Privacy Policy

This Privacy Notice sets out how CLL Systems Sdn Bhd, its subsidiaries and affiliates (collectively referred to as CLL Systems’, ‘us’, ‘we’, ’our’) understand the importance of ensuring that we collect, process, update, maintain, use, store, share and dispose of (collectively ‘Use’) personal data/information about you (‘Personal Data’) in a fair, ethical, transparent, secure and lawful way in accordance with the Personal Data Protection Act 2010 (“PDPA”) and the laws of Malaysia.

This Privacy Statement describes what Personal Data we Use about you, how we Use it, and your choices and rights in relation to your Personal Data. This Privacy Statement applies to our Use of your Personal Data in our interactions with you through our websites and social media sites (“Sites”) that link to our Privacy Statement, or Personal Data about you that we may collect offline or receive from other parties, including and not limited to information acquired from third party sources such as credit reporting agencies for the purpose of execution of commercial sales and purchase transactions, credit risk assessment and management, advertisement and promotional activities, and other general business related matters.

Please read this Privacy Statement to understand how we process the Personal Data we may collect from you. By accessing our Sites and/or providing your Personal Data to us, you are agreeing to the provisions of this Privacy Statement and the processing of your personal data as described in this Privacy Statement.

Personal Data is any information that identifies you or relates to you.

We collect Personal Data about you from different sources including amongst others: Personal Data that we collect directly from you; Personal Data that we collect automatically about you as you use our Sites; and Personal Data that we collect from other sources, as described in this Privacy Statement.

• Personal Data that we collect directly from you.

  We collect Personal Data directly from you in the following circumstances:

  • Onboarding Process: When you onboard as a customer or representative of a customer, we collect your name, business contact information, job title, and employer’s name.
  • Products, Service or Solution Purchase: When you place an order for our products, services and solutions, you will need to create an account where we collect the aforementioned information and your payment information.
  • Contact or Feedback Submission: When you reach out to us for information or provide feedback, we may collect your name, contact information, job title, industry, location, and inquiry details.
  • Mailing Lists or Newsletters Subscription: When you subscribe to our mailing lists or newsletters, we collect your email address.
  • Downloadable Content Access: For white papers, reports or other collateral, we may collect your name, contact information, job title, industry and location.
  • Events, Workshops, or Seminars Registration and Attendance: When you register for and attend our events, we collect your name, contact information, meal preferences, contact preferences, and additional details required to be provided in our event forms.
  • Use of our Sites: When you use our Sites, we will collect information about your use of the Site and any information that you submit through the Sites.
  • Social Media Interactions: When you engage with our social media pages, we may collect information from your post to respond to your inquiries and we do not usually associate this information with your account.
• Personal Data that we automatically collect.

  We, and our service providers, automatically collect the following information about your use of our Sites through cookies, web beacons, and other technologies including amongst others: your domain name; your browser type and operating system; web pages you view; links you click; language preferences; demographic information such as your marketing preferences; your IP address; the length of time you visit or use our Sites; and the referring URL, or the webpage that led you to our Sites. We may also collect your approximate location through collection of your IP address. Typically, we do not combine this information with other information that we have collected about you, including, other Personal Data. For more information, see the “Cookies and Similar Technologies” section below.

• Personal Data we collect from other sources.

  We also collect Personal Data from other sources, as follows:

  • Our Affiliates: Subject to applicable law, or, where your consent is required, our affiliates may provide your contact information to us if they believe that a product, service or solution may be of interest to you.
  • Our Business Partners: We collect information about you from our business partners with whom we offer co-branded services or engage in joint marketing activities.
  • Public Databases or List Enhancement Services: We obtain information about you from public databases and list enhancement services. This may involve employing a service provider to validate mailing addresses. Occasionally, our external service provider may handle mailing activities, resulting in us not directly obtaining updated address information.

We do not collect sensitive or special category Personal Data about you, e.g. information related to your health, biometric or genetic details, religion, beliefs, political affiliations, membership in unions, race or sexual orientation. We kindly request that you refrain from sending or providing this type of information to us.

You have the option to choose not to provide Personal Data to us in certain circumstances. However, if your Personal Data is necessary to provide you with our products, services or solutions, or to grant access to our Sites, or to perform administrative functions, we may be unable to fulfil these actions without your Personal Data.

