NETGLUE PRIVACY STATEMENT

The Personal Data Protection Act 2010 (“PDPA”) was introduced by the Government to regulate the processing of Personal Data in commercial transactions. The PDPA, which applies to all companies that are established in Malaysia, requires us to inform you of your rights in respect of your Personal Data (hereinafter defined) that is being processed or that is to be collected and further processed by us and the purposes for the data processing. The PDPA also requires us to obtain your consent to the processing of your Personal Data.

Consequently, we want you to be clear how we are using your Personal Data and the ways in which you can protect your privacy. This Privacy Statement describes on what information is gathered, how this information is used and stored, who the information will be shared with, how you can opt out and how you can modify your Personal Data held by us and any other changes that have been made from time to time.

All capitalized words not defined in the Privacy Statement will have the same meaning ascribed in Netglue Terms of Use. This Privacy Statement is incorporated and forms part of Netglue Terms of Use.

Our Privacy Statement may change from time to time without notice. As such, please look at our Privacy Statement periodically, and especially before you provide us any of your Personal Data. This Privacy Statement was last updated on the date indicated above. Your continued access and/or use of Netglue Property after any changes, revisions or modifications to this Privacy Statement shall indicate your agreement with the terms of such revised Privacy Statement.

ONE OR MORE OF THE CONTENT FOUND IN THE NETGLUE PROPERTY MAY NOT BE CATERED TO YOU IF YOU ARE UNDER THE AGE OF 18. ALSO, WE WILL CONTRACT WITH YOU ONLY IF YOU ARE 18 YEARS OLD AND ABOVE. AS SUCH, PLEASE OBTAIN YOUR PARENT OR GUARDIAN’S PERMISSION BEFORE ACCESSING AND/OR USING NETGLUE PROPERTY UNLESS YOU HAVE OBTAINED PERMISSION FROM YOUR PARENT OR GUARDIAN. IF YOU HAVE REASON TO BELIEVE THAT A CHILD UNDER THE AGE OF 18 HAS PROVIDED PERSONAL DATA TO US THROUGH OUR NETGLUE PROPERTY, PLEASE CONTACT US AND WE WILL ENDEAVOUR TO DELETE THAT INFORMATION FROM OUR DATABASE. OTHERWISE ALL PERSONAL DATA PROVIDED BY A USER SHALL BE DEEMED TO HAVE BEEN SUBMITTED BY A USER ABOVE 18 OR HAS OBTAINED THE RELEVANT PERMISSION FROM THEIR PARENT/GUARDIAN.

The Privacy Statement is applicable to you the moment you access and/or use Netglue Property.

Yes, we need to collect and process your Personal Data to enable us to provide you with access and/or use of Netglue Property and we need your consent to collect and process such Personal Data of yours, failing which we are not able to provide you with the access and/or usage of Netglue Property.

We collect information in (2) ways:-

1. device-specific information such as hardware model, operating system version, unique device identifiers, mobile network information, Internet Protocol (IP) address, GPS locations, GSM cell information.
2. cookies that may uniquely identify your browser. This is described in detailed below.
3. details of how you access and/or use Netglue Property such as your search queries.
4. total number of visitors accessing and/or using Netglue Property.
5. diagnostic and usage data that your device generates. This is described in detailed below.
6. how you and other user use and interact with Netglue Property.

The above is collectively known as “Information”. If we do combine non-personal information with Personal Data the combined information will be treated as Personal Data for as long as it remains combined.

As an ongoing effort to better understand and serve you better, we often conduct research on customer demographics, interests and behaviour based on the Personal Data and Information provided to us. This research may be compiled and analysed on an aggregate basis. We may share this non-identifiable and aggregate data with our Affiliate and/or Authorised Third Party (hereinafter defined) but this type of non-identifiable and aggregate does not identify you personally. We may also disclose aggregated user statistics in order to describe our Netglue Property to our Affiliate and/or the Authorised Third Party for other lawful purposes.

“Authorised Third Party” shall mean business partners, contractors, agents, auditors, advisers, any telecommunications provider which we have an arrangement with in connection with the Netglue Property and/or third party supplier engaged by us from time to time for the purposes of providing Netglue Property to you.

