Sources of Personal Data

We may collect Personal Data:

1. when you ask us about our services or otherwise communicate with us;
2. when you enter into a contract with us;
3. when you register an account with us;
4. when you participate in our promotional events;
5. from publicly available sources;
6. when you access our Sites;
7. when we provide any goods or services to you;
8. when you provide us with any feedback, participate in surveys and/or lodge a complaint with us; and/or
9. where relevant, from third parties.

Disclosure of Personal Data

If and when necessary in connection with the above Purposes, your Personal Data may be disclosed and/or transferred to third parties which may or may not be located outside Malaysia to the extent as may be necessary for the purpose of, or in connection with, legal proceedings (including prospective legal proceedings), and/or otherwise necessary for the purposes of establishing, exercising or defending legal rights, including but not limited to:

1. our affiliates;
2. our employees, contractors and other third party service providers who provide services to Wellous Sdn. Bhd. or the Group for any of the Purposes contemplated in Paragraph 4;
3. our external advisors, professional or otherwise, including solicitors, accountants and auditors; and/or
4. government or quasi-government and regulatory authorities.

In the event that we transfer your Personal Data outside of Malaysia, it will be done in accordance with the relevant provisions under laws and regulations. This includes taking appropriate steps to ascertain that the overseas recipient organization of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act.

We will provide our preferred service providers with the information they need to perform their services and work with them to respect and protect your Personal Data. We require our service providers to adhere to strict privacy guidelines and not to use your Personal Data for any unauthorised purposes.

We will not disclose your Personal Data to third parties without first obtaining your consent permitting us to do so except as permitted or required by the law. However, please note that we may disclose your Personal Data to third parties without first obtaining your consent in certain situations, including, without limitation, (i) in cases in which the disclosure is necessary for any investigations or proceedings, or authorized based on the applicable laws and/or regulations including enquiries from governmental and regulatory agencies under proper authority; (ii) where such disclosure is permitted by the Act or by law.

Provision Of Third-Party Personal Data By You

Should you provide the Group with personal data of individual(s) other than yourself, you represent and warrant to the Group and you hereby confirm that :

1. prior to disclosing such Personal Data to us, you would have and had obtained consent from the individuals whose Personal Data are being disclosed to us, to:
   1. permit you to disclose the individuals’ Personal Data to Group for the purposes; and
   2. permit Group to collect, use, disclose and/or process the individuals’ Personal Data for the purposes, as set out in paragraph 4 above;
2. any Personal Data of individuals that you disclose to us is accurate; and
3. you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their Personal Data to the Group and for the Group to collect, use, disclose and process such Personal Data for the purposes.

Security of Personal Data

We take every measure to provide a comparable level of protection for Personal Data and we are committed to comply with the Act as well as corresponding guidelines and orders. Although we endeavour to maintain appropriate technical and organizational security measures to protect the security of your Personal Data against loss, misuse, unauthorized or accidental access, disclosure or alteration or destruction, no electronic transmission of information can be entirely secure. We do not guarantee that the security measures we have in place are one hundred percent sufficient or effective to safeguard your Personal Data. You agree to assume all responsibilities and risks in your use of our Sites and acknowledge the existence of all such risks in using the internet generally. To further protect your Personal Data, you should safeguard your username and password (registered on our Sites) and not to share such information with anyone.

We will only retain your personal data for as long as we are either required or permitted to by law or as relevant for the purposes for which it was collected. We will also take reasonable measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that the purposes for which that Personal Data was collected is no longer being served by the retention of such personal data and that retention is no longer necessary for any other legal, regulatory or business purposes.

The Rights of Data Subject

a. To request access/ correction to personal data

You should ensure that all your Personal Data submitted to us is accurate, true, correct and complete. Failure on your part to do so may result in our inability to provide you with product/ services you have requested for.

You may request to access and/or correct the Personal Data currently in our possession by submitting your request to us formally through the contact details indicated below. We will endeavour to respond to such requests within a reasonable time frame. We may take steps to verify your identity before fulfilling your request for access to your Personal Data. Please note that depending on the information requested, we may charge you a reasonable fee for the request. We will provide you with a written estimate of the fee before acceding your request. Please be informed that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

For a request to correct Personal Data, once we have sufficient information from you to deal with the request, we will deal with your request in compliance with the Act, including correct your Personal Data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction.

b. To limit processing of your personal data/ request to withdraw consent

You may limit the processing of your Personal Data and/or withdraw your consent for receiving marketing or promotional materials/ communication from us. Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/ communication, we will require some time to process your withdrawal request. During this period of time you may still receive marketing or promotional materials/ communication.

You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to us at compliance@svo2u.com. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will subsequently not collect, use and/or disclose your Personal Data in the manner stated in your request, unless the law or the Act allows us to. It is important to note that withdrawal of consent for us to collect, use or disclose personal information, including but not limited to your name, address, email, mailing address and/ or telephone contacts may render us being unable to continue providing the relevant services to you effectively.

Changes To Privacy Policy

We reserve the right to amend our Privacy Policy from time to time without prior notice. We advise that you check our website for our Privacy Policy on a regular basis. Any such update or revision will be effective immediately upon its release on our website.

Acknowledgement And Consent

If you would prefer that we do not collect Personal Data from you, please do not provide us with any such information or access our Sites. By visiting our Sites, providing Personal Data to us, or otherwise interacting with us, you shall be deemed to have read and consented to our processing of your Personal Data in the manner as described in this Privacy Notice. You are also aware that you may withdraw your consent to our processing for any of the above Purposes, at any time by contacting us via the contact details provided in this Privacy Notice. If we do not receive any notification from you concerning our processing of your Personal Data, we shall proceed to continue to process the same for the Purposes as set out above, on the basis that you have consented to our current as well as all our previous processing of your Personal Data in accordance with this Privacy Notice.