SVARATNA PRIVACY POLICY
1.0 INTRODUCTION
1.1 PICC E-Commerce Sdn. Bhd. welcomes clients and customers to the Svaratna platform. Svaratna is committed to respecting the privacy rights and concerns of all Users of our platform and mobile application (the "Platform"). The services we provide on our Platform is, henceforth, referred to as the "Services".
1.2 “Users” refers to a user who registers and opens an account with us for use of the Services, including both buyers and sellers.
1.3 The personal data you have provided to us is our responsibility to properly manage, protect and process. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and process the personal data you have provided to us.
1.4 "Personal Data" means data about an individual who can be identified from that data. Common examples of personal data include name, identification number and contact information.
1.5 The use of the Services and visit to our Platform is an indication of your acknowledgement and agreement that you are aware of and accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby agree to us collecting, using, disclosing and/or processing your personal data.
1.6 If there are any changes to our Privacy Policy, we shall notify you by posting those changes on our Platform. Continued use of our Services shall be interpreted as your acknowledgment and acceptance of the changes made to this Privacy Policy.
1.7 This Policy is applicable together with other notices, contractual clauses and consent clauses that apply in relation to the collection, use, disclosure and/or processing of your personal data by us.
1.8 This Policy applies to both buyers and sellers who use the Services except where expressly stated otherwise.
2.0 COLLECTION OF PERSONAL DATA
2.1 We shall or may collect personal data about you when you:
i. register and/or use our Services or Platform, or open an account with us;
ii. submit any documents related to any of our products and services, whether online or hard copy;
iii. interact with us via telephone calls, letters, face-to-face meetings, social media platforms and emails;
iv. use our electronic services, or interact with us via our application or use Services on our Platform;
v. grant permission on your device to share information with our application or Platform;
vi. link your Svaratna account with your social media or other external account;
vii. carry out transactions through our Services;
viii. provide us with feedback or complaints;
ix. register for a contest; or
2.2 You agree not to submit any inaccurate or misleading information to us, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right to request for additional documents to verify the information provided by you.
3.0 TYPES OF PERSONAL DATA COLLECTED
3.1 The personal data that Svaratna may collect includes the following:
i. name;
ii. email address;
iii. date of birth;
iv. billing and/or delivery address;
v. bank account and payment information;
vi. telephone number;
vii. gender;
viii. information sent by the device(s) used to access our Services or Platform;
ix. information about your network and the people and accounts you interact with;
x. photographs or audio or video recordings; and
xi. Government-issued identification or other information required for our due diligence, identity verification, or fraud prevention purposes;
3.2 Users have the option to allow or not the collection of your personal information and data at any time by notifying Svaratna in writing. However, you have to bear in mind that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services and the Platform.
4.0 USAGE OF PERSONAL INFORMATION PROVIDED TO US
4.1 We may use your personal data for one or more of the following purposes:
i. to enforce our Terms of Service or any applicable end user license agreements;
ii. to protect personal safety and the rights, property or safety of others;
iii. for identification, verification, due diligence, or know our customer purposes;
iv. to evaluate and make decisions relating to your credit and risk profile and eligibility for credit products;
v. to deal with or facilitate customer service, carry out your instructions, deal with or respond to any
enquiries given by you or on your behalf;
vi. to contact you or communicate with you for the purposes of administering and/or managing your
relationship with us or your use of our Services;
vii. to allow other users to interact, connect with you;
viii.to conduct research, analysis and development activities to analyse how you use our Services, to
recommend products and/or services relevant to your interests, to improve our Services or products
and/or to enhance your customer experience;
ix. to allow for audits and surveys to validate the size and composition of our target audience, and
understand their experience with Svaratna’s Services;
x. for marketing and advertising i.e. to send you by various mediums and modes of communication
marketing and promotional information and materials relating to products and/or services;
xi. to respond to legal processes or to comply with or as required by any applicable law, governmental or
regulatory requirements of any relevant jurisdiction or where we have a good faith belief that such
disclosure is necessary;
xii. to produce statistics and research for internal and statutory reporting and/or record-keeping
requirements;
xiii. to audit our Services or Svaratna's business;
xiv. to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
xv. to respond to any threatened or actual claims asserted against Svaratna or other claim that any Content violates the rights of third parties; and/or
xvi. any other purposes which we notify you of at the time of obtaining your consent.
