App Privacy Notice


 

Collection and Security of Personal Data 

This notice is issued pursuant to the Personal Data Protection Act 2010. TipTop takes its responsibilities under the Personal Data Protection Act 2010 and its regulations ("PDPA") seriously and is committed to respecting the privacy rights and concerns of all users of our TipTop Solutions, which includes the TipTop (TEA) and its related autonomous facility solutions such as IoTs and smart cameras, as defined in our Terms and Conditions.

We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Notice (“Privacy Notice” or “Notice”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.

 

All definition in the Terms and Conditions shall be adopted unless the context otherwise required or specified.

Please read this Privacy Notice carefully. By accessing the App, using the services and/or registering for an account with us, you acknowledge that you have been notified and understood the terms of this Privacy Notice and that you agree to accept the practices, requirement and/or policies outlined in this Privacy Notice and hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. 

We may update this Privacy Notice from time to time. Any changes we make to this Privacy Notice in the future will be published and posted on the App and, where appropriate, notified to you by email, whereupon your continued access to the App and/or use of the Services shall constitute your acknowledgment and acceptance of the changes we make to this Privacy Notice. Please check back frequently to see any updates or changes to this Privacy Notice.

If you have any queries, comments, suggestions or complaints regarding this Privacy Notice or our privacy practices, please contact us through email to engineering@codesocialist.com.

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Nature of Personal Data We Collect From You

The personal data we collect in relation to you may include but not limited to the following:

  1. Personal information such as your name, gender, date of birth, age, identity card number;
  2. Contact information such as company name, address, email address and phone numbers;
  3. Transaction and usage data such as your usage of the App, log in time, usage time, geo-location to and from you, and other details of the Services you have used from the App;
  4. Technical data, such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and other technology on the devices you use to access the App;
  5. Marketing and communications data, such as your preferences in receiving marketing and or communication from us and our third parties and your communication preferences.
     

​The above description of personal data is merely a general description of the various types of personal data that we collect from various users. The nature of personal data differs from user to user. Depending on the nature of business and circumstances, we may only need to collect and process a more limited form of personal data from certain users. In other situations, there may be a need to collect more personal data depending upon the nature of transaction, business and so forth. We do not believe in collecting excessive personal data and what we collect are the essentials that are required to ensure the efficacy of business and transactions.

You may choose whether or not to provide your personal data to us, including sensitive personal data. Sensitive personal data may include such things as information on physical or mental health or medical condition, political opinions, religious or other similar beliefs, commission or alleged commission of any offense.

 

Source of Personal Data

During the course of your use of the App and/or the Services, we may receive personal data from you in the following situations:

  1. When you register an Account with TipTop;
  2. When you submit any forms to us, including (but not limited to) application or registration form, whether online or by way of a physical form;
  3. When you enter into any agreement or provide other documentation or information in respect of your arrangement with us;
  4. When you use any of the features or functions available on the App and/or Services;
  5. When you subscribe to our publications or marketing collaterals;
  6. When you participate in a contest, promotional activity or survey;
  7. When you log in to your Account on our App or otherwise interact with us via an external service or application, such as Email, Chatbot or Google; 
  8. When you interact with us offline; and/or
  9. Through various reference checks, background checks or from various governmental authorities. 
  10. TipTop or our authorised service providers may from time to time implement "cookies" or other features to allow us or third parties to collect or share information that will help us improve our App and/or the Services we offer, or help us offer new services and features. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your computer or device and tell us how and when the App or Services are accessed or used, by how many people and to track movements within our App. We may link cookie information to personal data. Cookies are also used to deliver content specific to your interest and to monitor App’s usage. You may be able to manage and delete cookies through your browser or device settings. However, please note that if you do this you may not be able to use the full functionality of our App or Services.

 

If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent from that third party to share and transfer his/her personal data to us, and for us to collect, use and disclose that data in accordance with this Privacy Notice.

 

Importance of Providing Personal Data

It is important for you to submit personal data which is true, accurate and up to date for us to provide you with the Services. We shall have the right to request for documentation to verify the personal data provided by you as part of our verification processes and you should also notify us of any changes to your personal data to enable us to update our records.

