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Privacy PolicyUpdated 9 months ago

Updated on 1st November 2022

 

Introduction

At Teleport, we take your privacy and our responsibility in relation to protecting your Personal Data and compliance with Applicable Laws very seriously. We are committed to comply with all data protection laws applicable to us. 

 

In the course of providing you with our services and access to the Platforms, we may collect and process your Personal Data. We will only manage, process, and disclose your Personal Data in accordance with this Policy and the Applicable Laws. This Policy will inform you how we collect, use, process, and disclose your Personal Data. We trust that it will assist you in making an informed decision whether to provide us with any of your Personal Data. 

 

It is important that you read this Policy together with any other applicable notices we may provide on specific occasions when we are collecting or processing your Personal Data, so that you are fully aware of how and why we are using your Personal Data.

 

For the purposes of understanding this Policy, capitalised terms used in this Policy shall have the following meanings:

 

“Applicable Laws" means Malaysia's Personal Data Protection Act 2010 and its subsidiary legislations and regulations as amended from time to time;

 

"Personal Data" means any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as "personal data" or "personal information" under the Applicable Laws or any applicable data protection laws; 

 

"Platform" means the website, software, or any other means that is used by Teleport to provide its Services owned by Teleport which is made available to you for use, or for integration via the APIs and/or data repository provided by Teleport;

 

“Services” means the services offered by Teleport on the Platform to you; and

 

“Teleport” or “Teleport Entities” means the relevant Teleport entities (Malaysia - Teleport Commerce Malaysia Sdn Bhd, Singapore - Teleport Everywhere Pte Ltd, Philippines - Teleport Commerce Philippines Inc, Indonesia - PT Teleportasi Bisnis Indonesia, and Thailand - Teleport Commerce (Thailand) Co. Ltd.) from the country you are accessing the Platforms from.

 

By (1) clicking "Yes" on our Policy pop-up or any web form referring to this Policy on any of our online platforms, (2) submitting your Personal Data to us when signing up for an account on the Platform, (3) browsing our Platform, or (4) using any of our services, you acknowledge that you have been notified of and understood the terms of this Policy and that you have agreed to the collection, usage, processing, and disclosure of your Personal Data as described and under the terms herein. 

 

We may update this Policy from time to time to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. Any changes we make to this Policy in the future will be posted on our Platform and, where appropriate, notified to you by email, whereupon your continued use of our services, access to the Platform or use of the Services, shall constitute your acknowledgment and acceptance of the changes we make to this Policy. Please check back frequently to see any updates or changes to this Policy.

 

TYPE OF PERSONAL DATA COLLECTED

 

Examples of the types of Personal Data we may collect include:

 

  1. identity data, such as your name, gender, age, birthday, facial image, voice recording (for customer service calls);
  2. contact details, such as phone number, email address, billing address, home address (or any other delivery address);
  3. payment details (bank accounts and credit card details);
  4. transaction data, such as details about payments to and from you, and other details of products that you have purchased from third party sellers and any of our services that you have utilised;
  5. technical data, such as internet protocol (IP) address, your login data, network details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform;
  6. profile data, such as your username and password, purchases or orders made by you, your interests, preferences, your shopping or browsing behaviours, feedback and survey responses;
  7. usage data, such as information on how you use our Platform, products promoted in our Platform, and our services;
  8. marketing and communications data, such as your preferences in receiving marketing from us and our third parties and your communication preferences; and
  9. any other personally identifiable information which you have provided us in any forms you may have submitted to us, or in the course of any other forms of interaction between you and us.

 

COLLECTION OF PERSONAL DATA

 

We collect Personal Data from you when:

 

  1. You register an account on our Platform;
  2. You use any of our Services, including our related services such as subscribing to our newsletter, curated products, product notifications;
  3. You browse the products listed in our Platform, our Services or otherwise interact with our Platform;
  4. You accepted an order at through or link to our Platform;
  5. You submitted payments details, including bank account and credit card details;
  6. You accept our cookies on your device;
  7. Our third-party analytics and other service providers provide your Personal Data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or
  8. When you voluntarily submit your Personal Data to us for any reason.

