This Privacy Notice describes how NCD2U.com and its related companies including but not limited to its affiliates (collectively referred to as “the Company”, “us” or “we”) collect, store and handle personal information (as defined below) of individuals is consistent with the Personal Data Protection Act of Malaysia and Singapore, as well as the General Data Protection Regulation (GDPR) in the European Union.
We value the trust you have placed in us and respect your privacy. Please read this Privacy Notice to understand how we use the personal information we may collect from you, why we collect it, and how we use it. By providing your Personal Information to us, you are consenting to this Privacy Notice and the collection, use, access, transfer, storage and processing of your personal information as described in this Privacy Notice.
What does it mean for you to give consent?
By providing your Personal Information to us and/or continuing access to our website, software, apps and/or any other products and services (collectively referred to as “Services”) offered by the Company, you are consenting to this Privacy Notice and the collection, use, access, transfer, storage and processing of your personal information as described in this Privacy Notice. If you do not agree to this Notice or any amendments to this Notice, please do not subscribe to any of our Services and stop using or accessing our website.
What Personal Information do we collect?
Defining Personal Information
In this Privacy Notice, Personal Information refers to any data, whether true or not, about an individual 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, including data in our records as may be updated from time to time.
Examples of such Personal Information you may provide to us include, but not limited to (depending on the nature of your interaction with us) :-
- Date of Birth
- Telephone number(s)
- Mailing address
- Email address
- Payment information (credit card, paypal, cost centre/code, bank account details, billing address )
- Network data
- Any other information relating to any individual which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you
- Information about any transactions, both free and paid, that you enter into on our websites
- Information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google
- Publicly available information that we acquire from service providers
Legal basis for processing Personal Data under General Data Protection Regulation (GDPR)
If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.
When and how we collect your Personal Information
We may collect personal information directly from you when you:-
- Fill up application or registration forms or other similar forms
- Interact and communicate with the Company at any events or activities
- Communicate with us (for example when you contact us for any enquiries including by calling our customer service)
- Register interest and/or request for information of (through our online portals or other available channels)or subscribe to our products and/or services
- visit or browse our websites
- register or subscribe for our publications (for example, newsletters)
- use our network and other services of the Company
- request us to contact you, be included in an email or other mailing list
- provide feedback to us (for example via our websites or in hard copy)
- use some of our services, for examples, websites and apps including establishing any online accounts with us
- interact with our customer service officer, for example, via telephone calls, letters, online accounts with us
- contacted by and respond to our customer service officer, for example, via telephone calls, letters, online accounts with us
- subscribe to any of our Subscription Services, which require us to collect and process payment information from you such as your credit card numbers and billing information, using third party PCI DSS-compliant service providers
Information we collect from third parties
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.
Purposes for the Collection of your Personal Information
Your Personal Information will be used by the Company to:-
- Verify your identity
- update and inform you on our latest promotion, etc
- send you automated email messages or marketing materials regarding our products and services
- administer or otherwise carry out obligations in relation to any agreement that you or your business have with us
- respond to your inquiries about our programs of services, membership matters
- communicate with you, such as keeping you abreast of current developments, technical up-dates, news, articles or any matter that may be of interest to you
- conduct research and market surveys
- develop, enhance, market and provide products and services to meet your needs
- gain an understanding of your information and communication needs in order for us to provide you with better services
- maintain and develop our business systems and infrastructures, including testing and upgrading of these systems
- support recruitment inquiries
- personalize marketing communications and website content based on your preferences, such as in response to your request for specific information on products and services that may be of interest
- contact individuals that you refer to us and identify you as the source of the referral, in accordance with the “Referral” section below
- meet contract or legal obligations
- improve browsing experience by personalizing the websites
- send information or content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business
- promote use of our services and products to you and share promotional and information content with you in accordance with your communication preferences;
- provide other companies with statistical information about our users — but this information will not be used to identify any individual user;
- send information to you regarding changes to our Privacy Notice, or other legal agreements
We also may use the information in other ways for which we provide specific notice at the time of collection.
What if you do not want to provide us with your personal information?
If you do not provide your personal information to us, we may not be able to:
- provide you with the product or service you want
- manage or administer your product or service
- personalize your experience with us
- verify your identity or protect against fraud, or
- let you know about other products or services that might better meet your needs.
