you are accepting and consenting to the practices described in this Privacy Notice.

For the purposes of this Privacy Notice, please note that:

• “personal data” means any information which relates directly or indirectly to you, who is identified or identifiable from that information, and/or your dealings with us. This information may include your name, NRIC number, passport number, address, occupation, details of your company, contact details, car number plate details, details of your account(s), the type of products offered to you, your financial information and such other necessary information regarding yourself and your transaction(s) including sensitive personal data.
• “sensitive personal data” means any information relating to your health (including without limitation, any information/data as stated in your MySejahtera (or other similar apps/ program)), political opinions, religious beliefs or any other personal data prescribed under the PDPA.

1. THE PERSONAL DATA WE COLLECT

In order for us to provide you with our products and services, we may be required to process, including collect, use, disclose and store, your personal data as follows:

1.1 Information you give us

This is information about you that you give us by filling in forms or enquiries on our website, our visitor management system and any other websites or sites as provided by Foz One from time to time (“our Sites”) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our Sites. The information you give us may include:

1. name;
2. NRIC number/ passport number/ company registration number, as the case may be;
3. car number plate;
4. company details and related documents;
5. correspondence address (home address, office address);
6. home and work e-mail address;
7. personal and work telephone number;
8. marital status and details of spouse and children (with consent from parents or guardians for children below 18 years old) (as applicable);
9. bank details, financial and credit card information and financial related documents;
10. sales and services tax number;
11. employment history;
12. education and other qualifications;
13. personal description and photograph;
14. other personal information as may be disclosed by you; and
15. other information as we may require.

1.2 Information we collect about you

With regard to each of your visits to our Sites, we will automatically collect the following information:

1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version.
2. information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products or services you viewed or searched for, download errors, length of visits to certain pages, page interaction information and any phone number used to call our customer service number.

1.3 The personal data to be submitted may be mandatory or optional

If the personal data required is mandatory and you fail to provide such information, we may not be able to process your dealings with us. If the personal data required is optional, you may choose not to provide such information and we will be able to process your dealings with us.

2. COOKIES

2.1 Our website uses cookies and other similar tracking technologies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Sites.

2.2 By accessing, visiting and using our Sites, you agree to the use of cookies and other technologies.

2.3 You can manage cookies by changing the settings of your Internet browser to notify you when a cookie is being set or updated, or to disable, delete or block cookies altogether. However, by doing so, it may limit certain functionality of our Sites or prevent our Sites from loading properly or you may not have access to certain features of our Sites and it may have an impact on the quality of your browsing experience.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect your personal data when you deal with us in connection with the provision of our products and services. The sources of your personal data are as follows:

1. Information we obtain when you submit forms or orders (whether through our Sites or otherwise): This includes details as stated under Paragraph 1.
2. Information we obtain through our transactions with you: This includes your transactions, bank accounts details, claims history and payment records.
3. Information we obtain through the internet or social media sites: This includes your personal data which are publicly available such as on Linkedin, Facebook, credit reference agencies and government linked websites (such as Companies Commission of Malaysia).
4. Information from other sources: This includes personal data to which you have given your consent to disclose personal data relating to you and/or where not otherwise restricted.

4. THE PURPOSE FOR COLLECTING YOUR PERSONAL DATA

Your personal data is collected to allow us and our authorised agents to process your dealings with us, which may include one or more of the following purposes:

1. to carry out our obligations arising from any contracts entered into between you and us;
2. to provide you with the information, products and services that you request from us;
3. to access and manage your transactions so that we can provide you with more and up-to-date information such as improvements and new features to our existing products and services, developments, promotions and offers which may be of interest to you;
4. to manage and maintain your account(s) registered with us through regular updates, consolidation and improving the accuracy of our records, including records of purchases, sales and other transactions. In this manner, we can respond to your enquiries, complaints and resolve any disputes to better improve our business relationship with you;
5. to conduct research for analytical purposes, data mining and analyses of your transactions on our products and services to better understand your future needs;
6. for purposes of employment screening and other related background verifications in accessing your employment application with us;
7. for purposes of our business development and planning;
8. for event management such as inviting you to our events;
9. to perform shared services within our group such as audit, compliance, legal, human resources, risk management;
10. to administer our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
11. to improve our Sites to ensure that content is presented in the most effective manner for you and for your computer;
12. to allow you to participate in interactive features of our service, when you choose to do so;
13. as part of our efforts to keep our Sites safe and secure;
14. to comply with the requirements of any law binding on us such as conducting anti-money laundering checks, crime detection or prevention, prosecution, protection or enforcement of our rights to recover any debt owing to us including transferring or assigning our rights, interests and obligations under any of your agreements with us; and
15. for any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities.

We will seek your consent before processing your personal data for a purpose other than those set out in this Privacy Notice and/or in the terms of any of your agreements with us.

5. HOW WE PROTECT YOUR PERSONAL DATA

5.1 We strive to ensure your personal data is accurate, complete, not misleading and kept up-to-date at all times.

5.2 Your personal data is securely stored in our database server to which only our authorised employees and agents can have access to. The access is given only to the extent necessary to enable such persons to process your personal data for the purposes described in Paragraph 3 above. To prevent any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction of your personal data, we have in place adequate security measures governing the processing of your personal data and any authorised employees or agents involved in such processing, in accordance with the PDPA.

