We respect your privacy, Revotrend Sdn. Bhd. (referred to as “Revotrend” or “We” or “Our” in this Privacy Notice) has developed this Privacy Notice to inform you of how We process and protect the Personal Data that We Collect, Use, or Share with third parties. It also covers how Revotrend makes the Personal Data it holds available for access to and correction by you.
This Privacy Notice has been drafted having regard to Revotrend’s obligations under Personal Data Protection Act 2010 (the “PDPA” or the “Act”). This Privacy Notice is a public document and has been prepared in light of the “Notice and Choice Principle” (Section 7) under the Act.
Please read this Privacy Notice. By using the Revotrend Website, or by receiving notification from Revotrend of how you may access this Privacy Notice, whether by phone, email or otherwise, you are consenting to or deemed to have consented to the Collection, Use and Disclosure of your Personal Data as set forth in this Privacy Notice.
1. COLLECTION OF YOUR PERSONAL DATA
1.1 Revotrend Collects Personal Data about customers, prospective customers, vendors, prospective vendors, contractors, job candidates, the general public (via our CCTVs) and Website users which is reasonably necessary for, or directly related to, one or more of our functions or activities. The Personal Data may be collected through our Website, over the phone, or otherwise.
1.2 At or before the time, or, if that is not practicable, as soon as practicable after, We collect your Personal Data, We will notify you upon your request of the matters required pursuant to Section 7 of the “Act” by providing you with a hard copy of this Privacy Notice, or by notifying you of how you may access this Privacy Notice.
1.3 Revotrend will not Collect Personal Data secretly or in an underhanded way and will not sell your Personal Data to any third party (except in the course of a sale of the business, etc.).
2. HOW WE USE YOUR INFORMATION AND WHEN WE MAY SHARE IT
2.1 Revotrend holds Personal Data, which it has collected for its primary purposes, including but not limited to:
(a) providing you with the products and services ordered from us or in relation to products or services we order from you;
(b) answering your inquiry;
(c) sending you additional materials relating to Revotrend and services that may be of interest to you;
(d) providing you with effective customer service; and
(e) for security measures relating to our services.
2.2 Revotrend also holds Personal Data for purposes other than its primary purposes (secondary purposes). You provide your consent to us using your Personal Data for the following secondary purposes:
(a) billing and account management;
(b) business planning and product development;
(c) providing you with relevant information, including promotions, about the products and services of Revotrend and its affiliates;
(d) enabling us to better understand your needs and interests;
(e) improving the content, functionality and usability of our Website;
(f) improving our marketing and promotional efforts;
(g) displaying personalised advertising when you visit our Website;
(h) for any other purpose identified in any other agreement between you and Revotrend;
(i) issues, news or other information relevant to your dealings with Revotrend, or about Revotrend generally, or the industries in which you or Revotrend operates; and
(j) as otherwise described in this Privacy Notice.
2.3 Revotrend may Use and/or Share your Personal Data for any Secondary Purposes not included in this Privacy Notice if:
(a) the Secondary Purpose is related to a Primary Purpose; and
(b) you would have a Reasonable Expectation that We would Use the information for that Secondary Purpose.
2.4 From time to time We may Share your Personal Data to organisations outside of Revotrend in order to deliver the services you require or if required for other legal reasons. Your Personal Data is Shared with these organisations in relation to us providing Our services to you or to meet such other legal requirements. These organisations carry out, amongst other services, Our:
(a) billing and debt- recovery functions;
(b) customer inquiries;
(c) information technology services;
(d) marketing and communication services (including market research);
(e) website usage analysis;
(f) to support or facilitate any of those activities described in Points 2.1 and 2.2 herein; and
(g) advisers and insurers.
Revotrend adopts contractual or other means in compliance with the “Security Principle” and “Retention Principle” (Sections 9 & 10 of the Act) to prevent:
(a) your Personal Data transferred to above organisations from being kept longer than is necessary for the purpose or for other legal purposes;
(b) unauthorised access, collection, use, disclosure, copying, modification, disposal of or similar risks to your Personal Data transferred to organisation for the provision of the above services.
Furthermore, We will take reasonable practicable steps to ensure that these organisations are bound by confidentiality obligations in relation to the protection of your Personal Data.
3. DIRECT MARKETING
3.1 Revotrend only targets businesses with its services. Although Personal Data may be collected from any individual through Our website or otherwise for various purposes (i.e., to download a document, respond to a query or a job application), with respect to direct marketing purposes, We intend to use Personal Data that is collected from individuals in their official capacities and Our promoted services are clearly meant for the use of the targeted business.
