What is Personal Information?
a. Name, home address, business address, date of birth, age, gender, nationality, citizenship, race, religion, identity records (including National Registration Identity Card or passport details), spoken language, telephone number, fax number, phone numbers, e-mail address, employer’s, name, address and contact details, and job title;
b. Credit card or debit card or banking details;
c. Details or usage or analytics of the usage (for example including but not limited to the sent or received, amount of data, IP addresses, transmission details, details of the hardware used, the time of use, duration of use, clickstream data of pages browsed, personal settings, interest and preferences), of the subscribed, Services or third party services;
d. Details or usage or analytics of the usage of mobile devices (for example including but not limited to the mobile device’s unique identifier and the location) if used to access the subscribed, Services or third party services;
e. CCTV recordings of Your visits at any of our branches;
f. Recordings of Your phone calls to Us (at Our help desk or at any of Our other contacts).
1. OUR COMMITMENT TO YOU
2. DEFINING PERSONAL INFORMATION
3. PERSONAL INFORMATION WE COLLECT
3.1. In order for TITAN to provide you with the best possible Products and/or Services and to operate in an effective and efficient manner, we need to collect relevant personal information from you. The personal information collected by us is not limited to but may include the following:
• Contact information such as current private and/or business address, fax number, telephone or mobile phone number, email address and physical address.
• Sensitive information such as your date of birth, full name, identification supporting documents (including NRIC or passport number), nationality, gender and race.
• Payment information such as your credit card information, including the name of cardholder, billing address, card number, expiry date and other bank account details.
• Usage of the Products and/or Service (for example the website that you are hosting and/or emails you send out or receive).
• Recording of calls placed by you to our help desk, LiveChat chats you have had with our operators and/or Tickets you have placed for our service improvement and enhancement.
• The status of the Products and/or Services you have acquired from us.
3.2. Although no personal data is revealed to us, for general web browsing certain statistical and technical information is available to us via our internet service provider such as your IP address, cookies, time, duration and date of your visit.
We collect information about your use of our websites from cookies. Cookies refers to electronic packets of information stored on your computer and used by websites to keep track of registered users and visitors, and this is one of the methods of uniquely tracking visitors for different purposes. You are not obliged to accept cookies. If you have concerns about the cookies, you can change your browser setting either to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time. However, you should note that rejection of cookies may affect your use of our website and you will not be able to take advantage of all the features presented on our website.
TITAN may also utilise “advertising cookies” to track visits from advertising campaigns. Cookies and pixel tags may be used in our website to measure the effectiveness of our advertising activities. Please note that we may be utilizing a third-party service to send you emails that you have agreed to receive. These emails contain special tracking that helps us provide more focused marketing communications accustom to your needs.
4. HOW WE COLLECT PERSONAL INFORMATION
We may collect personal information directly from you, from your authorised representatives or from publicly available sources:
• When you communicate with us (for example when you submit a contact form on our website, or when you contact us for any enquiries by phone, LiveChat or ticketing system).
• When you participate in any competitions, contests or loyalty programs run/organised by us.
• When you register an account on our website.
• When you participate in any of our surveys.
• When you subscribe to a specific Product and/or Service on our website.
• When you commence a business relationship with us (for example, as a business partner/service provider)
• When you visit or browse our websites.
• When you lodge a complaint with us.
• When you visit any of our offices.
• When you provide feedback to us.
• When you interact with us via social media or interactive applications including but not limited to Twitter, Facebook and Instagram.
Other than personal information obtained from you directly (as detailed above), we may also obtain your personal information from third parties we deal with. We may also collect information from such other sources where it is lawfully permitted and/or in circumstances where you have given your consent for the disclosure of personal data relating to you.
5. USE OF PERSONAL INFORMATION
• To verify your identity.
• To comply with any legal or regulatory obligations under the applicable laws, regulations, guidelines or industry codes that applies to us.
• To administer and manage the Products and/or Services we provide you (including billing, charging, facilitating payments and collecting debts).
• To process and access your application(s) /request(s) for our Products and/or Services.
• To provide you with the Products and/or Services you have requested.
• To resolve and investigate any service issues, complaints, billing queries or other enquiries that you submit to us regarding our network, Products and Services.
• To detect and prevent fraudulent activity.
