PRIVACY AND COOKIES POLICY

Your privacy is important to us. This Privacy and Cookies Policy (“Policy”) sets out the basis which JA Secure Sdn. Bhd. (“we”, “us”, “our”, ”the Company” or “JaguarTransit”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act 2010 (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONALDATA

1. As used in this Policy:

“customer” means an individual who (a) has contacted us through any means to find out more about any services we provide, or (b) may, or has, entered into a contract with us for the supply of any services by us; and

“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.

3. Other terms used in this Policy shall have the meanings given to them in the PDPA(where the context so permits).

COLLECTION,USE AND DISCLOSURE OF PERSONAL DATA

4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

5.  We may collect and use your personal data for any or all of the following purposes:

(a)   performing obligations in the course of or in connection with our provision of the services requested by you;

(b)  verifying your identity;

(c)   responding to, handling, andprocessing queries, requests, applications, complaints, and feedback from you;

(d)  managing your relationship with us;

(e)  processing payment or credit transactions;

(f)    sending your marketing information about our services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;

(g)   complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(h)  any other purposes for which you have provided the information;

(i)     transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Malaysia or abroad, for the aforementioned purposes; and

(j)    any other incidental business purposes related to or in connection with the above.

6. We may disclose your personal data:

(a)   where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you; or

(b)  to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.

7.  The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter(including, where applicable, a period to enable us to enforce our rights under any contract with you)

THIRD PARTY WEBSITES

8.   Users may find advertising or other content on our Site that is linked to the sites and services of our partners, suppliers, advertisers, sponsors, licensors or other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services have their own privacy policies and customer service policies. As such, browsing and interaction on any other website, including websites which have a link to our site, is subject to that website’s own terms and policies.

 WITHDRAWING YOUR CONSENT

9.   The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you inwriting. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

10. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fifteen (15) business days of receiving it.

11. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.

12. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

13.  If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

14.  Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

15.  We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

16.  To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

17.   You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

18.  We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

19.  We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

20.  We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

WEB BROWSER COOKIES

21.  Our Site may use “cookies” to enhance User experience. Most sites, like ours, use cookies for record-keeping purposes and at times to track information about the User. The User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. However, do note that as a result, some User activity or Site functionalities may be limited and there might be slight delays in the Site’s operations. 

DATA PROTECTION OFFICER

22.  You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner: