You will find the following information in this privacy notice:
- Who we are
- Information you explicitly provide to us
- Information collected automatically
- How we use your information
- User generated content
- Who can see your information
- When we share your information
- How we look after your information
- How long we keep it for
- Your rights and choices
- Collecting information from children
- Consent for processing
- Access and security
- External links
- Contact information
WHO WE ARE:
Luxury Richways Sdn Bhd is registered in the Malaysia.
INFORMATION YOU EXPLICITLY PROVIDE TO US:
From time to time we may offer promotions, contests or sweepstakes on our site. If you choose to participate we may collect information including your name, address, age, telephone number, email address or other contact information. We would use this information to notify contest winners, award prizes, monitor site traffic, personalize the site (in the case of anonymous information collected in surveys) and to send participants an email newsletter. We may also request other information some of which may be optional. We may use a third party service provider to conduct these surveys or contests; that company may not be prohibited from using our users’ personally identifiable information for any other purpose. Participation is subject to the Official Rules governing that promotion and we encourage you to read such Rules carefully.
INFORMATION COLLECTED AUTOMATICALLY:
(i) Server Statistics.
Like many Web sites, we automatically collect general statistics about our Website traffic and store it in log files in order to track usage and user trends on our site. This information includes hits to our server, browser type, Internet service provider (ISP), page views, navigational patterns, operating system, date/time stamp, clickstream data and the numbers and frequency of visitors to our site. We use this information, which does not identify individual users, to analyze trends, to administer the Website, to track users’ movements around the Website so that we can communicate with our users in the most effective manner and provide them the most useful and desired features, functionality, products and services. In connection with this analysis, Tenang also uses devices called “web beacons” to help us identify when emails sent to you from us have been received and read. We may also collect IP addresses and other information in order to prevent the introduction of viruses and hackers into the Site.
When we collect this usage data, we typically only use this data in aggregate form, and not in a manner that would identify you personally. When IP addresses are tied to personally identifiable information it is to offer customers the best user experience possible. We may also provide this data in aggregate form to partners, Artists and Institutions so that they can understand how often users are seeing their pages and buying their products on our Site.
Tenang uses “session” or temporary cookies to ensure that you are recognized when you move from page to page on the site and that any information you enter on the Site (for example, items in your shopping cart) are not lost as you navigate the site. We also use persistent cookies so we can remember you on subsequent visits to our Site, which enables us to provide a more enhanced, efficient and personal experience when you return to our Site. We do not link the information we store in cookies to any personally identifiable information you submit while on our Site.
If you do not want to have cookies placed on your computer, you can set your browser to refuse or remove cookies by following the instructions in your browser’s “help” file. However, doing so will limit system performance, may not allow you to take advantage of certain features on our Site and even cause certain features of the Site to malfunction.
We may permit limited third parties to place cookies through the Site to provide us with better insights into the use of the Site, user demographics, or to provide relevant advertising to you. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our Site.
We do not use technology that recognizes do-not-track signals from your web browser.
HOW WE USE YOUR INFORMATION:
- i) We may share your information with selected vendors and business partners with whom we work (“Service Providers”). These Service Providers provide functions on our behalf such as fulfillment, shipping, credit card processing, data and tracking analysis, customer service, market services etc in order to complete the transactions and offer you the best service our Site.
- ii) We may use your personal and transactional information internally for our business purposes, including among other things, to offer our own, our affiliates’ or third-party products and services that we think you may find of interest. We may use your email address to contact you to respond to your customer service inquiries. You can elect not to receive emails from by unsubscribing to our emails or by contacting us as indicated below.
iii) As noted above, we may provide aggregate statistics, which do not include Personal Information, about our customers, sales, traffic patterns and related Site information to reputable third party vendors. We sometimes use this aggregated data (such as what areas of our Site are visited most frequently, what services are most used, what products are most popular and how often our emails are opened etc.) for research and commercial purposes. This information helps us develop a better site that is more useful and accessible to you as well as offer better products and services to you but is never associated with any Personally identifiable information.
USER GENERATED CONTENT:
You may choose to participate in areas of our Site dedicated to user-generated content that we provide you to enjoy. By “User Content” we mean any content you post to the site, which may include reviews, comments, image uploading, captions, participating in forums, curating or creating art collections and other such features that allow you to add content to the site. Any User Content you voluntarily disclose for other users to view on the Site is not Personal Information. It becomes publicly available information and can be read, collected, redistributed or used by any person for any purpose. We are not responsible for the personally identifiable or other information you choose to submit as User Content and we reserve the right to remove any User Content generated by any user at our sole discretion.
WHO CAN SEE YOUR INFORMATION:
Our staff or the staff of third party service providers may process your information on our behalf. Processing can mean any activity that involves the use of information about someone that can identify them. All uses of your information – for example, obtaining, recording, storing, disclosing, organizing, retrieving, deleting and destroying – are types of data processing.
We take measures to ensure that third parties who process your information on our behalf are acting lawfully in accordance with our instructions and are subject to appropriate confidentiality requirements. We also have adequate technical and organizational safeguards in our company and with third party processors to protect your information. Third party processors of your information include: • our website hosts and operators, IT support providers, database operators, site analytics providers and software developers; • our marketing or publicity services providers; • our editorial and production service providers;• our financial services and payment service provider; • our warehousing and delivery service providers; • our auditors, technical consultants and legal advisors; and • our fraud detection services.
