PRIVACY AND PERSONAL DATA PROTECTION POLICY

1.1 This policy (“Privacy Policy”) describes how GFG TECH SDN. BHD. (Company No. 1423861-V) (“GFG”) manages Personal Data which is in our possession or under our control. “Personal Data”, is defined in the Personal Data Protection Act 2010 of Malaysia (“PDPA”), and currently refers to any information in respect of commercial transactions, that relates directly or indirectly to an individual, who is identified or identifiable from that information or from that and other information which is in our possession and includes any sensitive personal data and expression of opinion about the individual.

1.2 By using our services pursuant to your agreement(s) with us (“Services”), operating any account maintained with us, accessing the online platform operated by us (which is accessible through our website at www.roomsos.com, or through our mobile application) (“Platform”), websites or mobile applications, or otherwise providing information to or communicating with us, you are taken to have agreed to our collection, use, processing and disclosure of your Personal Data in accordance with this Privacy Policy.

1.3 This Privacy Policy  does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other rights which we may have at law to collect, use, process or disclose your Personal Data.

1.4 The words “we”, “us”, “our” or any of their derivatives refer to GFG and its successors and any novatee, assignee, transferee or purchaser of GFG’s rights and/or obligations hereunder and any reference to GFG includes a reference to such successor, novatee, assignee, transferee or purchaser. The words “you”, “your”, “yours” or any of their derivatives refer to the person using our Services, operating any account maintained with us, accessing our Platform, website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).

1.5 This Privacy Policy shall be governed by, and construed in accordance with, the laws of Malaysia. Without prejudice to your rights under any applicable laws, any dispute arising out of or in connection with this Privacy Policy and/or the documents referred to herein, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by the Courts of Malaysia and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the Courts of Malaysia.

GFG PRIVACY POLICY

Your privacy is important to us. It is GFG TECH SDN. BHD. (1423861-V)’s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website, www.roomsos.com and others sites we own and operate.

This policy is effective as of September 2013 and was last updated on 3 May 2021. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

1. INFORMATION WE COLLECT

Information we collect includes both information you knowingly and actively provide us when using or participating in any of our services and promotions, and any information automatically sent by your devices in the course of accessing our products and services.

1.1 LEGITIMATE REASONS FOR PROCESSING YOUR PERSONAL INFORMATION

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

1.2 WHAT PERSONAL INFORMATION DO WE COLLECT FROM THE PEOPLE THAT VISIT OUR BLOG, WEBSITE OR APP?

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number or other details to help you with your experience.

1.3 LOG DATA

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, other details about your visit, and technical details that occur in conjunction with any errors you may encounter.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

1.4 PERSONAL INFORMATION

We may ask for personal information which may include one or more of the following:

  • Name
  • Email
  • Social media profiles
  • Date of birth
  • Phone/mobile number
  • Home/mailing address

1.5 COLLECTION AND USE OF INFORMATION

We may collect personal information from you when you do any of the following on our website:

  • Enter any of our competitions, contests, sweepstakes, and surveys
  • Sign up to receive updates from us via email or social media channels
  • Use a mobile device or web browser to access our content
  • Contact us via email, social media, or on any similar technologies
  • When you mention us on social media
  • Use Live Chat
  • Open a Support Ticket
  • Enter information on our site, mobile app and online forms.

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to enable you to customise or personalise your experience of our website
  • to contact and communicate with you
  • for analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms
  • for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you
  • to consider your employment application
  • to enable you to access and use our website, associated applications, and associated social media platforms
  • for internal record keeping and administrative purposes
  • to run competitions, sweepstakes, and/or offer additional benefits to you
  • to comply with our legal obligations and resolve any disputes that we may have
  • for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use

Please be aware that we may combine information we collect about you with general information or research data we receive from other trusted sources.

2. HOW DO WE PROTECT YOUR INFORMATION?

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

  • We use regular Malware Scanning.
  • Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
  • We implement a variety of security measures when a user places an order to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. We will comply with laws applicable to us in respect of any data breach.

You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services.

2.1 HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. If your personal information is no longer required, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

3. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

We may disclose personal information to:

  • a parent, subsidiary, or affiliate of our company
  • third party service providers for the purpose of enabling them to provide their services, for example, IT service providers, data storage, hosting and server providers, advertisers, or analytics platforms
  • our employees, contractors, and/or related entities
  • our existing or potential agents or business partners
  • sponsors or promoters of any competition, sweepstakes, or promotion we run
  • courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
  • third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you third parties to collect and process data

3.1 THIRD-PARTY LINKS

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

3.1.1 GOOGLE

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

3.1.2 WE USE GOOGLE ADSENSE ADVERTISING ON OUR WEBSITE.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

3.1.3 WE HAVE IMPLEMENTED THE FOLLOWING:

  • Remarketing with Google AdSense
  • Google Display Network Impression Reporting

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

3.1.4 GOOGLE OPTING OUT:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

3.2 INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

The personal information we collect is stored and/or processed where we or our partners, affiliates, and third-party providers maintain facilities. Please be aware that the locations to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

3.2.1 CALIFORNIA ONLINE PRIVACY PROTECTION ACT

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

3.2.2 ACCORDING TO CALOPPA, WE AGREE TO THE FOLLOWING:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.

You will be notified of any Privacy Policy changes:

  • On our Privacy Policy Page

Can change your personal information:

  • By emailing us

3.2.3 FAIR INFORMATION PRACTICES

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur within 30 business days.
We will notify the users via in-site notification

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

4. YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION

You always retain the right to withhold personal information from us, with the understanding that your experience of our website may be affected. We will not discriminate against you for exercising any of your rights over your personal information. If you do provide us with personal information you understand that we will collect, hold, use and disclose it in accordance with this privacy policy. You retain the right to request details of any personal information we hold about you.

If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time. We will provide you with the ability to unsubscribe from our email-database or opt out of communications. Please be aware we may need to request specific information from you to help us confirm your identity.

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

4.1 HOW DOES OUR SITE HANDLE DO NOT TRACK SIGNALS?

We honour Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

4.2 DOES OUR SITE ALLOW THIRD-PARTY BEHAVIOURAL TRACKING?

It’s also important to note that we allow third-party behavioural tracking

5. COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old.

6. DO WE USE ‘COOKIES’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

7. WE USE COOKIES TO:

  • Keep track of advertisements.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

If you turn cookies off, Some of the features that make your site experience more efficient may not function properly.It won’t affect the user’s experience that make your site experience more efficient and may not function properly.

8. LIMITS OF OUR POLICY

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

9. CHANGES TO THIS POLICY

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

10. CONTACT US

For any questions or concerns regarding your privacy, you may contact us using the following details:

GFG TECH SDN. BHD.
admin@roomsos.com