We use your Personal Data for the following purposes depending on the purpose for which your Personal Data was collected and our relationship with you:

• • Entering and Performance of Contract: to provide our products, services or solutions to you or your employer and to take action on your or your employer’s requests.
  • Legitimate Business Interests: to protect our legitimate business interests or those of a third party with whom we share your Personal Data, for the purpose of managing, operating or promoting our business, including and not limited to activities like direct marketing, and intra-CLL Systems transfers of Personal Data for business and administrative purposes. We always endeavour our best to ensure that our business interests do not override your fundamental rights and freedoms. If you have concerns, you have the right to object to our use of your Personal Data in certain circumstances. See the ’Your Rights’ section of this Privacy Statement.
  • Compliance with Mandatory Legal Obligations: to ensure compliance with Malaysian laws and regulations that govern and regulate our business operations and/or prevention of illegal activities or crimes.
  • Consent: Where you have provided consent to us to use your Personal Data, we will use your Personal Data as provided herein. You have the right to withdraw your consent at any time. When giving consent, you will receive details on how we will use your Personal Data and where you can go to withdraw your consent if you change your mind.
  • General purposes: for purposes relating to any of the above (including but not limited to research, benchmarking and statistical analysis) and any other relevant purposes in undertaking ordinary course of our businesses including and not limited to conduct credit risk assessments and background check or to recover outstanding payments owing.

We may use your Personal Data to:

• enable effective use and improvement of our products, services and solutions. This includes:
  • performing administrative and business functions as well as internal reporting;
  • sending administrative information and managing our business relationship with you;
  • obtaining feedback from you about our products, services and solutions, for the purpose of sending customer satisfaction surveys through third party;
  • assessing and improving the performance of our Sites;
  • processing orders and delivering products, services and solutions;
  • providing current information about our products, services and solutions;
  • responding to inquiries and fulfilling requests;
  • updating records and maintaining up-to-date contact details.

• provide personalized experiences and marketing materials. This includes:
  • sending marketing communications;
  • enhancing your interaction experience with personalized content;
  • enabling subscription to newsletters and mailing lists;
  • managing marketing and cookie preferences;
  • facilitating registration and attendance for events, workshops and seminars.

• achieve business purposes and analyze information. This includes:
  • establishing, managing, and maintaining our business relationship with you;
  • compiling usage statistics for our Sites;
  • handling privacy requests, questions, concerns and complaints;
  • fulfilling contractual obligations.

• conduct research and analysis to:
  • better understand Site usage;
  • improve products, services and solutions;
  • evaluate demand for products, services and solutions;
  • administer surveys and questionnaires for market research or customer satisfaction purposes.

• comply with legal obligations. This includes:
  • investigating, preventing, or taking action regarding illegal activities or suspected fraud;
  • addressing violations of our Terms of Use or this Privacy Statement.

We may share your Personal Data with the third parties, including and not limited to the following parties for the purposes set out in this Privacy Statement (as applicable):

• Our Affiliates: for the purposes set out in this Privacy Statement, CLL Systems Sdn Bhd is the entity responsible for the management of jointly used Personal Data.
• Business Partners: to offer co-branded services or engage in joint marketing activities, in compliance with applicable law.
• Service Providers: to provide operational services or facilitate transactions on our behalf, including but not limited to order processing, sales-related assistance, post-sales support, customer service, email delivery, data analytics, survey distribution and insights, and auditing.
• Authorities: to fulfil requests for information from competent authorities in accordance with, or required by any applicable law, regulation or legal process; or where necessary to comply with judicial proceedings, court orders or government directives.
• Other parties: when necessary, our auditors, consultants, accountants, lawyers or other financial or professional advisers; any guarantor or security provider related to your trade facility; debt collection and/or credit reporting agencies in the event of default in payment.

We also may share your Personal Data in the following circumstances:

• When you consent to the sharing of your Personal Data;
• In the event of any joint venture, merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company. This includes sharing with our advisors and the advisors of the other company involved in such transactions;
• To protect the rights, property or safety of CLL Systems Sdn Bhd, its business partners, you, or others, or as required by applicable law;
• For other reasons in the good-faith belief that such action to protect and defend our rights or property, or in urgent circumstances to protect the personal safety of any individual.

When we share Personal Data with our service providers or other parties, we will take reasonable efforts to ensure that they implement appropriate physical, administrative and technical safeguards to protect Personal Data and that they are not permitted to use Personal Data for any purpose other than the purpose for which they are provided with or given access to Personal Data.

We are committed to protecting your Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized access or disclosure by using a combination of physical, administrative and technical safeguards and contractually requiring our service providers to whom we disclose your Personal Data to do the same.