If you choose to use our referral service to tell a friend about our products, you represent that you have their consent to provide us your friend’s name and email address.
Data Subject Rights
You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this notice.
In certain circumstances, you have the following data protection rights:
- The right to access.update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification.You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object.You have the right to object to our processing of your Personal Data.
- The right of restriction.You have the right to request that we restrict the processing of your personal information.
- The right to data portability,You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent.You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
- Right to erasure.You have the right to ask us to delete your information from our systems at any time by contacting us at email@example.com. However, please be aware that if we do not have your permission to hold your information, we will not be able to provide you with our services.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact the data protection authority of your country or EU Member State.
Protecting your Personal Information
The Company ensures that your personal information is secured and protected. Your personal information is stored in a database, protected by password, and accessible only to you and the Company’s employees who require access to perform necessary responsibilities related to the management of your accounts. You can choose to access your registered information with the Company via our Secure Web Server that will encrypt the data while it is transferred through the Web.
Storage of Personal Information
The Company will secure storage of the Personal Information collected in the following ways in compliance with the minimum-security measures prescribed under the PDPA, its regulation and standards:
- register all those who are allowed access
- control and limit access based on necessity
- maintain proper record of access and transfer of Personal Information
- ensure all employees of the Company protect confidentiality
- conduct awareness programmes to all employees (if necessary) on responsibility to protect Personal Data
- establish physical security procedures
- bind third parties involved in processing of Personal Information
We retain the Personal Information we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims.
Consent to International Transfer of Personal Information
You acknowledge that in order to provide services to you, we may need to transfer your Personal Information to recipients in countries other than the country in which the information was originally collected. Whenever your Personal Information is transferred internationally, we will take appropriate steps to ensure its security and confidentiality in accordance with applicable data protection law.
Disclosure to Third Parties
Your personal data may be transferred, assessed or disclosed to third parties for the purposes and additional purposes. Further, the Company may engage other companies, service provider or individuals to perform function on its behalf and consequently may provide access or disclose to your Personal Data to such service provider or third parties referred to in this section (without limitation) :-
- Event management companies and event sponsors
- Market research companies
- IT service providers
- Data analytics and/or marketing agency
- Credit Card verification providers
- The Company partners and advertisers, which include parties with whom the Company collaborates with for certain events, programmes and activities
- Other associated companies of the Company
- Governmental authorities to comply with statutory, regulatory and governmental requirements
- Other third parties in order to process your commercial transactions;
- Legal bodies as permitted or required by law such as in compliance with a warrant or subpoena issued by a court of competent jurisdiction
- Safety and security personnel
Ownership of Content and Materials
All content and materials are copyrighted and protected by worldwide copyright laws and treaty provisions. They cannot be copied, reproduced, modified, published, uploaded, posted, transmitted, or distributed in any way without prior written permission of the copyright owner and/or the Company.
A link from our Web site to another site does not imply endorsement of that site. Linked sites are not under the control of the Company and the Company will not be held responsible for the content or privacy policies of any linked sites or any links containing other linked sites. If you decide to access any of the third party sites linked to the Company, you will do this entirely at your own discretion and at your own risk.
If you access any third party sites using the links provided, the operators of these sites may collect your personal information. Please ensure that you are satisfied with the privacy statements of these third Party Sites before you submit any personal information. The Company cannot be held responsible legally or otherwise for the activities, privacy policies or levels of privacy compliance of these third party sites.
Sensitive Personal Information
We will never ask you to provide sensitive Personal Information such as information about your medical or health records, political, religious or philosophical beliefs, criminal offences (alleged, or committed), criminal conviction background, racial or ethnic origin, trade union membership, sexual orientation, sexual history, behavior or genetic data. Please refrain from providing us with such sensitive Personal Information.
Procedure for Unsubscribing and Opt-Out
You may opt out of receiving such marketing email messages at any time by sending a message with “unsubscribe” in the subject line to firstname.lastname@example.org, or by following the instructions in any marketing communication.
Updating of Privacy Notice
The Company will, as and when it deems fit to do so, change, alter or modify its Privacy Notice. You are advised to visit the Website continually in order to monitor changes in the notice, as the notice will be binding upon you.