PRIVACY POLICY

Last updated on 16 November 2024

This Privacy Policy describes how Infomina AI collects, stores, uses, discloses or otherwise processes information associated with an identified or identifiable individual (referred to in this Privacy Policy as “Personal Data”) and what choices you have around this activity. If you have any questions, please do not hesitate to contact us.

When we refer to “Infomina” or “Infomina AI”, we mean Infomina AI Sdn Bhd (Registration No. [Ÿ]), a company validly subsisting under the Malaysia Companies Act 2016.

Our objective of using your Personal Data is to provide the Services (as defined below) to you. Your data and privacy are of utmost priority to us in every aspect, we will not reveal any of your Personal Data to any third party without your consent. Infomina AI ("we", "our", or "us") is committed to protecting your Personal Data.

This Privacy Policy applies to our Services and other interactions you may have with Infomina AI on the Website (as defined below), domain and/or sub-domains where the Services are being provided. By accessing and/or using our Services or register for an Account (as defined below) on our website, you signify that you have read, understood, and agreed to our collection, storage, use, disclosure and process of your Personal Data as described in this Privacy Policy.

By proceeding, you agree and provide your consent to the collection, use, disclosure, storage and/or processing of your personal data under the terms of this Privacy Policy.

DEFINITIONS AND KEY TERMS

The following terms as used in this Privacy Policy shall have the meaning ascribed next to them:

1. PERSONAL DATA WE COLLECT FROM YOU

The type of Personal Data which we collect from you may vary depending on the nature of our relationship and may include Personal Data that is sensitive in nature. We only collect Personal Data that is necessary and depending on the purpose of collection, including but not limited to the following:

(a) your name;

(b) contact information such as telephone or mobile phone number and email address;

(c) the messages sent by you to our AI chatbot assistance as well as the messages that you have had with us;

(d) log data, which may include your IP Address, the address of the web page you visited before visiting the Website or using the Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins;

(e) information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs and unique device identifiers;

(f) your approximate location which we may determine through the IP Address received from your browser or device; and

(g) diagnostic data related to Service usage to allow us to deliver the Services (troubleshoot, secure and update the Services and monitor performance) and perform internal business operations.

We may also collect from you the aforementioned Personal Data relating to persons connected to you, such as your family members, friends, and colleagues. Where you are providing us with the Personal Data of such persons, please ensure that they have read this Privacy Policy and consented to us processing his/her Personal Data for any of the purposes prior to supplying the information to us. Upon us receiving these third-party Personal Data from you, it shall be deemed that you have obtained their consent for the disclosure of their Personal Data to us and the processing thereof.

We would also like to inform you that in order for us to provide you access to our Services, it may be obligatory for you to provide us with certain types of Personal Data. Conversely, some Personal Data may be voluntary or optional. We will indicate at the time of request on whether the Personal Data is obligatory or voluntary. In the event that you decline to provide obligatory Personal Data or withdraw your consent for us to use such Personal Data, our ability to provide you access to our Services (in whole or in part) may be affected.

Please be informed that this Privacy Policy does not apply to any third-party websites you may access from our Website or through your use of our Services (if applicable). To determine how the operators of those websites deal with your Personal Data, please ensure that you read their respective privacy policies.

2. SOURCES OF PERSONAL DATA

During your use of our Website and/or our Services, we may collect Personal Data in a few ways, from a few sources, either from you, your authorised representatives, employers, third parties, publicly available sources or through the use of technologies, which may include (but is not limited to):

(a) when you sign up to our Services or create an Account on the Website;

(b) when you use our Services;

(c) when you participate in any surveys and questionnaires, done by us or via an appointed third party;

(d) when you contact us or interact with our AI chatbot assistance;

(e) when you visit or browse our Website;

(f) when we collect information about you from third parties we dealt with or are connected with you;

(g) through the use of technologies such as internet Cookies or sessions; and/or

(h) from such other sources where you have given your consent for the disclosure of Personal Data relating to you, and/or where otherwise lawfully permitted.

When you access our Website, your device sends information which may include Personal Data and we may track, collect, and aggregate information indicating, among other things, your device’s IP Address, type and characteristic of the mobile device, through the use of Cookies or similar technologies; and which pages of the Website were visited, the order in which they were visited, when they were visited, which hyperlinks were clicked and the URLs from which you linked to our Website.