5.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

6. ACCESSING YOUR PERSONAL DATA

6.1 You may make a data access request in writing for information of your personal data that is being processed by us or request for a copy of your personal data held by us. Your right of access can be exercised in accordance with PDPA. We will endeavor to comply with your request within 21 days of receiving your completed form and the relevant processing fees.

6.2 If your personal data is inaccurate, incomplete, misleading or not up-to-date, you may make a data correction request in writing to us and we will make the necessary correction to your personal data.

6.3 We may request for documentary evidence to verify your identity. Please note that we may withhold your access to your personal data to the extent permitted by the PDPA to avoid incidents of fraud and/or inaccurate information. In such situations, we will notify you in writing of the refusal and reasons for the refusal.

7. DISCLOSURE TO THIRD PARTIES

7.1 We may disclose your personal data to the extent it is necessary and appropriate to process your dealings with us to the following parties. You agree that we have the right to share your personal information with:

1. any member within FOZ One;
2. our business partners or suppliers for the performance of any contract we enter into with them or you;
3. our potential business partners. As we continue to develop our business, we may buy, merge or partner with other companies as well as selling or transferring all or part of our assets. In such transactions, your personal data may be disclosed to our potential business partners;
4. our agents, service providers and/or professional advisers who assist us in (i) processing, administering, fulfilling transactions or providing value added services that you have requested; and (ii) performing supporting activities or functions on our behalf, such as research, marketing, customer support, recruiting, web hosting, data storage, analysis and processing, and legal and financial services;
5. your employer if you are an employee of FOZ One’s customers. We may provide your employer with your personal data collected when you register an account with our Sites or use our Sites;
6. any person authorised or appointed by you to give instructions to us on your behalf such as your agents, accountants, auditors, lawyers and financial advisers;
8. analytics and search engine providers that assist us in the improvement and optimisation of our Sites;
9. to any other third party engaged by us; or
10. with your consent, at your request or as allowed by law.

7.2 Your personal data may also be disclosed by us where the disclosure is permitted under the PDPA, including but not limited, to the following:

1. where the disclosure is necessary for the purpose of preventing or detecting a crime or for the purpose of investigations;
2. where the disclosure was required or authorised by or under any law or by the order of a court;
3. where the disclosure is necessary to enable us to respond to third party claims; and/or
4. where the disclosure is necessary to protect the rights, property, or personal safety of FOZ One, its business partners, authorised agents, customers, and the public. This includes exchanging information with other organizations and authorities concerning cyberattacks, fraud prevention, spam/malware prevention, and similar purposes.

8. INFORMATION FROM CHILDREN

Our Sites, products and services are primarily intended for adults only and we do not collect personal data from children below the age of 18 without the prior consent of the child’s parents or guardian. If a child’s personal data is collected with prior consent of the parents or guardian, we will only use or disclose the personal data as permitted by law. If we discover that we have unintentionally collected personal data of a child below the age of 18 without the prior consent of the child’s parents or guardian, we will remove that child’s personal data as soon as possible.

9. TRANSFER OF PERSONAL DATA

We may transfer your personal data to places outside Malaysia when carrying out any of the purposes stated under this Privacy Notice. In such circumstances, we will take all reasonable measures to ensure that your personal data has an appropriate adequate level of protection and safeguards and is processed as required under the applicable laws. By choosing to use our Sites, you consent to any such transfer of personal data outside of Malaysia.

10. RETENTION OF YOUR PERSONAL DATAG

We will retain your personal data for the duration of your relationship with us or for the period as may be necessary to protect your interest and our interest, as allowed by law.

11. EXERCISING YOUR CHOICE IN RESPECT OF DISCLOSURE AND USE OF YOUR PERSONAL DATA FOR MARKETING PURPOSES

11.1 You may exercise your choice in respect of the disclosure and use of your personal data by us. In the event you choose not to receive any marketing materials from us with respect of our products or services, you may either contact us at the contact details provided below or by choosing to opt out from receiving marketing materials, a choice provided for in the relevant forms.

11.2 Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

11.3 Please note that irrespective of the choice you make in relation to the above, you may still contact us subsequently through the contact details provided below in order for you to change your choice. Your latest choice communicated to us will apply. We will update your most recent marketing preference in our database.

12. CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice is governed by and construed in accordance with Malaysian law. We may update our Privacy Notice from time to time. In the event there are material changes in the way we treat your personal data, we will publish a notice on our website to inform you on the same and/or through other means of communications deemed suitable by us. Unless notified as such, our current Privacy Notice applies to all personal data provided by you to us. We recommend that you regularly review our website to ensure that you are always aware of our current practices. Any revised Privacy Notice will supersede and replace any previous privacy notice effective as of the date on which the revised Privacy Notice is posted. Your continued use of our Sites and services after any changes to our Privacy Notice signifies your consent, acceptance and agreement to the updated terms under our Privacy Notice.

13. HOW TO CONTACT US

Should you have any enquiries, comments and requests about this Privacy Notice, you may contact us as below: