We, Hybrid Management Sdn Bhd (Registration No. 1353797-P) (“Hybrid Management”) are committed to protecting all Personal Data kept by us and providing our customers with the highest levels of customer service. Hybrid Management is bound by the Personal Data Protection Act 2010 and the related law and regulations, which set out a number of principles concerning Personal Data and consumer protection in Malaysia.
“Authorised Third Parties” means Hybrid Management’s contractors, agents, sponsors, organizers or third party suppliers with whom Hybrid Management enters into an agreement to provide the services.
“Personal Data” means any personal information relating to Hybrid Management’s customer that the customer has provided to Hybrid Management or made available to Hybrid Management due to his/her contract with Hybrid Management, i.e. name, date of birth, current and previous addresses, telephone or mobile numbers, email address, bank account or credit card details, username or password;
“Sensitive Personal Data” comprises information as to the customer’s physical or mental health or condition, political opinions, religious beliefs or other beliefs of a similar nature, commission or alleged commission of any offense or any other Personal Data determined by law;
“Services” comprises of all type of services provided by Hybrid Management.
1.2. Personal Data held by us may include your name, date of birth, current and previous addresses, telephone or mobile numbers, email address, bank account or credit card details, username or password (“Personal Data”). Hybrid Management also holds details of Hybrid Management’s services (including their status) as well as certain details about your personal interests.
Personal Data management practices, including the types of information gathered, how it used and safeguarded and the degree to which you may control the maintenance and sharing of your Personal Data. Hybrid Management will act in accordance with the
current Malaysian legislation on Personal Data including but not limited to the Personal Data Protection Act 2010.
1.5. If you choose not to provide certain Personal Data, Hybrid Management may not be able to provide you with the services you require.
Hybrid Management is directly responsible for the administration of this policy and monitoring enterprise wide compliance.
3. EFFECTIVE DATE
This policy is effective as at 1 st January 2020.
4. PERSONAL DATA PROTECTION PRINCIPLES
4.1. General Principle:
4.1.1. Hybrid Management will use, process, record, hold, store, share and disclose (“process”) Personal Data provided to Hybrid Management by you when you register for our services and with your consent.
4.1.2. Continuance of use of Hybrid Management’s services and/or products shall amount to your consent for the processing of your Personal Data by Hybrid Management.
4.1.3. If you are below the age of 18, you should ensure that you obtain the prior consent of your parents or legal guardian before obtaining Hybrid Management’s Services and/or products.
4.2. Notice and Choice Principle:
4.2.1. Your Personal Data will be used by Hybrid Management’s contractors, agents or third party suppliers with whom Hybrid Management enters into agreement to provide the Services (“Authorised Third Parties”), in support of the purposes stated at the time at which it was given or sought, and/or including but not limited to the following reasons:
- For the provision of Hybrid Management’s services;
- For the purposes of technical administration of the Hybrid Management’s website and services;
- For research and development;
- For statistical analysis;
- For customer administration, including outsourced customer service management;
- For profiling service preferences;
- For finance and marketing operations and activities and/or as required in the provision of our services including but not limited to credit control services;
- In compliance with any regulatory, statutory or legal obligation imposed on us by any relevant authority;
- To support your questions about billing or use of the services;
- To detect and prevent fraudulent activity;
- To provide other goods and services by Hybrid Management or its designated representatives and/or business partners to you or parties designated by you and matters ancillary thereto;
- To verify and record your Personal Data including comparing it with information from other sources and using the information to communicate with you;
- To conduct market research of the users of Hybrid Management’s website and services including the number of users, the frequency of use, profile of users and using such analysis for our business plans, the enhancement of our products and services, targeted advertisements and conveying such information in broad aggregate terms to third parties who have or propose to have business dealings with Hybrid Management;
- To send you information, promotions and updates including marketing and advertising materials in relation to our goods and services and those of third-party organisations selected by Hybrid Management;
- To comply with any order of court or directive from authorities investigating any alleged offence, misdeed and/or abuse, where such action is necessary to protect and defend the rights or property of Hybrid Management;
- To Hybrid Management’s shareholders, related corporations and affiliated companies for purposes of providing any goods or services to the customer;
- To payment channels including and without limitation, financial institutions for purposes of maintaining financial records, assessing or verifying credit and facilitating payments of any amount due to Hybrid Management pursuant to the Terms and Conditions;
- To other service providers or to parties nominated by Hybrid Management either solely or jointly with other service providers, for purposes of establishing and maintaining a common database of customers;
- To Hybrid Management’s professional advisors on a need to know basis.