3. USE OF PERSONAL DATA

We use your Personal Data principally to provide to you or offer to you access to our Website and/or our Services. We would also use your Personal Data for purposes such as to assess any request that you submit to us. Any of the Personal Data we collect from you may be used in any of the following ways:

(a) to comply with any legal or regulatory obligations under the applicable laws, regulations, guidelines or industry codes that apply to us;

(b) to verify your identity;

(c) to manage, maintain and update your Account with us;

(d) to allow you to use the Services, the Website and all of its available functionalities;

(e) to investigate and resolve any service issues, complaints or other enquiries that you submit to us regarding our Website or Services;

(f) to improve our Services (we continually strive to improve our service offerings based on the information and feedback we receive from you);

(g) to improve customer service (your information helps us to more effectively respond to your customer service requests and support needs);

(h) to send periodic emails or to communicate with you in relation to our Services or for marketing and commercial purposes;

(i) for internal management of the Services provided to you;

(j) to produce data, reports and statistics which shall be anonymised or aggregated in a manner that does not identify you as an individual;

(k) to communicate with you by responding to your requests, comments and questions;

(l) for billing, Account management and other administrative matters;

(m) to conduct research for analytical purposes including but not limited to data mining and analysis of your transactions with us (if any); and

(n) to maintain records required for security, claims or other legal purposes.

By submitting your email address for the purpose of Account creation on our Website, you agree to receive emails from us, including for direct marketing purposes. We only send emails to people who have authorized us to contact them, either directly, or through a third party. If you have provided the same email to us through another method (i.e., through answering of surveys and questionnaires), we may use it for any of the other purposes stated in this Privacy Policy.

4. YOUR RIGHTS TO YOUR PERSONAL DATA

4.1 Updating your Personal Data

It is important that the Personal Data that you provide to us is accurate, current and complete and that you do not submit any information to us which is inaccurate or misleading in order for us to provide our Services effectively. In the event you believe that your Personal Data as provided to us are inaccurate and out of date, you are responsible for informing us of such changes. If there has been any change in your Personal Data, we encourage you to keep us informed of any such change. Additional information from you may be needed to verify your identity before making any such correction. Please note that it may take some time for any change to your personal data to be reflected in our system.

4.2 Request to access data and portability

If you wish to request for a copy of all of your Personal Data provided to us, you can do so by sending an email to our data protection officer of your intention and we shall provide you the Personal Data in a structured, commonly used and machine-readable format. You may also request portability of your Personal Data and we shall assist to transmit the Personal Data to another data user as requested.

4.3 Withdrawing or limiting your consent on processing of Personal Data

If you wish for us to cease collecting, using, disclosing or process your Personal Data (whether in whole or in part) rightfully in our possession or control, you may withdraw your consent by submitting a written request via email to our data protection officer of your intention. Please note that it may take some time for any request to be fully processed, during that time we may still use, disclose or process your Personal Data. You may also request that our processing of your Personal Data be limited such that (i) we only process your Personal Data for some but not all of the purposes mentioned; (ii) we only process some but not all of your Personal Data for the purposes mentioned; (iii) a combination of (i) and (ii); or (iv) any form of limitation of our processing of your Personal Data in any way. Note that, depending on the nature of the consent withdrawal or limitation, we may not be able to continue to provide or assist you with some or all of the features that we customarily provide. Upon the receipt of your request, we will process within a reasonable time and once the processing is complete, we will no longer collect, use, disclose or process your Personal Data, except to the extent that we retain your Personal Data for compliance, regulatory or other legal purposes.

4.4 Account privacy and security

To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections or changes to your Personal Data processing preference. You are responsible for maintaining the secrecy of your unique password and account information at all times. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate.

Promptly after receiving your request, all Personal Data stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable, but in any event within the period allowed under applicable laws. Please note that it may take some time for any change to your Personal Data or the processing thereof to be reflected in our system and during that time, you might still receive communications from us or your Personal Data may still continue to be processed by us.

Such updates, corrections, changes and deletions will have no effect on other Personal Data that we maintain which are not the subject of the request.

5. DISCLOSURE OF PERSONAL DATA

We may engage trusted third-party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and our Services, providing data for us to analyse, and providing content or data for the Website in relation to your use of the Services. We will share your Personal Data with these third-party service providers to enable them to perform these services for us and for you. We may share portions of our log file data, including your IP Addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP Address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the Website or use the Services in a shared location, and the type of device used to visit our Website or use our Services. They may aggregate information about our advertising and what you see on our Website and then provide auditing, research and reporting for us and/or our advertisers (if any).

We may also disclose Personal Data about you to the government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

Given that the source of the information and data through which we are providing the Services come from our Partners, we will also share your Personal Data with our Partners, pursuant to our contractual obligations in relation to the creation of your Account on our Website or the access to our Services. Any Personal Data relating to you that we provide to third parties and/or our Partners will be treated by those third parties and/or our Partners in accordance with the terms of this Privacy Policy.

The disclosure of your Personal Data may also involve the transfer of your Personal Data between different countries or geographic locations. When we transfer your Personal Data to another country or location, we will comply with our legal and regulatory obligations in relation to your Personal Data for such transfer and adopt appropriate safeguards in place to ensure an adequate level of protection including ensuring the new recipient of the Personal Data is obliged to protect your Personal Data in accordance with any Privacy Laws.