 

Please also take note of our Cookies Policy below in respect of the data collected and used by third-party cookies and trackers on our Platform.

 

We may also collect your Personal Data in circumstances where such collection does not require consent under Applicable Laws.

 

Please ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide you with the services you have requested and/or access to our Platform.

 

If you provide us with Personal Data relating to a third party by submitting such Personal Data to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

 

USAGE OF PERSONAL DATA

 

We may use and disclose your Personal Data for purposes necessary to provide you with our services and/or access to our Platform, including but not limited to:

 

  1. register and maintain your user account and to verify your identity or age;
  2. process or collect your order and payment for our services. We may engage third-party payment processors, which means that your payment details might be collected, processed and stored directly by such third-party payment processors pursuant to their terms of use and privacy policies and/or shared to such third-party payment processors;
  3. perform the Services;
  4. share your Personal Data with any other party which might be part of or in any way related to the Services and/or our Platform;
  5. communicate with you in relation to (i) your queries, requests and feedback, (ii) material changes to our Platform’s Terms of Service, Policy or other terms and conditions, and (iii) matters relating to the operation of your account;
  6. personalise and improve your customer experience when you visit the Platform;
  7. monitor and enforce compliance with our Terms of Service, including dispute resolution;
  8. comply with (i) internal risk controls, (ii) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or (iii) any applicable law; and
  9. ensure our Platform function properly and to improve their performance, by carrying out activities such as debugging, statistical analyses for optimizing our Platform.

 

(collectively, the "Purposes")

 

In addition, we may use and disclose your Personal Data for the following purposes, to:

 

  1. send you marketing communications in relation to any product promoted in our Platform, services that we provide, other promotions or the Platform itself;
  2. send you marketing communications in relation to the sales, products, services or promotions of our business partners, including promotional mail together with your order;
  3. deliver ads which are related to our products and services which may be of interest to you on the Platform or other websites, apps or online platforms;
  4. enable businesses to deliver ads which are related to their products and services which may be of interest to you;
  5. provide you with our add-on or premium services;
  6. invite you to our private customer events;
  7. process your participation in our promotions, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;
  8. process your participation in our business partners' loyalty or point redemption programs;
  9. conduct market and customer research, analysis or tracking;
  10. promote the products and services on our Platform;
  11. manage the administrative and business operations of Teleport and complying with internal policies and procedures;
  12. improve your customer experience across all touchpoints and training our customer experience team, such as by recording and monitoring phone calls; and
  13. any specific purpose in relation to a particular product or service, which we may separately notify you on the product or service page;

 

(collectively, the “Additional Purposes”)

 

We may also use your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such use does not require consent under Applicable Laws.

 

Note: If you withdraw your consent for us to use and process your Personal Data for the Purposes or the Additional Purposes, we may no longer be able to provide you with the related products, services or benefits associated with our promotion, or to grant access to our Platforms.

 

DISCLOSURE OF YOUR PERSONAL DATA

 

In relation to our use of your Personal Data, we may disclose your Personal Data to our:

 

  1. employees, consultants, temporary workers;
  2. payment processors, who process your payment on our Platforms;
  3. business partners or vendors in connection with the processing of any promotion, event or service organised by us;
  4. professional advisers and consultants;
  5. agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimization, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of your Personal Data; 
  6. logistics providers, such as third party courier services entities who assists in delivering your goods or parcel;
  7. any actual or potential assignee, transferee or acquirer of the Platform and/or one or more members of the AirAsia group of companies for securitisation purposes, in connection with any capital or fund-raising exercise carried out by the AirAsia group. Such transfer or assignment of rights will not affect your ability to exercise any of your rights regarding your Personal Data. At all times, we will ensure that you shall continue to have the ability to exercise all rights over your Personal Data (as provided under applicable data protection laws). In the event of foreclosure of the security, data that forms part of the security may be transferred to the transferee / assignee / acquirer and processed by them for their own purposes, but your statutory rights to your Personal Data will continue to subsist nevertheless;and

and

  1. any other party whom you authorize us to disclose your Personal Data to.

 

We may also disclose your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such disclosure does not require consent under the Applicable Laws.

 

We do our best to minimize the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose. 