4.2 You agree that Svaratna may disclose your Account information and Content if required to do so by law, by an order of a court or by any governmental or regulatory authority having jurisdiction over Svaratna.
5.0 COLLECTION OF OTHER DATA
5.1 Some form of information may be collected through your device i.e. when your interaction with us, your device will send information such as
a. your device’s Internet Protocol (IP) address;
b. type and characteristics of mobile device;
c. the location of your mobile device
d. the address of a referring web site;
e. the pages you visit on our website;
f. the content and advertisement viewed;
g. marketing and communications data, such as your preferences in receiving marketing material from us and third parties, your communication preferences and history of communications with us;
h. usage and transaction data, including type and number of orders; and
i. mobile applications.
These information gets logged by a web server when you browse our Platform and it allows us to understand how visitors use our site. These information will help us to improve our Platform and the Services, help us to provide new services and features, and enable us and our advertising partners to serve more relevant content to you.
6.0 PROTECTION AND RETENTION OF CUSTOMER INFORMATION
6.1 We do implement a variety of security measures to maintain the safety of your personal data that is in our possession. Users’ personal data is kept behind secured networks and is only accessible by a limited number of staff who have special access rights to such systems and are required to keep the personal data confidential. However, we have to remind you that there can be no guarantee of absolute security.
6.2 We shall destroy your personal data when we have reasonably determined that the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and no other legitimate interests warrant further retention of such personal data.
6.3 If you cease using the Platform, or your permission to use the Platform and/or the Services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.
7.0 DISCLOSURE OF THE INFORMATION COLLECTED TO OUTSIDE PARTIES
7.1 In conducting our business, we shall or may need to disclose your personal data to other stakeholders, such as our third party service providers, and/or our affiliates, which may be located in Malaysia or outside of Malaysia, for one or more of the purposes stated in Section 4.0 and 5.0. It is our responsibility to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access.
7.2 We shall deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws. However, there can be no guarantee of absolute security when unauthorised disclosure arises from malicious and sophisticated hacking by external elements through no fault of ours.
7.3 Videos from YouTube can be shared in the Svaratna platform and by sharing YouTube Content, you hereby agree to be bound by the Google Privacy Policy (http://www.google.com/policies/privacy).
7.4 Sellers (including any staff, agents, representatives, or any other person acting for such Seller) shall comply with all applicable Privacy Laws and, in respect of any Buyer’s personal data received from Svaratna i.e. they
a. are not permitted to use nor disclose to any unauthorized third parties such Buyer’s personal data, without the Buyers’ and Svaratna’s prior written consent, except as reasonably necessary to respond to Buyers’ enquiries and to deal with or complete a transaction;
b. should refrain from contacting Buyers using such information outside of the Svaratna platform;
c. shall ensure sufficient security measures are in place to protect each Svaratna User’s personal data in their possession, retain such data only for as long as necessary for the purposes above and in
d. accordance with the Privacy Laws; and
e. to inform Svaratna’s Personal Data Protection Officer in the event of any potential data breach or other loss of such user’s data.
8.0 INFORMATION ON CHILDREN
8.1 Children under the age of 15 are prohibited to use our Services. We advise parents and legal guardians not to allow such children under your care to submit their personal data to Svaratna.
9.0 WITHDRAWAL OF CONSENT, REQUEST ACCESS TO OR CORRECT INFORMATION YOU HAVE PROVIDED TO US
9.1 Withdrawing Consent
You may withdraw your consent for the collection and use of your personal data in our possession by sending an email to our Personal Data Protection Officer, and we shall process such requests in accordance with this Privacy Policy and our obligations under the Privacy Laws and other applicable law. However, you have to bear in mind that your withdrawal of consent may mean that you will not be able to enjoy the Services and we may need to terminate your existing relationship and/or the contract you have with us.
9.2 Requesting Access to or Correction of Personal Data
If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page on the Platform.
10.0 QUESTIONS, CONCERNS OR COMPLAINTS
If you have any questions or concerns about our privacy practices, Users can contact us by e-mail at user@svaratna.com.