Personal Data Protection Policy
Effective Date: 1st October 2020
This Personal Data Protection Policy (“Personal Data Protection Policy”) explains how Melaka Privilege Sdn. Bhd., its affiliates, and its subsidiaries (“VIVIFY,” “us,” “our,” and “we”) use your personal data and this Personal Data Protection Policy applies to anyone who uses our websites, applications, platforms, devices and programs – including mobile applications, touch technologies, electronic services, chat functionality, interactive features, online services or any of our described activities that we own or control (collectively, the “Services”). For terms that govern the use of the Services, please review the Services’ User Terms and Conditions or the Merchant Terms and Conditions, as applicable.
By using the Services, you acknowledge that you have read and agreed to the terms of this Personal Data Protection Policy. If you do not want your personal data handled as described in this Personal Data Protection Policy, please do not provide us with your personal data or interact with the Services. If you choose not to provide the necessary personal data to us, we may not be able to provide you with the Services or allow you to set up an account.
We may modify this Personal Data Protection Policy at any time. You are deemed to agree and consent to any changes in this Personal Data Protection Policy by way of your continued use of the Services.
If we make any material changes, we will notify you by email (sent to the email address specified in your account) or through a notice on the Services before the change becoming effective. You can determine when this Personal Data Protection Policy was last revised by referring to the “Effective Date” above.
Personal data, as used in this Personal Data Protection Policy, shall have the definition ascribed to it under the Personal Data Protection Act 2010. Defined terms shall have the meaning ascribed to them in the User Terms and Conditions or the Merchant Terms and Conditions, as applicable unless the context otherwise requires. To the extent that this Personal Data Protection Policy varies or modifies any provision of the User Terms and Conditions or the Merchant Terms and Conditions, the term in the Personal Data Protection Policy prevails.
Types of Information We Collect
We may collect, and you hereby consent to such collection of, the following categories of personal data from and about you:
- Identifiers: such as your name, nationality or ethnic origin, postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses at which you can receive communications.
- Demographic information: such as your age, birthdate, and gender.
- Commercial information: such as information that enables us to determine lifestyle, interests, and activities, including purchasing tendencies and order history (such as the Vouchers you purchase and redeem or the events that you participate in); areas of interest; information collected through your interactions with the chat functionality; information about persons for whom you have purchased gift Passes or who have bought gift Passes for you; and information about Users who refer you or whom you have referred.
- Location information: such as information related to your state, district, city, or neighborhood, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Services.
- Inferences regarding preferences and other characteristics: such as our assessment of the types of products or services you may have an interest in, including any Merchant Offerings. Financial information: such as information collected from you as needed to process payments for Passes, process redemption of cash vouchers, process forms for Account creation, User or Merchant onboarding, or as provided by you to administer your participation in any Services, such as your payment card number, expiration date, and a card verification number.
- Internet and network activity information: such as information about your browsing behavior, search history, and interactions with websites and advertisements, including data from cookies, pixel tags, and web beacons.
How We Collect Information
We may collect personal information about you from a variety of sources, including:
- From you: We collect information that you submit to us. For example, when you use the Services; purchase a Pass; redeem a Voucher; in the case of Merchants, when you submit the Merchant Application Form or subscribe for advertising services; register to receive information available through the Services; or interact with us in other ways. We will collect any information you voluntarily provide, and we may also request optional information to support your use of the Services. We also collect any information that you voluntarily enter into the chat functionality within the Services. If you send an e-mail to us, we will collect your e-mail address and the full content of your e-mail, including attached files and other information you choose to provide to us.
- Location information: We may collect different types of information about your location, including general information, such as the city, state, district and/or post code associated with your IP address, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Services. We may use such location information to customise the Services, including advertising that is presented to you. In order to do this, your location information may be passed along to our affiliates, agents, Merchants, vendors or advertisers. You may be able to disallow our use of certain location data through your device or browser settings, for example, by disabling “Location” services for the VIVIFY application in iOS privacy settings.