4.2.2. Any customers who have provided his/her Personal Data prior to this policy, may contact Hybrid Management using the contact details set out below to know what types of Personal Data have been processed and the purpose for the processing.
4.2.3. Clause 4.3.1 above and except as permitted or required under any enactment, law, statute or code in Malaysia, Hybrid Management will not use or disclose your
Personal Data without your prior written consent.
4.2.4. You will be given the opportunity to “opt-out” of having your Personal Data used for purposes not directly related to the services or Hybrid Management’s website at the point where Hybrid Management asks for information.
4.3. Disclosure Principle:
4.3.1. Hybrid Management will not sell or rent your Personal Data to third parties. Save as provided for herein, Hybrid Management will not disclose your Personal Data to any third party without your consent.
4.3.2. Hybrid Management may from time to time, contact you on behalf of external business partners about particular goods, offers, or services that may be of interest to you. In those cases, Personal Data that may identify you will not be transferred to the third party. All communication whether from Hybrid Management’s business partners will be sent to you by Hybrid Management.
4.3.3. Hybrid Management may, however, need to work with Authorised Third Parties to provide part or all of Hybrid Management’s website, services, and/or other services to you or to perform market research and statistical analysis. In such situations, Hybrid Management will share your Personal Data as is necessary for the Authorised Third Party to perform these services, on a strictly confidential basis. These parties are not allowed to use your Personal Data disclosed to them except for the limited purpose of providing the particular service for Hybrid Management. By using and continuing to use Hybrid Management’s website you are deemed to have consented to such disclosure.
4.4. Security Principle:
4.4.1. Hybrid Management has implemented security policies, rules, and technical measures to protect your Personal Data from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction, or accidental loss. All our employees and data processors, who have access to and are associated with the processing of Personal, are obliged to respect the confidentiality of your Personal Data.
4.4.2. Personal information that Hybrid Management collects from you will be stored and backed up securely in an environmentally controlled location which shall be accessible by Hybrid Management’s authorized personnel.
4.4.3. In discharging its responsibilities with respect to the confidentiality of Personal Data, Hybrid Management will employ a number of safeguards, appropriate to the sensitivity of the information, to protect Personal Data against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures, and technological measures, for example, locked filing cabinets, restricted access to offices, security clearances and limiting access on a “need to know” basis and use of passwords and encryption. Procedures for implementing these measures will be communicated to all Hybrid Management employees and third parties to ensure compliance with this principle.
4.5. Retention Principle:
4.5.1. Personal data processed for any purpose or purposes by Hybrid Management will not be kept for longer than is necessary for that purpose or those purposes.
4.5.2. Hybrid Management will store your Personal Data as long as the purpose it was collected remains valid and thereafter for a period of seven (7) years or any other period of time required and/or permitted by Malaysian law.
4.6. Data Integrity Principle:
4.6.1. Hybrid Management takes all reasonable precautions to ensure that the Personal Data that we collect, use and disclose is accurate, complete and up to date. However, the accuracy of that information depends to a large extent on the information that you provide.
4.6.2. You have the right to access your Personal Data, subject to some exceptions allowed by law. If you would like to do so, please let us know. You may be required to put your request in writing for security reasons. We reserve the right to charge a fee as permitted by the applicable law in Malaysia, including but without limitation to Personal Data Protection Act 2010 for searching for and providing access to your information.
4.6.3. Hybrid Management reserves the right to refuse to provide Hybrid Management’s visitors with a copy of their Personal Data by providing a written explanation for such refusal.
4.7. Access Principle:
4.7.1. Any customer dealing with Hybrid Management can have access to his/her Personal Data that Hybrid Management has in its possession or control and may request that his/her Personal Data be amended for purposes of accuracy and completeness.
4.7.2. You may at any time remove your personal details from our database or amend or correct those Personal Data. If you remove your Personal Data from our records, we will no longer be able to provide our services to you.
5. SENSITIVE PERSONAL DATA
5.1. Hybrid Management will obtain explicit consent from you before or when we process Sensitive Personal Data.
5.2. Hybrid Management may process Personal Data without your consent only in limited circumstances as permitted by Malaysian law.