While we endeavour to ensure the security of your Personal Data, please note that absolute security cannot be guaranteed. Therefore, it is important for you to take reasonable precautions to protect your Personal Data (e.g. by not sharing your passwords, selecting strong passwords and implementing other appropriate measures). If you are sharing a computer/laptop/device with anyone, you should always log out before leaving a website so that subsequent users will not be able to access your data.

We retain your information for as long as is necessary to fulfil the purposes for which it was collected, unless we are required to keep it longer due to legal obligations, dispute resolution, asset protection, or rights enforcement. The criteria we use to determine how long we retain Personal Data includes:

• legal, contractual or other obligations;
• maintenance of accurate business and financial records;
• provision of automated means for accessing and deleting your Personal Data at any time;
• consent-based retention in line with your preferences.

In some instances, we may anonymize your information in accordance with our policies and may retain those anonymized records for longer periods.

Our information technology storage facilities and servers may be located in other jurisdictions outside of Malaysia. This may include, but not limited to, instances where your Personal Data may be stored on servers located outside Malaysia. In addition, your Personal Data may be disclosed or transferred to entities located outside Malaysia or where you access the Site from countries outside Malaysia. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in Malaysia under the laws of Malaysia. By choosing to use our Sites and/or to providing Personal Data to us, you hereby expressly consent to us transferring your Personal Data outside of Malaysia for such purposes. We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of Malaysia shall not use your Personal Data other than for that part of the Purposes and to adequately protect the confidentiality and privacy of your Personal Data.

You have rights under data protection law in relation to your Personal Data.

We are committed to upholding your rights, including:

• Right to be informed: you have a right to know what Personal Data we have about you, what we do with it, where we get it from, who we share it with, how long we keep it and why we need it
• Right of access: you have the right to access your Personal Data and obtain a copy of your Personal Data from us
• Right to rectification: you have the right to update inaccurate and/or incomplete Personal Data about you
• Right to be forgotten: you have the right to have your Personal Data erased, deleted or destroyed
• Right to data portability: you have the right to move, copy or transfer your Personal Data in a safe and secure way and reuse it for your own purposes
• Right to withdraw consent: you have the right to withdraw consent at any time regarding the use of your Personal Data or in relation to direct marketing activities
• Right to restrict Use: you have the right to limit the way we use your Personal Data
• Right to object: you have the right to stop or prevent us from using your Personal Data. In particular, you can object to our use of your Personal Data for direct marketing or the sale of your Personal Data
• Right to challenge automated decisions: you have the right to query and review decisions made about you using purely automated means (i.e. without human involvement or intervention)
• Right to complain: you have the right to make a complaint or raise a concern about how we use your Personal Data. Complaints may be made directly to us or a relevant Data Protection Authority

Where you contact us, we may request specific information from you to verify your identify to enable us to assist you. Where permitted under applicable law, we may charge you a reasonable fee to access your Personal Data, however we will advise you of any fee in advance.

In certain instances, we may be unable to fulfil a request due to legal or regulatory constraints, or where we are not obligated to enforce such rights according to relevant laws. Additionally, we may have a legitimate business interest that necessitates declining a request to exercise your rights. You may contact us with requests, complaints or questions regarding these rights as set forth in the ‘How to contact us’ section, below.

When you access our Sites, we and our service providers use, amongst others, cookies (small text files containing a unique identification number which are placed on your PC or device) and similar technologies including scripts, embedded web links, web beacons, Local Shared Objects (flash cookies) and Local Storage (HTML 5). We and our service providers use, amongst others, cookies to assist us with activities such as:

• Facilitating your sign-in to our Sites;
• Authenticating your identity;
• Tracking information provided to us;
• Enhancing your browsing experience;
• Personalizing our interactions with you;
• Storing and managing your preferences and settings;
• Compiling statistical data;
• Analyzing the performance and usability of our Sites;
• Measuring traffic patterns on our Sites;
• Identifying visited areas of our Sites;

These technologies collect information that your browser sends to our Sites including data such as your browser type, information about your IP address (a unique identifier assigned to your computer or device which allows your PC or device to communicate over the Internet), together with the date, time and duration of your visit, the pages you view and the links you click on.

Our Sites may also contain web beacons or similar technologies from analytics providers, through which they collect information about your activities across our Sites to help us to compile aggregated statistics.

Currently, our Sites do not recognize web browser “do-not-track” requests, but several of our service providers who utilize these cookies or web beacons on our Sites enable you to opt out of targeted advertising practices. You may, however, disable certain tracking as discussed in this section (e.g. by disabling cookies) or you may also opt-out of targeted advertising by following the instructions in the Cookies Statement.

For more information on how we use cookies and other technologies, please refer to the relevant Cookies Statement.

