PRIVACY POLICY

A. PREAMBLE

We, THE GROUP (as defined in our Terms of Use), respect the privacy of Users (as defined in our Terms of Use) who use our Services (as defined in our Terms of Use), our Portfolios (as defined in our Terms of Use), and our Platform (as defined in our Terms of Use) with regard to their Personal Data, and are committed to protecting the privacy of our Users (as defined in our Terms of Use), and strive to provide a safe and secure user experience.

This Privacy Policy is in accordance with the Personal Data Protection Act 2010 ("PDPA") and its subsidiary regulations, which describe how your Personal Data is collected, process and used, and your choices with respect to your Personal Data.

This Privacy Policy shall be used and applicable to all THE GROUP’s members, alliances, affiliates, brands, product and services.

The following discloses our information gathering and dissemination practices for our Platform and if relevant, for the use of, or subscription to, or purchase of Services offered by us.

I. INFORMATION COLLECTED BY THE PLATFORM

1. Our Platform do not automatically recognize specific information about individual Users on our Platform. In addition, our Platform do not automatically record information regarding Users information such as their email addresses unless the Users supply it.
2. We collect information about Users during the registration process for certain parts of our Services and/or Platform, through Users participation in certain activities, including but not limited to contests, forums, polls, and through the use of cookies.
3. When you request pages from our server, it automatically collects some information about your preferences, including your internet protocol (“IP”) address. We use this to help diagnose problems with our servers, and to administer our Platform.
4. Your Personal Data may be collected, stored, and processed through your use of our Service and/or Platform, and are used to improve our Services and the content of our Platform, and/or used for marketing purposes.

II. COLLECTION & RETENTION OF PERSONAL DATA

1. Your Personal Data that have been provided and disclosed to us shall be voluntary, and may be collected, retained, processed, shared, and/or disclosed to our Authorized Third Parties (as hereinafter defined) for the following purposes (collectively, "Purposes"):
   1. to manage, verify and complete transactions with you;
   2. to manage and verify your membership or subscription with us;
   3. to direct market our Services and Portfolios to you;
   4. to understand and analyze our sales and Services, and your needs and preferences;
   5. to develop, enhance, market and provide Services to meet your needs;
   6. to enable your participation in our marketing and promotions;
   7. to process exchanges or returns of any of our Services;
   8. to improve our Platform and Services;
   9. to widen the reach of our Services, Portfolios, and/or our Authorised Third Parties’ services;
   10. to respond to your requests or complaints;
   11. to send you updates on our Services, news and event updates, rewards and promotions, special privileges and initiatives offered by THE GROUP and/or our Authorized Third Parties (as defined herein);
   12. to process your payment transactions, if any;
   13. for our credit control service and/or collection of debts due and owing to us; and
   14. to conduct customers’ due diligence, if necessary; and
   15. to comply with any regulatory, statutory or legal obligation imposed on us by any relevant authority.
2. We reserve our rights to disclose and share your Personal Data to any third party for whatsoever purpose whether directly or indirectly relevant to our Services, Portfolios, and/or nature of business.
3. Although the precise details of the Personal Data collected will vary according to the specific purpose, we may typically collect the following Personal Data from or in relation to you as follows:
   1. Full name;
   2. Address;
   3. Phone number(s);
   4. Date of birth;
   5. Email address;
   6. Gender;
   7. Race;
   8. Transaction Details; and
   9. Identity card number or passport number.

III. USE AND DISCLOSURE

1. We may disclose your Personal Data within our organization, group of companies, alliances and affiliations, and/or to our Authorized Third Parties for the Purposes set forth hereinabove in accordance with the terms and conditions set out herein.
2. We are responsible for the Personal Data under our control and retention, but shall not be held responsible for the Personal Data disclosed or shared by us to any of our Authorized Third Parties.
3. “Authorized Third Parties” shall have the same meaning as defined in our Terms of Use.
4. We use and disclose aggregated non-personally identifying information collected through our Platform as part of our organization's process of constantly improving the Platform and Services offered by THE GROUP.

IV. IMPACT OF NON-PROVISION OF PERSONAL DATA

Please note that in the event that a sufficient and/or relevant Personal Data is not supplied, or is not satisfactory to us, then your application or request for any of the above Purposes or any of our Services may not be accepted, or acted upon, or your request to browse some information on the Platform, or the use of, or subscription to, or purchase of any Services offered by us may be denied or affected.

V. STORAGE AND RETENTION OF PERSONAL DATA

1. Your Personal Data may be stored in hard and/or soft copies at our offices, and/or in servers located inside and/or outside Malaysia.
2. It may be necessary to transfer your Personal Data to our Authorized Third Parties service providers based/located outside Malaysia. By continuing to use the Platform and/or Services and/or Portfolios offered by THE GROUP, you hereby consent to such transfer.
3. Your Personal Data provided to us will be retained by us as long as necessary for the fulfilment of our Services, Portfolios, and the Purposes stated above, or as required to satisfy legal regulatory, accounting requirements or to protect our interests.

VI. EMAILS AND MESSAGES

1. We may preserve the content of any email and/or other electronic messages that we received.
2. Any Personal Data contained in those messages will only be used or disclosed in ways set out in this Privacy Policy.
3. The message content may be monitored by our Authorized Third Parties service providers or employees for Purposes stated herein, including but not limited, to compliance, auditing and maintenance or where email abuse is suspected.

