Privacy Statement
The purpose of this document (“Privacy Statement”) is to inform you of how Strategy Winner SDN BHD (Company No. 1278432-K), (“us”, “we” or “our“) manages Personal Data (as defined below) which is subject to the Malaysian Personal Data Protection Act 2010 (Act 709), as amended or re-enacted from time to time (“the Act”).
Please take a moment to read this Privacy Statement so that you know and understand:
- how and when we collect your Personal Data;
- the types of Personal Data we collect from you;
- why we collect your Personal Data and how we use your Personal Data;
- how we manage the security of your Personal Data; and
- how long we retain your Personal Data.
By accessing our website, interacting with us and submitting Personal Data to us, you agree and consent to us, as well as our representatives and/or agents collecting, using, processing, disclosing, sharing and storing your Personal Data, and disclosing such Personal Data to relevant third parties in the manner set forth in this Privacy Statement.
| 1. Personal Data | ||
| 1.1 | In this Privacy Statement, “Personal Data” refers to any information about an individual who can be identified (a) from that information; or (b) from that information and other information which is in our possession. | |
| 1.2 | Examples of Personal Data that we may collect from you include: | |
| (a) | personal details such as your name, address, contact number, email, passport number and IC number; | |
| (b) | demographic details such as your profession, age, race, ethnicity, gender, marital status, income and education level; and/or | |
| (c) | internet details such as your Internet Protocol address, or website movements, log-in information, browser type, operating system and URL information. | |
| 1.3 | If you provide us Personal Data of anyone other than yourself, please make sure you have their prior consent to provide us their Personal Data and they understand how we collect, use, process, share, disclose and store Personal Data as set out in this Privacy Statement. | |
| 1.4 | Although we try to provide reasonably adequate information concerning our policy relating to Personal Data, this Privacy Statement is not an exhaustive list of all situations or scenarios concerning Personal Data. Please approach us if you need clarification about a specific situation. | |
| 2. Collection of Personal Data | ||
| 2.1 | We may collect Personal Data from you in a variety of ways, such as where you voluntarily: | |
| (a) | visit our website (see “Cookies” below for further details on what Personal Data we obtain by you visiting our website); | |
| (b) | interact with our website, for e.g. when you contact us via our website; | |
| (c) | interact with our staff via telephone (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails; | |
| (d) | apply to us or one of our subsidiaries for a job; | |
| (e) | request for further information or documents (e.g. Annual Report); | |
| (f) | attend our events or meetings (e.g. Annual General Meeting); | |
| (g) | submit any forms to us (such as the Whistleblower’s Form); | |
| (h) | when your images are captured via CCTV cameras while you are at our premises, or via photographs or videos taken by us or our representatives when you attend our events or activities (such as our Annual Dinners or Annual General Meetings); and/or | |
| (i) | when you submit Personal Data to us for any other reasons. | |
| 2.2 | You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the information you have requested, or delay in providing you with the information you have requested, or responding to your queries; or processing any requests submitted to us. | |
| 3. Purposes of the Collection and Use of Your Personal Data | ||
| 3.1 | Generally, we collect, use and disclose Personal Data for the following purposes: | |
| (a) | to identify you and personalize any communications with you; | |
| (b) | to obtain information about your preferences, online movement and use of our website, to help us better understand your requirements and interests in order to make your online browsing more efficient and enjoyable; | |
| (c) | to carry our research and statistical analysis to help improve the content of our website, and as part of our effort to keep our website safe and secure; | |
| (d) | to process and respond to queries, feedback, complaints and requests; and/or | |
| (e) | for such other purposes related to the above or where it is permitted under applicable laws. | |
| (collectively, “Purpose”). | ||
| 4. Disclosure of Personal Data | ||
| 4.1 | We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the Purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Malaysia: | |
| (a) | amongst the Strategy Winner SDN BHD of companies (“Group”); | |
| (b) | our approved third party service providers who provide services to the Group, such as insurance companies, financial institutions, telecommunications, information technology, payment, printing, billing, debt recovery or other services to the Group; | |
| (c) | our professional advisers such as consultants, auditors and lawyers; | |
| (d) | relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or | |
| (e) | any other party to whom you authorise us to disclose your Personal Data to. | |
| 5. Security of Personal Data | ||
| 5.1 | We will use reasonable commercial efforts to protect Personal Data against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. | |
| 5.2 | We use various methods to safeguard Personal Data, including physical measures, technical tools and organisational controls. | |
| 5.3 | Online security is also a priority. We incorporate security measures such as encryption and authentication tools to protect your Personal Data from unauthorized use. Firewalls are utilized to protect our servers and network from unauthorized users accessing and tampering with files and other information that we store. | |
| 5.4 | While we cannot ensure that loss, misuse or alteration of data will not occur, we will make reasonable commercial efforts to prevent such unfortunate occurrences. | |
| 6. Retention of Personal Data | ||
| 6.1 | We retain Personal Data provided or made available to us as may be required for business or legal purposes, and such purposes do vary according to the circumstances. | |
| 7. Cookies | ||
| 7.1 | When you interact with us on our website, we or our authorized service providers may use cookies for collecting and storing information to help provide you with a better, faster and safer web experience. | |
| 7.2 | The information collected by us or our authorized service providers may recognize a return visitor as a unique visitor and may collect information such as: how a visitor arrives at our sites, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page. | |
| 7.3 | Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website. Cookies allow a website to recognize a particular device or browser. | |
| 7.4 | The use of cookies, by us or our website is necessary for the functioning of our services, to help us improve our performance, or serve to provide you with extra functionalities. They may also be used to deliver content that is more relevant to you and your interests, or to target advertising to you on or off our site. | |
| 7.5 | Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, if you decline cookies, you may not be able to take advantage of certain site features or services tools. | |
| 8. Contacting Us – Withdrawal of Consent, Access and Correction of Your Personal Data | ||
| 8.1 | We have procedures in place in order to receive and respond to enquiries about our policies and practices relating to our handling of Personal Data. Any complaint or enquiry should be made in writing and addressed as shown below. If there are any questions or concerns regarding this Privacy Statement or the data collection practices outlined herein, please email our Admin at admin@strategywinner-com. | |
| 8.2 | You can request to correct or update your Personal Data held by us by emailing us at the above address. We will endeavour to provide you with suitable means of accessing your Personal Data (e.g. by emailing or mailing it to you). You may also request us to correct or update your Personal Data by contacting us at the above address. We reserve the right to verify all requests for the authencity of the request. | |
| 8.3 | If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide you with the information you have requested or respond to or process your queries. | |
| 9. Links to Third Party Website | ||
| 9.1 | Our site may contain links to and from the websites and social media channels of our affiliates and other third parties.If you follow a link to any of these websites or channels, please note that these websites or channels have their own privacy statements or policies. We are not responsible for the privacy practices or content of such sites. Please review the privacy statements or policies posted at those sites. | |
| 10. Changes to this Privacy Statement; Conflicts | ||
| 10.1 | We reserve the right to change this Privacy Statement from time to time. Any change we make to this Privacy Statement will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Statement and in particular, before you submit additional Personal Data. | |
| 10.2 | If there is a conflict between the English version and the national language version of this Privacy Statement, the English version shall prevail, to the extent of the discrepancy. | |
| Updated on 7 May 2021 | ||