ACCESS OR CORRECTION TO YOUR PERSONAL DATA

 

You may access or correct your name, e-mail address, birthday, shipping and billing addresses and contact numbers by logging in to your user account on the Platform under "Account Information" and clicking the "Edit" button under each relevant field.

 

For Personal Data that cannot be corrected by you by logging in to your user account on the Platform, you may request to access and correct such Personal Data by submitting a written request to us via [email protected]. We may need to request additional information from you to confirm your identity before providing the access or making the correction.

 

We will do our best to respond to Personal Data access and correction requests within 21 days from the date of receipt of the requests. Where we are unable to meet this timeline, we will update you with the soonest possible time within we can provide the information or make the correction. Please note that certain types of Personal Data access and correction requests may be exempted under Applicable Laws.

 

Note that we may charge you a reasonable fee for the handling and processing your Personal Data access request.

 

We will send your corrected Personal Data to every other person or entity to which such Personal Data was disclosed by Teleport within the year OR twelve (12) months before the date of the correction, unless such person or entity does not need the corrected Personal Data for any legal or business purpose or unless we reasonably believe that the other person or entity has ceased using such Personal Data for the purpose for which such disclosure was made.

 

REQUEST TO WITHDRAW CONSENT

 

If you wish to withdraw your consent for us to send you sales, marketing or promotional information, please inform us as follows:

 

  1. to withdraw consent from receiving SMS promotions: please unsubscribe by following the steps provided in the promotional SMS;
  2. to withdraw consent from promotional emails: please click on the Unsubscribe link in the promotional emails;
  3. to withdraw consent from receiving promotional material with your order package: please email our Data Protection Officer at the email address provided below.

 

Once we receive notification that you wish to withdraw your consent for receiving marketing or promotional materials or communications, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials or communications during this period.

 

If you withdraw your consent to receive marketing or promotional materials through a specific communication mode (e.g. SMS), we may still contact you for other purposes in relation to the products and services via other communication modes you have subscribed to (e.g. email).

 

You may withdraw your consent for the collection, use and/or disclosure of any of your Personal Data in our possession or under our control by submitting a written request via email to our team via [email protected]. 

 

Note that, depending on the nature of the consent withdrawal, we may not be able to continue to provide you with some or all of our products or services or access to our Platforms. We will process such a request within a reasonable time from receiving notice from you of your withdrawal of consent. Once the processing is complete, we will no longer collect, use and/or disclose your Personal Data, except to the extent we retain your Personal Data for compliance, regulatory or other legal purposes.

 

ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

 

We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organization is accurate and complete. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of changes.

 

We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. This includes putting in place reasonable measures to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage or alteration of your Personal Data. However, we will not be responsible for any unauthorized use of Personal Data by third parties which is attributable to factors beyond our control.

 

When Personal Data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such Personal Data is destroyed, permanently deleted or anonymised.

 

If Personal Data is transferred out of Malaysia, we will comply with Applicable Laws in doing so. This includes: (i) obtaining your consent, unless an exception exists under Applicable Laws or any other laws, and (ii) taking reasonable steps to ascertain whether the foreign recipient of the Personal Data is bound to comply with standards of protection that are at least comparable to the Applicable Laws.

 

INDIVIDUAL RIGHTS FOR USERS IN THE EUROPEAN ECONOMIC AREA

 

If you are located in the European Economic Area, you may seek confirmation regarding whether Teleport is processing your Personal Data, request access to your Personal Data and ask that we correct, amend, delete, or restrict processing of your Personal Data. In addition, you may object to Teleport's processing of your Personal Data at any time. However, please note that doing so may impact your ability to access and use Teleport’s Platforms and services.

 

While Teleport makes reasonable efforts to provide our users with access to their Personal Data, there may be circumstances in which we are unable to provide such access, including but not limited to: where the information in question is legally privileged, would compromise the privacy or other legitimate rights of other persons, where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the request is clearly excessive or unfounded, or where the information requested comprises confidential commercial information.

 

COOKIES

 

A cookie is a small file that can be placed on your device. It is sent to your browser and stored on your computer’s hard drive, tablet or mobile device. When you visit our Platform, it can allow us to recognise and remember you.