VII. COMMUNICATION OR UTILISATION DATA

1. Through your use of telecommunications services to access our Platform, your communication data/device (e.g. IP address) or utilization data (e.g. information on the beginning, end and extent of each access, and information on the telecommunications services you accessed) are technically generated and could conceivably relate to your Personal Data.
2. To the extent that there is a compelling necessity, the collection, retention, processing and use of your communications or utilization data will occur and will be performed in accordance with the PDPA and its subsidiary regulations.

VIII. AUTOMATIC COLLECTION OF NON-PERSONAL DATA

1. When you access our Platform and/or use any Services offered by us, we may automatically collect non-personal data (such as type of Internet browser and operating system used, domain name of the website from which you came, number of visits, average time spent on the site, and pages viewed).
2. THE GROUP may use this non-personal data and share it within its organization (including but not limited to all of its related companies, subsidiaries, alliances and affiliates, and associated companies) and/or with its Authorized Third Parties, to monitor the attractiveness of our Services and Platform, and improve our Platform performance and content, and also to improve our Services.
3. THE GROUP, additionally, reserves its right to disclose, share, and/or transfer your non-personal data to any of its Authorised Third Parties and/or any third party for whatsoever purposes whether directly or indirectly relevant to its nature of business, Services, and/or Portfolios.

IX. ONLINE TRACKING AND ADVERTISING

We and our Authorized Third Parties who have been appointed/authorized by us to provide content, advertising, or functionality or measure and analyse advertisement performance on our Platform, may use cookies, web beacons, mobile advertising identifiers, and similar technologies to facilitate administration and navigation, to better understand and improve our Platform, to determine and/or improve the advertising shown to you, or within the Platform operated and/or managed by THE GROUP, and to provide you with a customized online experience.

Cookies

1. Cookies are small files that are placed on your computer when you visit our Platform. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same Users across one or more browsing sessions, and across one or more sites.
2. Cookies can help us and our Authorized Third Parties understand which parts of our Platform are the most popular because they help us see which pages and features Users access and how much time they spend on the pages. By studying this kind of information, we are able to adapt our Platform and provide our Users with a better experience.
3. Most browsers accept cookies automatically, but it can be configured not to do so or to notify the Users when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. If you disabled browser cookies or flash cookies, it may interfere with the proper functioning of our Platform.

Beacons

1. Together with our Authorized Third Parties, we may use technologies called beacons (or pixels) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device.
2. We and our Authorized Third Parties use beacons for a variety of purposes, including to analyze the use of our Platform and/or Services, and to provide content and advertisements that are more relevant to you (used together with cookies).

Local Storage and Other Tracking Technologies

1. We may use other type of technologies, such as Global Positioning System (GPS), Local Shared Objects (also referred to as flash cookies) and Hypertext Markup Language revision 5 (HTML5) local storage, in connection with our Platform.
2. We also may use unique identifiers associated with your device, such as mobile advertising identifiers. These technologies are similar to cookies. They are stored on your device and can be used to store certain information about your activities and preferences.
3. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings.

Additional Choices with respect to Targeted Advertising

1. THE GROUP and its Authorized Third Parties may use cookies and other tracking technologies to facilitate serving relevant advertisements to you.

X. CONFIDENTIALITY

Without prejudice to all our rights as stated in this Privacy Policy, any Personal Data held by us will be kept confidential in accordance with this Privacy Policy, pursuant to the PDPA and its subsidiary regulations.

XI. SECURITY

1. 1.Our Platform has security measures in place to protect the loss, misuse, theft and alteration of the Personal Data under our control.
2. No data transmission over the internet can be guaranteed as completely secure. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data transmitted to us, and Users shall do so at their own risk. Once any Personal Data comes into our possession, we will take reasonable steps to protect that Personal Data from misuse, theft, loss and from unauthorized access, modification or disclosure.
3. A username and password may be essential for you to use some sections of our Platform. For your own protection, we require you to keep these confidential and to change your password regularly (if required).

XII. LINKS

Our Platform may contain links to external sites. We are not responsible for the privacy practices or the content of such external sites. We have established relationships with our Authorized Third Parties but such relationships are generally technical in nature, or content collaborations. Users who feel they do not wish their Personal Data to be shared by anyone other than us and/or our Authorized Third Parties, may then opt out of completing the registration.

XIII. RIGHT OF ACCESS TO PERSONAL DATA

1. 1.Under the PDPA, you have the right of access to your Personal Data held by us on payment of a prescribed fee and/or to request correction of the Personal Data that is inaccurate, incomplete, misleading or not up-to-date.
2. If you have any questions regarding this Privacy Policy, or if you wish to request access to your Personal Data, or if you wish to correct your Personal Data, or if you wish to withdraw your consent for future communication, you may send your request in writing to:
   Personal Data Protection Officer
   Email: support@spriicommerce.com
   Address: Unit 05-05, Level 5, Tower B, Vertical Business Suite II, Avenue 3, Bangsar South City, No.8, Jalan Kerinchi, 59200 Kuala Lumpur, Malaysia.

XIV. CHANGES TO PRIVACY POLICY

We reserve the right to amend this Privacy Policy from time to time without prior notice. Any changes to the Privacy Policy will be uploaded onto our Platform and therefore, we encourage you to check/visit our Platform from time to time for any changes on a regular basis.