How We Use Information
We may use information collected as described in this Personal Data Protection Policy to:
- Operate, maintain, and improve the Services and other programs, features, and functionality related to the Services
- Provide you with interest-based ads, push notifications, communications, and offers for VIVIFY Offerings and Merchant Offerings, and other goods and services related to the Services, including based on your precise geolocation
- Facilitate and fulfill orders. For example, for VIVIFY’s Passes, Vouchers, cash vouchers, Tokens, giveaway, and lucky draw entries and prizes, and other goods and services, including tracking redemption
- Process and confirm bookings for Merchant Fest or any other event, if any
- Process your payments
- Evaluate your eligibility for certain types of VIVIFY Offerings, Merchant Offerings, or other promotions or services that may be of interest to you, and analyze advertising effectiveness
- Answer your questions and respond to your requests
- Perform analytics and conduct customer research
- Communicate and provide additional information that may be of interest to you about VIVIFY and our business partners, sometimes by combining your information with information we obtain from other sources
- Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of our business partners
- Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our business partners
- Manage our everyday business needs, such as administration of the Services, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations, User Agreement or Merchant Agreement, or to comply with the law
- Allow you to apply for a job, apply to become a Merchant, make a complaint, post a video, or sign up for special offers from our business partners, or other companies
- Verify your requests made according to this Personal Data Protection Policy, and
- Enhance other information we have about you to help us better understand you and determine your interests
We also may use information collected as described in this Personal Data Protection Policy with your consent or as otherwise required or permitted by law.
VIVIFY uses your geolocation, including your precise geolocation, consistent with this Personal Data Protection Policy to deliver location-based VIVFY Offerings, Merchant Offerings, or other goods and services that may be of interest to you.
If you use any features on the Services to send information about the Services to another person, we will also collect the personal information of that other person to the extent disclosed by you and may contact them using the information you provided us.
When and Why We disclose Information
We may share your personal information as follows:
- as required to comply with the law or legal obligations, such as to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions
- in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in Malaysia and other countries where we operate
- with our vendors who perform a variety of services and functions for us, such as data storage, order fulfillment, transmitting emails, and managing digital content. We may share your information with such vendors subject to confidentiality obligations consistent with this Personal Data Protection Policy and on the condition that the service providers use your information only on our behalf and according to our instructions
- in the event, we go through a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of our assets
- to combat fraud or criminal activity, and to protect our rights, users, and business partners, or as part of legal proceedings affecting VIVIFY or its related bodies corporate
- with our affiliates and subsidiaries who may only use the personal information for the purposes described in this Personal Data Protection Policy
- if the information has been aggregated, de-identified, anonymised, or otherwise does not identify you personally, and
- otherwise with your consent.
We may disclose the following categories of personal information for our own business and operational purposes including in exchange for services, insights, or other valuable consideration:
- Commercial information;
- Location information;
- Financial information;
- Internet and network activity information; and
- Inferences regarding preferences or characteristics
Security of Personal Data
VIVIFY has implemented an information security program that contains administrative, technical, and physical controls that are designed to reasonably safeguard personal data that is compliant with the Personal Data Protection Standard 2015. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your personal data, please contact firstname.lastname@example.org
Your Rights regarding Personal Data
You have certain rights concerning your personal data:
- You have the right to know and request information about the categories and specific personal data we have collected about you within the last twelve (12) months, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal data for business purposes
- You have the right to correct or update your personal data
- You have the right to request a copy of your personal data
- You have the right to withdraw consent for further processing of your personal data
- You have the right to request for us to cease processing your personal data if such processing is likely to cause damage or distress, and
- You have the right to request for us to cease processing your personal data for direct marketing.
- To delete your personal information and/or data from the app applicable Databases.
- If you have any requests in relation to the above-mentioned rights and/or for any inquiry in respect of your personal information and/or Data, please write to and/or contact the following below.
Please contact us if you have any questions or comments about our privacy practices or this Personal Data Protection Policy. You can reach us online at email@example.com. You can reach us via postal mail at the following address:
No. 31-2, Jalan AKP 1, Taman Ayer Keroh Permai, 75450 Melaka