WHEN WE SHARE YOUR INFORMATION:
We share your information within the companies that make up the Tenang group of companies. Where we share your information outside our group of companies, you will be asked to consent to a third party sharing your information and if you choose to give your permission any interaction you have with a third party is governed by their privacy terms. The third party becomes a joint data controller of your information with us. This means that the third party can make decisions about how to use your information. Before we share your information, we require third parties to enter into a data sharing agreement, which stipulates that they must maintain appropriate security to protect your information from unauthorized access, processing or use. We will share your information with the following third parties: • selected marketing partners; • any prospective seller or buyer of businesses or assets, only if we decide to acquire, transfer or sell any business or assets; • any other third parties (including legal or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law or where we have a legal obligation to do so.
HOW WE LOOK AFTER YOUR INFORMATION:
We look for opportunities to minimize the amount of personal information we hold about you. Where appropriate we anonymize and pseudonymize your information. We use appropriate technological and operational security measures to protect your information against any unauthorized access or unlawful use, such as: • ensuring the physical security of our offices, warehouses or other sites; • ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption; • maintaining a data protection policy for, and delivering data protection training to, our employees; and • limiting access to your personal information to those in our company who need to use it in the course of their work.
HOW LONG WE KEEP IT FOR:
We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our legitimate interests. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it.
For example: • we archive our email and paper correspondence regularly and destroy unnecessary information; • we operate a best practice email retention policy requiring password protected folders and departmental shared drives to provide restricted access to information; • we auto-delete emails periodically; • we conduct regular access reviews to keep access profiles and policies up to date; • we conduct periodic review and purge cycles of documents in accordance with our document retention policy; • we retain information relating to orders, refunds and customer queries for approximately 7 years; • we retain information relating to commercial contracts for approximately 7 years after expiration or termination whichever is the sooner; • we maintain a suppression list of email addresses of individuals who no longer wish to be contacted by us. So that we can comply with their wishes we must store this information permanently; • we delete information collected through marketing channels 2 years after our last interaction with you; • we destroy CVs and related information from job applicants who have not been shortlisted for interview once the recruitment process is complete.
INTERNATIONAL TRANSFER OF YOUR INFORMATION.
Our company is located in the Malaysia. Whenever we transfer your personal information out of the European Economic Area (EEA), we will take all steps necessary to ensure that it is adequately protected and processed in accordance with this Privacy Notice by using all appropriate cross-border transfer safeguards such as: • by entering into the European Commission’s Standard Contractual Clauses with the provider which give personal data the same protection it has in the EEA; and • where the provider is in the US, the EU-US Privacy Shield if the provider is part of the EU-US Privacy Shield Framework. Please contact us if you would like additional information on the specific means used by us when transferring your personal data outside of the EEA.
YOUR RIGHTS AND CHOICES:
Your Right to Object – you can object to us using your information for direct marketing and on the basis of our legitimate interests (refer to section ‘How we use your information’ above to see when we are relying on our legitimate interests). If you want to do this, you can contact us using the details in the section ‘Who we are’.
Your Right to Withdraw Consent – you can withdraw your consent for us using your information in reliance of your consent (refer to section ‘How we use your information’ to see when we are relying on your consent). You can do this by contacting us using any of the details in the section ‘Who we are’.
Your Other Rights and Choices – in addition, you can also: • request access to the information that we hold about you to check that we are acting lawfully; • receive a copy of any information we hold about you in a format of your choice; • request that we transfer your information to another service provider in a structured, commonly used, machine-readable format; • ask us to correct information we hold about you if it is inaccurate or incomplete; • ask us, in certain circumstances, to delete information we hold about you; • ask us, in certain circumstances, to restrict processing of your information. You may exercise your rights and choices by contacting us using the details above in the ‘Who We Are’ section. You can also prevent processing for marketing activities by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing.
Your Right to Complain – if you have any questions or are unhappy about the way we have used your information, please contact us using the details above in the ‘Who We Are’ section. We hope we will be able to resolve any problems or issues you may have. You can also have lodge a complaint about us and our use of your information to the relevant authority in your country of work or residence.
COLLECTING INFORMATION FROM CHILDREN:
This Site is not designed nor intended to be attractive to use by children under the age of 18 (“Minors”). We do not knowingly collect information from Minors. If you are under the age of 18, you are not authorized to use this site so please do not submit any information to us.
CONSENT TO PROCESSING:
Your Personal Information may be processed by us in the country where it was collected as well as other countries, including the Malaysia, where laws regarding data protection may be less stringent than the laws in your country. By using this site and by providing any Personal Information to the Site, all users, including without limitation users in Canada and the European Union, fully understand and unambiguously consent to the collection and processing of such information in the Malaysia.
ACCESS AND SECURITY:
If you are a registered user of this Site, you are responsible for maintaining the confidentiality of your account and password. If you use this Site, you are responsible for restricting access to your computer, and you agree to accept responsibility for all activities that occur under your account or password. You agree to notify us immediately of any unauthorized use of your account or any other breach of security. We reserve the right to refuse service, terminate accounts, or remove or edit content in our sole discretion.
We use reasonable physical, electronic, and administrative safeguards to help us protect the security, integrity and confidentiality of data stored on our system. The Site encrypts your credit card number and other Personal Information using secure socket layer (SSL) technology to provide for the secure transmission of the information from your PC to our servers. SSL is an industry-standard protocol for encryption over the Internet. While no system is 100% secure, we believe that the measures we have implemented minimize the risk of security breach to an appropriate level given the types of information involved. Please note that any information you provide us by email is unencrypted.
We may offer links to the websites of other companies but we are not responsible for the privacy practices of any third parties or the content of linked sites, nor are we responsible for how these other companies collect, use, disclose or secure the information you provide them. If you choose to access a third party website linked to or from our Site, you do so at your own risk. We do encourage you to read the applicable privacy policies and terms and conditions of such parties or web sites.