 

Teleport uses the services of third party vendors, who may implement cookies on the Platform. Advertisements on the Platform may also be provided by third party agencies. These advertisements may also generate cookies, for example, to track how many people have viewed the advertisement. The collection, use, and disclosure of information, including Personal Data, collected by such third party cookies are subject to the privacy and data protections policies of the third party vendors and are not under our control. Third parties may able to associate any Personal Data they collect with other Personal Data they have about you from our sources and we do not have control over this matter. 

 

Teleport also uses cookies such as session cookies (cookies lasting only as long as your online session and expires when you close your browser) or persistent cookies (cookies that stay on your device after your browser has been closed and last for a time specified in the cookie, to remember you for more than one browsing session such as remembering your preference) in enabling Teleport to provide the Services to you. 

 

You may reject, disable, block or deactivate cookies through the settings on your browser. Note however that this may result in the loss of Platform functionality, restrict your use of the Platform, or delay or affect the way in which the Platform  operates.

 

You may adjust your internet browser settings to disable, block or deactivate cookies, delete your browsing history or clear the cache from your internet browser. The settings may be contained within the “History”, “Preferences”, “Settings” or “Privacy” section of your internet browsers or you may even consult with the help section of your internet browser. 

 

Google Analytics

 

Teleport uses certain Google Analytics functions. Please see this link for how your data is collected and this link for instructions on how to opt-out of any Google Analytics data tracking.

 

Teleport may use Google Analytics features based on Display Advertising, including but not restricted to the following: Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. Using the Google Ads Settings, you can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads.

 

Teleport also uses Remarketing with Google Analytics to advertise online; third-party vendors, including Google, may show Teleport ads on sites across the Internet. Teleport and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitors' past visits to Teleport, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to Teleport.

 

When you log on to the Teleport website, Teleport with the help of Google Analytics may use your browsing behaviour to connect it with any other data that has previously been provided by you, in accordance with this Policy.

 

Sociomantic

 

Teleport uses Sociomantic's services, and Sociomantic's tags are implemented on Teleport's sites to collect anonymous information about you. You may find out more about the information collected by Sociomantic, how it is used, and how you can opt out at https://www.sociomantic.com/privacy/en/

 

LinkedIn Insight Tag

 

Teleport utilises LinkedIn’s services and its tags that enables the collection of data regarding LinkedIn members’ visits to our Platform including but not limited to; URL, referrer, IP address, device and browser characteristics. You may find more information the functionality of the LinkedIn Insight Tag at LinkedIn’s website HERE.  

 

Meta Pixel 

 

Teleport uses Facebook’s Meta Pixel to track and collect data on visitors’ activities on its Platform. Its primary use is to measure effectiveness of advertising which assist in Teleport’s sales and marketing activities for customising user experience. You may read more on the functionality of the Meta Pixel HERE. 

 

TikTok Pixel 

 

Teleport utilises Tiktok Pixel enables advertisers to share any website visitors’ activities or events to TikTok via browser. For an average user, this includes assessing your timestamp, IP address, and enabling first party and third party cookies. For more information, you may read on TikTok Pixel HERE.  

 

CONTACTING US

 

For any questions relating to your Personal Data or about this Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, or a question about how we are complying with Applicable Laws, you may contact our team via one of the following methods:

 

Email address: [[email protected]]

Office address: : [xxx]

 

Attention it to the ‘Data Protection Officer’.

 

Emails and letters should clearly state that you are making a data protection query, request or complain in the subject line to ensure the matter is dealt with expediently. We will strive to deal with any query, request or complaint promptly and fairly.

 

UPDATES ON DATA PROTECTION POLICY

 

As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. In this regard, Teleport may update this Policy to ensure that it is consistent with industry trends and any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Policy at our absolute discretion.

 

Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our Platform. Any amended Policy will be posted on our Platform and can be viewed at here. By continuing to use our Platform and/or services after the Policy has been amended, you hereby agree to be bound by the terms of such amended Policy.

 

You are encouraged to visit the above website from time to time to ensure that you are well-informed of our latest policies in relation to personal data protection.

 

GOVERNING LAW

 

This Policy and your use of our Platform shall be governed in all respects by the laws of Malaysia.

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