Our Sites may provide links to the websites of other parties. Some of the content, advertising, and functionality of our Sites may be provided via other parties that are not affiliated with us. Once you have used these links to leave our website, you should note that we do not have any control over those other websites.

We are not responsible for and make no representations or warranties in relation to the security, privacy practices and content of these websites. Please ensure that you read the applicable privacy and cookies policies of these third-party sites before sharing Personal Data on these third-party sites. Your use of such third-party sites is at your own risk.

You may also interact with us through social media plug-ins by ‘liking’ or sharing information provided on our Sites. Social media plug-ins are operated by the social network themselves (such as Facebook, LinkedIn, Twitter, Google+, etc.) and are subject to the terms of use, privacy and cookies policies of the respective social network. Please ensure that you are familiar with these.

We may send you direct marketing communications about our products, services and solutions.

You can choose whether you wish to receive marketing communications from us.

You may opt-out of receiving marketing materials from us at any time and manage your communication preferences by:

• selecting the option to ‘Unsubscribe’ included in our communications with you and at the bottom of our Sites;
• updating your preferences in our online Preference Center;
• sending an email to CLL Marketing at [email protected];

Once we have received and verified your opt-out request, we will comply with your request as soon as is reasonably practicable.

If you opt-out of receiving marketing related communications from us, we may still send you administrative messages as part of your ongoing use of our products, services and solutions, which you are unable to opt-out of.

We do not provide your Personal Data to unaffiliated parties for their own direct marketing purposes or sell, rent, distribute or otherwise make Personal Data commercially available to any third party.

Our Sites is a general audience site, although it may contain information that may be of interest to children. However, we do not seek to gather Personal Data from Minors.

To the extent that you have provided (or will provide) Personal Data about your family, spouse and/or other dependents, you confirm that you have explained to them that their Personal Data will be provided to, and processed by, us and you represent and warrant that you have obtained their consent to the processing (including disclosure and transfer) of their Personal Data in accordance with this Policy and, in respect of minors (i.e. individuals under 18 years of age) or individuals not legally competent to give consent, you confirm that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their Personal Data in accordance with this Policy.

We may update our Privacy Statement at any time. If we do, we will update the ‘Version’ and ’Last update’ information at the top of our Privacy Statement.

We encourage you to regularly review our Privacy Statement to stay informed about how we use your Personal Data and privacy practices.

While we strive to maintain the utmost accuracy and currency of our Privacy Statement’s terms and conditions, it is possible for errors to arise. Given the dynamic nature of laws, rules, and regulations, occasional delays, omissions, or inaccuracies in the information provided may be inevitable. Consequently, we cannot be held liable for any errors or omissions, nor for any outcomes resulting from the use of your Personal Data due to the aforementioned factors.

As a condition of your use of our Sites, you represent and warrant that the Personal Data that you shall provide to us shall be true and accurate and that you shall not use the Sites for any purpose that is unlawful or prohibited by laws and/or this Privacy Statement including and not limiting to the following:

• publish, distribute or disseminate any harmful, inappropriate, profane, vulgar, infringing, obscene, tortious, indecent, unlawful, immoral or otherwise objectionable material or information;
• defame, abuse, harass, stalk, threaten or otherwise violate or infringe the legal rights (such as, but not limited to, rights of privacy, publicity and intellectual property) of others;
• transmit or upload any material to the Web site that contains viruses, trojan horses, worms, time bombs, cancelbots, or any other harmful or deleterious programs;
• interfere with or disrupt the Web site networks or servers;
• attempt to gain unauthorized access to the Web site, other accounts, computer systems or networks connected to the Service, through password mining or any other means; or
• interfere with another individual’s or entity’s use and enjoyment of our Web site.

You shall be solely responsible and liable for all acts or omissions that occur while you use our Sites.

This Privacy Statement is prepared pursuant to the Malaysian Personal Data Protection Act 2010 and shall be governed by and construed and interpreted in accordance with the laws of Malaysia, without giving effect to its rules governing conflict of laws. You consent to submit to the jurisdiction of the courts of Malaysia. This Privacy Statement represents the entire understanding between us with respect to the subject matter hereof and supersedes all other written or oral agreements with respect to the subject matter hereof. If any provision of this Privacy Statement is declared invalid by a court of competent jurisdiction, such provision shall be ineffective only to the extent of such invalidity, so that the remainder of that provision and all remaining provisions of this Privacy Statement shall continue in full force and effect.

If you have any questions about how we use your Personal Data, have a privacy concern, or wish to make a request or complaint relating to your Personal Data, please contact us at [email protected].