3.2 Should We have doubts that the collected Personal Data relates to individuals in their official capacities, We ask for consent for Using and/or Sharing any Personal Data Collected from you for Direct Marketing purposes in accordance with the Act, whether Collected via telephone, the Website, or otherwise, but subject to the terms of this Privacy Notice.
3.3 In each Direct Marketing communication, We will include:
(a) a prominent statement appearing on the relevant piece of marketing material notifying you of your right to Opt Out from further Direct Marketing; and
(b) simple means for you to Opt Out of receiving further Direct Marketing communications of that kind.
3.4 Should you Opt Out, We will stop Using and/or Disclosing your Personal Data for Direct Marketing purposes.
4. ENSURING INFORMATION IS ACCURATE AND UP-TO-DATE
4.1 We take reasonable precautions to ensure that the Personal Data We Collect, Use and Share is complete, relevant and up-to-date.
4.2 However, the accuracy of that information depends to a large extent on the information you provide. That’s why we recommend that you:
(a) let us know if there are any errors in your Personal Data; and
(b) keep us up-to-date with changes to your Personal Data. You may change your personal details by using the relevant facility on Our Website or by contacting Revotrend via contact details described in Point 12.
5. HOW WE PROTECT YOUR INFORMATION
5.1 Revotrend will take reasonable steps to protect your Personal Data from misuse, interference, loss and unauthorised access or disclosure. This may include taking reasonable steps to destroy or permanently de-identify Personal Data once it is no longer needed for any purpose for which it may be Used or Shared in accordance with Sections 10 and 11 of the Act (“Retention Principle” and “Data Integrity Principle”).
5.2 Revotrend will not attempt to match de-identified or make anonymous data Collected through surveys or such online devices as “cookies”, with information identifying an individual, without notifying the relevant individual.
5.3 Revotrend requires employees and contractors to perform their duties in a manner that is consistent with Revotrend’ legal responsibilities in relation to privacy, including those in this Privacy Notice.
5.4 Revotrend will take reasonable steps to ensure that Personal Data is only accessible by people who have a genuine “need to know” as well as “right to know.”
6. HOW YOU CAN ACCESS OR CORRECT YOUR INFORMATION
6.1 Revotrend will permit Our records containing your Personal Data to be accessed by you when required by Section 12 of the Act (“Access Principle”). We may, however, refuse to provide you with access to your Personal Data if one or more of those matters contained in the Act – circumstances in which data user shall or may refuse to comply with data access request applies, i.e.:
(a) Revotrend is not supplied with such information as it reasonably requires to satisfy itself as to the identity of the requestor;
(b) Revotrend is not supplied with such information as it reasonably requires to locate the personal data to which the request for access relates;
(c) the burden or expense of providing access is disproportionate to the risks to the data subject’s privacy;
(d) the access would disclose the personal data of another individual who can be identified from that information and the individual does not consent to the disclosure of his identity;
(e) any other data user controls the processing of the Personal Data to which request relates in such a way as to prohibit Revotrend from complying with the data access request; or
(f) providing access would constitute a violation of an order of a court, result in disclosure of confidential commercial information, or where such access is regulated by another law.
Additionally, We may also refuse to provide you with access to your Personal Data or other information in respect of the matters specified in Section 32 of the Act (“Exceptions from Access Requirement”).
6.2 If Revotrend is satisfied that:
(a) having regard to the purpose for which the information is held, the information is inaccurate, out of date, incomplete or irrelevant or misleading; or
(b) you (as the person to whom the Personal Data relates) request that We correct the information; We will take reasonable steps to correct Our records containing your Personal Data as soon as practically possible in accordance with Section 12 of the Act (“Access Principle”) and with the exceptions stipulated in Section 36 of the Act (“Exceptions from Correction Requirement”).
6.3 If We have refused to grant you access to your Personal Data in accordance with Point 6.1 above, We will still take all reasonable steps to provide you with access to your Personal Data in a way that meets both your needs and Our needs.
6.4 If you:
(a) wish to lodge a request to access and/or correct your Personal Data; or
(b) have been refused access to your Personal Data by us for any reason described in this Privacy Notice and you wish to challenge that refusal; you may do so by contacting us as per the details in Point 12.
6.5 Revotrend will not charge a fee for processing an access request unless the request is complex or is resource intensive. Revotrend does, however, reserve the right to charge an administration fee if an individual requests access to their Personal Data more than once in a three month period.