We will only be able to collect your personal data if you voluntarily submit the personal data to us. The failure to provide your personal data to us or subsequently the withdrawal of your consent for our use of your personal data may result in us not being able to provide you with our services or access to the App.
 

Use and Disclosure of Personal Data

The personal data you provide will be collected, used, disclosed and/or processed by us and/or our Group of Companies for one or more of the following purposes (“Purposes”):

  1. To consider and/or process your application and/or transaction with us;
  2. To respond to, process, deal with or complete a transaction and/or to fulfill your order tickets, booking or requests and notify you of any service issues and unusual account activities;
  3. To deal with or facilitate customer service, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
  4. To contact you or communicate with you via voice call, text message, Whatsapp, MS Teams, Chatbot and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
  5. To administer your Account (if any) with us;
  6. To verify and carry out financial transactions in relation to payments (if any);
  7. To carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
  8. To identify and verify visitors on the App;
  9. To audit our businesses;
  10. To prevent or investigate any fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us, and whether or not there is any suspicion of the aforementioned;
  11. To carry out research, benchmarking and/or statistical analysis;
  12. Subject to having obtained your consent, to send you marketing or promotional materials of our Services from time to time;
  13. To conduct automated-decision making processes in accordance with any of these purposes; and/or
  14. Other purposes that are required or permitted under the Personal Data Protection Act 2010 or other applicable laws.

 

Other than the above, we do not collect personal data for any other reasons. Should there be a new purpose for the collection of data, we shall inform you accordingly and obtain your concurrence to the same, where necessary.

 

Confidential and Secure Disclosure of Personal Data

The personal data we collect from you for the purposes may be disclosed to the following categories of persons (whether within or outside Malaysia):

  1. entities within the CODE S Group of Companies including all related companies, subsidiaries, holding companies and/or related companies;
  2. our business partners including service providers, business affiliates, agents and vendors that we have entered into agreements with;
  3. our auditors, business consultants, accountants, lawyers or other professional advisers and/or consultants as we deem necessary and appropriate;
  4. our sub-contractors or appointed third party service providers as we deem necessary or appropriate, including but not limited to the website/system/portal developer or administrator and marketing companies or entities;
  5. any body or person to whom we are compelled or required to do so under any laws or in response to any competent or government, state, provincial, local government, statutory or municipal authority, industry regulators, agency or body; 
  6. law enforcement authorities.

 

In sharing and/or transferring your personal data to the categories of persons above, we endeavor to ensure that such third parties will keep your personal data secured from unauthorized access, collection, use, disclosure, or similar risks and retain your personal data only for as long as they need your personal data to achieve the purposes.

In addition, where we consider it necessary or appropriate for the purposes of the conduct of business, data storage or processing or customer management, we may transfer your personal data to another member of the Group or third party service or product providers within or outside the country in which we are established, under strict conditions of confidentiality and similar levels of security safeguards.
 

Correcting Your Personal Data

It is important that the personal data you provide to us is accurate. You are responsible to inform us of changes to your personal data, or in the event you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of date. You can request to correct or update your personal data anytime by contacting us via  email at engineering@codesocialist.com.

 

Your rights of Access and Withdrawal 

If you would like request access about your personal data which we have collected or inquire about the ways in which your personal data may have been used or disclosed by us or you wish to request us to specify or explain its policies and procedures in relation to the data and types of personal data handled by us, please contact us via email at engineering@codesocialist.com.

We may be charging you a reasonable administrative fee for the handling and processing of your requests to access your personal data. If we opt to charge, we will provide you with a written estimate of the administrative fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

You have the right to withdraw your consent to us from processing your personal data for a particular purpose(s) at any time, subject to the requirements of the law. Upon such withdrawal of consent, we will cease to process your personal data. However, please understand that your withdrawal of consent may result in us not being able to properly perform or discharge our obligations to you and unable to continue to provide you with the services. You may notify us that you wish to withdraw your consent by contacting us at engineering@codesocialist.com.

 

Retention of Personal Data

We will only retain your personal data for as long as we are either required to by law or as is relevant for the purposes for which it was collected.

We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected, and is no longer necessary for any legal or business purpose.

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Last Updated:  2023 JUNE 29