• To assess and/or verify credit worthiness.
• To engage in business transactions in respect of Products and/or Services to be offered and provided to you.
• To establish and better manage any business relationship we may have with you.
• To help us improve and monitor the performance of our Products and Services, our website and our customer service teams.
• To develop and maintain our business systems and infrastructure, including testing and upgrading of these systems.
• To manage staff training and quality assurance.
• To notify you about changes and benefits to the features of our Products and/or Services.
• To produce data, statistics and reports which shall be anonymised or aggregated in a manner that does not identify you as an individual.
• To analyse statistical data from website and advertisement analytics.
• To conduct marketing activities (for example, market research).
• To respond to, investigate or defend claims made against or involving TITAN.
• To maintain records required for claims, security or other legal purposes.
• For any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities.
6. DISCLOSURE OF PERSONAL INFORMATION
We assure you that TITAN will not sell or provide your personal information to any third party and will keep all information confidential. However, we may be required to disclose information about you to the following third parties:
• Companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions and providing you with Products and/or Services that you have requested or subscribed for.
• Companies and/or organisations that act as our agents, contractors, service providers and/or professional advisers.
• Our business associates and other parties for purposes that are related to the purpose of collecting and using your personal information.
• Our merchants and/or strategic partners that provide Products and/or Services which require personal information disclosure.
• Government agencies.
• Law enforcement agencies.
• Any credit reporting agencies or in the event of default, any debt collection agencies subject to the permitted law applicable to us.
• Other parties in respect of whom you have given your express or implied consent.
7. INCOMPLETE PERSONAL INFORMATION
Where indicated (for example in registration/application forms), it is obligatory to provide your personal information to us to enable us to process your application for our Products and/or Services. Should you decline to provide such obligatory personal information, we may not be able to process your application or provide you with our Products and/or Services.
8. YOUR OPTIONS
8.1. If you are of the opinion that your personal information held by us is incomplete, misleading, inaccurate, not relevant or not up-to-date, you may make a request to us by emailing to [email protected] You should quote your name, phone/account number and address and provide brief details of the information you want to correct.
8.2. Please note that we may have to withhold access to your personal information in certain situations, for example when information requested for is of a confidential commercial nature or when we are unable to confirm your identity or where we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.
8.3. We take reasonable steps to ensure that our agreements with our merchants and/or strategic partners include appropriate confidentiality and privacy obligations. If you do not wish your personal information to be utilised for the purposes of marketing or should you change your mind in relation to your previous decision, please contact us at [email protected]
8.4. When you create an account in TITAN, you are automatically subscribed to receive email newsletters, transactional notices and news of special promotions offered by TITAN. You may press the links provided in promotional email messages sent to you or contact our support to unsubscribe from our newsletters and promotional mailings.
9. YOUR OBLIGATIONS
9.1. You are responsible for providing accurate, complete and updated information to us about yourself. This obligation is a condition to the provision of our Products and/or Services to you and/or any other person authorised or permitted by you or your organisation/company to use the Products and/or Services.
10. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We will retain your personal information in compliance with this Policy and/or the terms and conditions of your agreement(s) with TITAN for the purpose to protect the interests of TITAN and/or its customers. TITAN retains personal information for as long as necessary to fulfil the stated purposes and reserve the right to keep your personal information when it is required by the law and/or by TITAN’s relevant policies. In accordance with established policies and procedures, TITAN will periodically destroy or erase any personal information that is no longer needed.
11. TRANSFER OF DATA OUTSIDE MALAYSIA
It is pertinent to note that the PDPA does not permit transferring of any personal data to a place outside Malaysia unless such a place specified by the Minister and published in the Gazette. There are certain circumstances specified in the PDPA where personal data can be transferred out of Malaysia, such as when you have given consent to us when the transfer is necessary for the performance of a contract between contracting parties and/or for the purposes of legal proceedings and/or for the purposes of obtaining legal advice.
13. OUR CONTACT DETAILS
TITAN SYSTEM INTEGRATION SDN BHD
D-3A-02 Capital 4, Oasis Square, No. 2 Jalan PJU 1A/7A, Ara Damansara, 47301 Petaling Jaya, Selangor.
Tel: (+6) 03-7890 2828 Fax: 03- 7890 2827 E-mail: [email protected]