Information we gather
We may collect information either directly (for example, through information provided when you sign up for a newsletter or register to comment on a forum site) or indirectly (for example, through our site's technology). You are responsible for ensuring that the information you provide us is accurate, complete and not misleading and that such information is kept up to date.
We may collect and process the following information to administer and/or manage your relationship with us including but not limited to the following:
- Information provided when filling up forms on our site, which extends to registering to use the site, subscribing to our services, newsletters and alerts, registering for a conference or requesting a white paper or further information. We may provide explanations on why your personal data is required and how it will be used and you can decide to provide these information or otherwise.
- If you contact us, we may keep a record of that correspondence for our internal compliance purposes.
- Occasionally, you will be requested to complete surveys that we use for research but you are not required to respond to them.
- Any postings, comments or other content that you upload or post on the site.
- Information about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
- Details of your visits to our site and resources you access (including but not limited to, traffic data, location data, weblogs and other communication data).
When this information relates to or identifies you, we will treat it as "personal data". Personal data may include your name, national registration identity card number, date of birth, e-mail address contact details, address and phone number.
Use of collected information
We use personal data to provide information requested, and other purposes which would be described at the point of collection. For example, we may use your personal data including but not limited to the following purposes:
- To assess, process and provide products, services and/or facilities to you.
- To administer and/or manage your relationship with us.
- To respond to your enquiries or complaints on any issues arising from and/or in connection with any transaction with us.
- To arrange your participation in any events organised by us, including meetings, seminars, conferences, trainings, promotions or campaigns.
- To share any of your personal data with our auditor for our internal audit and reporting purposes.
- To share any of your personal data pursuant to any agreement which you have duly entered with us for purposes of seeking legal and/or financial advice.
- To share any of your personal data with a third party necessary for the preparation of agreements to be entered by you (if any).
- To comply with the applicable legal or regulatory requirements and disclosing any of your personal data under the requirements of any applicable law, regulation, direction, court order, by-law or guideline applicable to us.
- To comply with any direction or order from any governmental authority and/or statutory bodies requiring for disclosure of your personal data.
- For our storage, hosting back-up of your personal data whether within or outside Malaysia.
- To fulfil your requests for white papers, articles, newsletters or other content.
- For surveys or research questionnaires.
- To personalise and enhance your site experience and your experience in using our products or services.
- To contact you for marketing purposes where you have agreed to this.
All information requested from you is obligatory and must be provided by you unless stated otherwise. Should you fail to provide the obligatory information, we may not be able to provide you with the relevant product or services requested.
Your IP and browser information will also be analysed to determine the effectiveness of our site, services and products; as well as to help us identify ways to improve our site, services and products.
Sharing of personal data with third parties
Your personal data will not be sold or transferred to any third party without your consent. However, we may disclose your personal data to the following third parties for the performance of one or more of the following purposes:
- Any party under a duty of confidentiality to which has undertaken to keep your personal data confidential which we have engaged to discharge our obligations to you.
- Our auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our business on a strictly confidential basis to provide services to us.
- Any party nominated or appointed by us either solely or jointly with other service providers, for purpose of carrying out our obligations to you.
- Data centres and/or servers located within or outside Malaysia for data storage purposes.
- Storage facility and records management service providers.
- Government agencies, law enforcement agencies, courts, tribunals, regulatory/professional bodies, industry regulators, ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities.
- Our business partners, third party product and/or service providers, suppliers, vendors, distributors, contractors or agents, on a need to know basis, that provide related products and/or services in connection with our business, or discharge or perform one or more of the above purposes and other purposes required to operate and maintain our business.
Sensitive personal data
We take great caution and endeavour to implement appropriate technical, physical, electronic and procedural security methods to maintain the security of personal data collected via our site in compliance with the applicable laws, regulations and industry standards to protect against unauthorised disclosure and/or processing of your personal data.
Whilst we take great caution in implementing security measures to V-Circle's site and your electronic communication with us, it is also your responsibility to understand that the Internet is not a secured medium allowing information and personal data to flow across networks connected to our systems regardless of the security measures and may be accessed and used by people other than those for whom the data is intended.
From time to time, V-Circle's site may present links to and from the sites of our network of partners and advertisers. Should you follow a link to any of these sites, do note that these sites have their own privacy policies and we do not accept any responsibility or liability for these policies or sites. Please check the privacy policies of these sites before you submit any personal data to these sites.
Processing of personal data
Further, our information technology storage facilities and servers may be located in a different jurisdiction from where you access our site or utilise our products and services, in such instances, your personal data may be stored in servers located in different jurisdictions. We shall endeavour to ensure that reasonable measures are taken to ensure that all such third parties will not use your personal data save for the purposes authorised and to adequately protect the confidentiality of your personal data.
To the extent permitted by the applicable law, you have the right to know if we hold your personal data and, if we do, you can request for access to that personal data, request for a copy of and require it to be corrected if it is inaccurate. You may also contact us with regard to any inquiries or complaints in respect of your personal data. You can do this by communicating with us via the contact information set out in below.
In accordance with the Malaysian Personal Data Protection Act 2010, and to the extent not limited by the relevant European data protection laws (including the European Union's General Data Protection Regulation), we may: (i) charge a fee for processing your request for access or correction to the personal data; and/or (ii) refuse to comply with your request for correction to the personal data and provide you with a basis for our refusal.
You can choose not to have or discontinue marketing communications sent to you by selecting certain boxes on the relevant correspondences sent by us or by indicating the same by communicating with us via the contact information set out in below.
You may also communicate with us via the contact information set out below to withdraw your consent to the continued use, disclosure, storing and/or processing of your personal data subject to the conditions and/or limitations imposed by any applicable regulations and laws.
Please note that upon communicating and confirming your decision to withdraw your content for the use, disclosure, storing or processing of your personal data for the purposes set out in this policy, we may not be able to continue to provide the Services to you or to perform any obligations to you. We will not be liable in the event that we are not able to continue to provide the Services to or perform our obligations to you. Our legal rights and remedies are expressly reserved in such event.
Retention of personal data
The personal data provided to us will be retained until the purpose for which your personal data was collected by us has been completed, requested by you to be deleted or as permitted by law. In the event the purposes for which your personal data was collected ceases or is no longer required for the purpose, your personal data will then be destroyed or anonymised from our records in accordance with our internal policy subject to compliance with our operational, legal, regulatory, tax or accounting requirements.
Cookies are text files containing small amounts of information downloaded to your computer or mobile device when you visit a site for record-keeping purposes, and is used by us to track your visit to V-Circle site.
V-Circle may from time to time use web beacons or other technologies for similar purposes which are possibly included in marketing e-mail messages or our newsletters to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor site activity.
Additionally, disabling or refusing cookies will also prevent any web beacons from tracking your user activity on our site. The web beacon will still account for an anonymous visit, but your unique information will not be recorded.
Types of cookies which are used by the site
Strictly necessary cookies - These cookies are essential to enable you to move around the site and use its features, such as accessing secure areas of the site. Without these cookies services, what you have asked for cannot be provided. This category of cookies include Registered Visitor Cookie where a unique identifier is given to each registered user, and is used to recognise them through their visit and when they return to the site.
Performance cookies - These cookies collect information about how visitors use a site, for instance, the pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how a site works.
Mergers, Acquisitions, Reorganizations, etc.
We may, during our business, be subject to or be involved in a merger, acquisition or reorganisation of our company. In the event of these circumstances, we may transfer or otherwise share your personal data/sensitive personal data in connection with these occurrences.
Attention: V-Circle Personal Data Protection Officer