6. SECURITY OF PERSONAL DATA

In managing your Personal Data, we will put in place all necessary security arrangements to ensure that your Personal Data is adequately protected and this includes any reasonable measures to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage or alteration of your Personal Data. In the event of a personal data breach involving your information, we will promptly notify both you and the Personal Data Protection Commissioner, ensuring compliance with regulatory obligations ad take immediate steps to protect your information. However, we will not be responsible for any unauthorised use of Personal Data by third parties which are attributable to factors beyond our control.

We keep your Personal Data only so long as we need it to provide the Services to you and fulfil the purposes described in this Privacy Policy. This is also the case for anyone that we share your information with and who carries out the Services on our behalf. Your Personal Data will be retained for as long as we are either required to by any applicable laws or as is relevant for the purposes for which it was collected. Once your Personal Data is no longer necessary for the purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Privacy Policy, or for purposes of safety, security, fraud prevention and detection in accordance with the requirements of any applicable law. Therefore, while we use reasonable efforts to protect Personal Data, we cannot guarantee its absolute security.

7. COLLECTION OF COOKIES DATA

We and/or our Partners may use Cookies to collect and store information about your device and access to our Website or use of our Services. You can find more information about Cookies and similar technologies at www.aboutcookies.org.

When you visit our Website through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website, such as the technical data and usage data. There will be a banner informing you regarding the use of Cookies on our website. If you don’t make a choice in the banner, only strictly necessary Cookies will be deployed, but the banner will re- appear every time you visit our website. This data is collected for analysis and evaluation in order to help us improve our Website and our Services, as well as to help us to personalise the content to match your preferred interests more quickly. The data is also collected to make providing our Services and accessing our Website more convenient and useful to you.

We use cookies, web beacons and similar tracking technologies for the purposes below, if without these Cookies, our Website is unlikely to work as you would expect and certain services that you may ask for cannot be provided. Currently, we deploy and use (a) Strictly necessary Cookies, which are necessary for our website or service to function as you reasonably expect, such as maintaining your current login status; (b) Functional Cookies, which are used to record your login status; or (c) Security Cookies, which are used to protect your account and password security. We do not use Cookies for any purpose other than those stated here and the Cookies deployed, collected and used by us have a duration of up to seven (7) days.

The Cookies collected will only be available to us and our Partners, and the data collected by Cookies is stored in the servers owned or controlled by us. You have the right to choose whether or not to accept Cookies, you may manage and delete Cookies through your browser settings. If you wish to withdraw your consent at any time, you will need to delete your Cookies using your internet browser settings. Most devices and browsers allow you to change your Cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser or devices. However, certain Cookies are required to enable core functionality. As such, please note that rejecting or blocking Cookies may affect the functions available on our website.

If you have any questions about the Cookies settings or if you want to make a suggestion or complaint, you can contact our data protection officer.

8. MINORS’ PRIVACY

We do not provide our Services to anyone under the age of 18. We do not knowingly collect Personal Data from anyone under the age of 18. By using our Services, you undertake that you are at least 18 years old.

9. CHANGES TO THIS PRIVACY POLICY

We may update and change this Privacy Policy from time to time, as may be required by laws, regulations and/or industry standards, or to suit our Services or business needs. In this regard, we reserve the right to amend the terms of this Privacy Policy at our absolute discretion. If we decide to change our Privacy Policy, we will publish a notification on our Website, post those changes on this page and encourage you to review our Privacy Policy from time to time to stay informed. Effective date of the changes will be specified accordingly. If you disagree with the changes to this Privacy Policy, you may deactivate your Account and refrain from using the Services and the Website.

10. CONTACTING THE DATA PROTECTION OFFICER

If you have any questions relating to your Personal Data or about this Privacy Policy, or you have any complaints regarding collection, storage, use, management and/or processing of your Personal Data by us, or you wish to report any unauthorised breach or violation of any terms in this Privacy Policy, or you wish to exercise any of your rights under Privacy Laws, you may contact our data protection officer at:

Name: Nasimah Binti Mohd Zain Designation: Data Protection Officer

Address: B03-C-12-1, Menara 3A, No. 3, Jalan Bangsar, KL Eco City, 59200 Kuala Lumpur Contact No.: +603 2201 7188

E-mail Address: dataprotection@infomina ai.co

Emails and letters should clearly state that you are making a data protection query, request or complaint in the subject line to ensure that matter is brought to our attention for our swift response. Every complaint, query and request will be dealt with promptly and fairly.

11. CONFLICT

In the event of any conflict or inconsistency between the English version and the Bahasa Malaysia version of this Privacy Policy, the English version shall prevail.