We use the Personal Data and Information you provide in a manner that is consistent with this Privacy Statement. If you provide Personal Data for certain reason, we may use the Personal Data in connection with the reason for which it was provided. Your Personal Data and Information may also be used by us, our Affiliate and/or Authorised Third Party for one or more of the following purposes:-

1. assessing your application,
2. credit checking with Credit Rating Agency,
3. to operate and provide Netglue Property to you,
4. administrating your Netglue Account,
5. technical administration of Netglue Property,
6. to verify and process payment,
7. to communicate with you,
8. to respond to your inquiries,
9. for research and development,
10. to detect and prevent fraudulent activity,
11. investigation of complaints and suspected suspicious transactions,
12. in compliance with any Appropriate Authority and/or Law,
13. profiling Netglue Service preferences,
14. to conduct market research and using such analysis for our business plans, the enhancement of Netglue Property, targeted advertisements and conveying such information in broad aggregate terms to our Affiliate, Authorised Third Party, and/or third parties who have or propose to have business dealings with us,
15. statistical analysis,
16. to provide you with information on our other product and services, of our Affiliate, and/or Authorised Third Party,
17. to send you information, promotions and updates including marketing and advertising materials in relation to Netglue Property and those of our Affiliate, and/or Authorised Third Party,
18. our other legitimate business activities, and/or
19. any other activities which are ancillary to Netglue Property.

The above shall collectively be referred to as “Purposes” in this Privacy Statement.

You represent and warrant that the consent of your Other User whose Personal Data you have provided in any application and/or disclosed to us has been obtained to allow us to process the same for the Purposes set out above.

If we intend on using any Personal Data in any manner that is not consistent with this Privacy Statement, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

We are not in the business of selling your Personal Data. We consider this information to be a vital part of our relationship with you. As such we will not sell or rent your Personal Data save and except as provided herein. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below.

Business Transfer. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Affiliate. We may also share your Personal Data with our Affiliate for purposes consistent with this Privacy Statement.

Legal Requirements. To comply with any order of court or directive from authorities investigating any alleged offence, misdeed and/or abuse or to enforce any of the terms and conditions applicable to you, or where such action is necessary to protect and defend our rights or property.

Authorised Third Party. Where services from such Authorised Third Party is required, we will share your Personal Data on a strictly confidential basis. Authorised Third Party will not be allowed to use your personal information disclosed to them except for the limited purpose of providing the particular service.

Credit Rating Agency. We will disclose your Personal Data and information with respect to the conduct of your account or business account to any credit reporting agency at any time. Such Personal Data and information provided to any credit reporting agency may in turn be provided to their subscribers of their service.

Our Netglue Property may provide a link or a platform to third party applications, website and/or services to make available certain services to you (“Third Party Services”). This Third Party Services may contain, from time to time, links to other web sites. We are not responsible for the privacy practices or the content of such websites or of any third party. You should review the privacy policies of such Third Party Services. This Privacy Statement applies solely to Personal Data and Information collected by us.

What is a Cookie?

When you access and/or use Netglue Property, your device will automatically be issued with a cookie. Cookies are small files containing string of characters that are placed in your device's hard drive to identify your device to our server. Generally, cookies themselves only record those areas of the site that have been visited by the device in question, and the duration. Many websites and/or software application do this whenever a user visits their site in order to track traffic flow.

Depending upon the type of device you are using, you may set your device to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services cannot then be provided to you.

Our Cookies:-

We use "cookies" to store and track information about you and your access and/or use of Netglue Property.

Our cookie and information retrieved from our cookie is used in line with the uses set out in in this Privacy Statement and more specifically:

1. to help save and retrieve passwords used on Netglue Property. This way, you will not have to re-enter information upon every new visit to Netglue Property.
2. to track information such as the frequency and duration of your access and/or use of Netglue Property, your click-stream as you go through Netglue Property and help us determine whether you came to Netglue Property from a particular internet link or banner advertisement.
3. to analyse the profile of visitors and users to helps us in providing you with better access and/or use of Netglue Property and to enhance Netglue Property.
4. to personalize the content, banners and promotions that you will see on Netglue Property. 