6.6 Where Revotrend offers online account management facilities, customers can use this capability to control aspects of their account, including amending or updating certain Personal Data.
7.1 If you wish to make an inquiry or complaint regarding your privacy, you should contact us as per the details in Point 12.
7.2 You will find that the Revotrend’s Website contains a copy of this Privacy Notice.
8. STAYING ANONYMOUS
8.1 Revotrend will not make it mandatory for visitors to Our Website to provide Personal Data unless such Personal Data is required to answer an inquiry or provide a service. Revotrend may however request visitors to provide Personal Data voluntarily to Revotrend (for example, as part of a competition or questionnaire).
8.2 Revotrend will allow you to transact with us anonymously or by using a pseudonym wherever that is reasonable and practicable.
9. TRANSFERRING PERSONAL DATA
9.1 If we send Personal Data out of Malaysia, Revotrend will take appropriate steps to ensure that the recipient is bound by legally enforceable obligations so at to provide to your transferred Personal Data a standard of protection that is comparable to that under the Act.
9.2 Revotrend may Share Personal Data to a recipient without complying with 9.1 if:
(a) you are Expressly Informed of the intended transfer of your Personal Data to the recipient, and you consent in writing; or
(b) We reasonably believe that the recipient is subject to a law or a binding scheme that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the Act seeks to protect the same and you can access mechanisms to enforce the protection of your Personal Data under that law or that scheme; or
(c) We exercised due diligence to ensure that the Personal Data will not be treated in a manner which will contravene the Act.
10. CHANGES TO THE PRIVACY NOTICE
Revotrend may, in its sole discretion, update this Privacy Notice at any time and from time to time. Any changes will be effective when posted on Our Website. Your continued use of Our Website will indicate your acceptance of any changes to the Privacy Notice. All Personal Data, Collected both before and after any changes take effect, will be subject to the terms of the then current policy, for which you will be taken to have provided consent, unless you indicate otherwise by contacting us as per the details in in Point 12. We encourage you to refer back to this page and especially prior to providing us with any Personal Data.
CollectÂ means gather, acquire or obtain by a lawful and fair means, information in circumstances where the individual is identifiable or identified.
Direct MarketingÂ involves the Use and/ or Sharing of Personal Data to communicate directly with an individual to promote goods or services through written, verbal or electronic means of communication for the company that the individual is acting for and behalf of. The goods or services which are marketed may be those of Revotrend or those of an independent third party organisation on behalf of Revotrend.
SharingÂ generally means the release of information outside Revotrend, including under a contract to carry out an “outsourced function.”
Expressly InformedÂ means the circumstance where We have provided you with a clear statement (either verbal or in writing) of the fact that that We will not be accountable under the Act and you will not be able to seek redress under the Act in the event that you provide consent to the Sharing of your Personal Data by us to a recipient outside of Malaysia and this recipient handles your Personal Data in breach of the Act.
Opt OutÂ means an individual’s expressed request not to receive Direct Marketing communications.
Revotrend MalaysiaÂ means Revotrend Sdn Bhd including all subsidiaries, related and/or associated companies.
Personal DataÂ means any data (a) relating directly or indirectly to a living individual;(b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (c) in a form in which access to or processing of the data is practicable. This includes, but is not limited to, an individual’s name, address, telephone number and email address.
Primary PurposeÂ is the main reason for the Collection of any Personal Data.
Reasonable ExpectationÂ means an individual’s reasonable expectation that their Personal Data might be Used or Shared for the relevant purpose.
Secondary PurposeÂ means a purpose of Use or Sharing other than a Primary Purpose.
UseÂ means the handling of Personal Data within Revotrend.
WebsiteÂ means the website of Revotrend and related webpages.
12. CONTACTING REVOTREND
If you have questions concerning this Privacy Notice, please contact us:
- by telephone on +603-6257 7699 between 8.30am and 6pm Monday to Friday; or
- via email to the Data Protection Officer atÂ firstname.lastname@example.org.
You can obtain further information about your privacy rights and the Act from the Personal Data Protection Department by visiting its web site atÂ http://www.pdp.gov.my/
13. LANGUAGE OF THIS PRIVACY NOTICE
In accordance with the requirements of the Act, this Privacy Notice is issued in both English and Bahasa Malaysia. In the event of any inconsistencies or discrepancies between the English version and the Bahasa Malaysia version, the English version shall prevail.
This Privacy Notice was last updated on 31 October 2018.