Most cookies are "session cookies," meaning that they are automatically deleted from your device at the end of a session. You are always free to decline cookies if your device permits, although in that case you may not be able to use certain features of Netglue Property and you may be required to re-enter your password more frequently during a session.

Third Party Cookies:

We may allow other third party to serve ads when you access and/or use Netglue Property. In the course of serving advertisements, the third-party may place or recognize a unique cookie in your device. Such third party may use information retrieved from their cookies to provide advertisements on Netglue Property and other product and services that may be of interest to you.

WE HAVE NO ACCESS TO OR CONTROL OVER THE THIRD PARTY COOKIES AND THEY ARE NOT SUBJECT TO OUR PRIVACY STATEMENT. PLEASE REVIEW THEIR PRIVACY POLICY FOR DETAILS. If you want to prevent such third party from sending and reading cookies on your device, you will need to visit each of their websites individually to request that you be removed from that system.

We would like you to help improving the quality and performance of Netglue Property. We can automatically collect diagnostic and usage information from the device you are using and send it to us for analysis. The information is submitted anonymously to us. None of the information submitted identifies you personally, nor do we include images or any of your text. If you allow us to collect diagnostic and usage data, it may include details about app crashes and details about which features of Netglue Property you use and how often. This data would also indicate the kind of device you’re using and which version of the operating system it’s running. Automatic reporting of diagnostic and usage information is on by default.

You may be able to access and/or use Netglue Property without providing us any Personal Data. If you choose not to provide any Personal Data, you may not be able to access and/or use certain Netglue Property.

However, when you choose to provide us with such Personal Data, we may also use your Personal Data to contact you in the future to tell you about our services we believe will be of interest to you.

In relation to direct marketing, you may request us by written notice not to process your Personal Data.

You can write to us vide the email address provided in this Privacy Statement at any time to obtain details of the Personal Data we hold about you. Please quote your name, NRIC, company name, company registration number and mobile number. It would be helpful if you also provide brief details of what information you want a copy of. We may charge a reasonable sum permitted by existing laws to cover our administration costs.

We reserve the right to refuse to provide you with a copy of your Personal Data, but will give reasons for our refusal.

We maintain your Personal Data in our business records while you accessing and/or use Netglue Property. We also maintain this information for a period of time after you are no longer a subscriber or when you discontinue accessing and/or using Netglue Property if the information is necessary for the Purposes for which it was collected or to satisfy legal requirements.

The Netglue Property may not be a secure medium, and communications over Netglue Property may be subject to third-party interception. We cannot accept responsibility for any unauthorised access or loss of Personal Data.

We have implemented security policies, rules and technical measures to protect your Personal Data from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. All our employees and data processors, who have access to and are associated with the processing of Personal Data, are obliged to respect the confidentiality of your information.

While we cannot guarantee that loss, misuse or alteration of Personal Data will not occur; we make reasonable efforts to prevent such unfortunate occurrences.

Personal Data that we collect from you will be stored and backed up securely in an environmentally controlled location. Only authorized people with user ID and password from our company have access to the information.

You must remember to log off from our system after accessing and/or using Netglue Property so that no unauthorized party can have access to your Personal Data. You must not, at any time, divulge your Personal Data to any third party.

It may be necessary to transfer your Personal Data and Information to our Affiliate, and/or Authorised Third Party located in countries outside Malaysia. This may happen where our Affiliate and/or the Authorised Third Party is based outside Malaysia or where you access and/or use our Netglue Property from countries outside Malaysia. By continuing accessing and/or using Netglue Property, you consented to such transfer.

If you have any questions relating to Netglue Property or your Personal Data, please contact us at:-

Name: Personal Data Officer

Address: Netglue Sdn Bhd,

C-10-09, Oasis Corporate Park, Jalan PJU 1A/2, Ara Damansara,

47301 Petaling Jaya, Selangor, Malaysia.

Telephone: 03- 7495 4881

Email: support@netglue.com.my

In the event of conflict on the use of the words and/or meanings of this Privacy Statement in the English and other languages, the use of words and/or meanings given to it in the English language shall prevail.

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