Privacy Policy

PERSONAL DATA PROTECTION NOTICE (PRIVACY NOTICE)

This privacy notice explains how we, SIRCLEHUB SDN BHD (Company No. 1284081-T) and/or its related companies, as defined in section 7 of the Companies Act 2016 (“us”, “we”, “our”, “Company”) process your personal data which is subject to the Personal Data Protection Act 2010 (Act 709) of Malaysia, as amended or re-enacted from time to time (“the Act”).

Please note that emphasis is placed on the inclusion of the additional notice, as outlined in Clause 8 (Processing Personal Data In Video, Image, Livestream or Other Multimedia Created), which shall be applicable to you if you sign or acknowledge the consent form provided by the Company or agree to the terms in any other manners to provide the consent for that purpose. These shall not prejudice to the validity of any other clauses and terms in the Privacy Notice. You are entitled to exercise the rights stated below if you are not agreeable to any of the terms which have been and will be revised from time to time.

If you are aged under 18 or the relevant age of majority where you live, it is required for your guardian or parent to agree to the disclosure of your personal data and agree to relevant terms in this Privacy Notice.

“Process” or “Processing” in relation to personal data means collecting, recording, holding or storing, uploading, displaying, publishing, advertising the personal data or carrying out any operation or set of operations on the personal data.

1. Collection of Personal Data

We collect your personal data which includes but is not limited to:

Your name, identity card number, contact details, date of birth, gender, marital status, nationality, preferred language, occupation, voice, physical appearance, monthly income and financial information and any other identifiable information;
The current company that you work for (applicable to our employees);
The location of my employment (applicable to the our employees);
The location and/or seller information associated with your purchases, in and/or from images, videos, livestream and other multimedia; and/or
Any other personal data required for the purposes set out below

2. Source of Personal Data Collection

We gather your personal data includes but is not limited to the followings:

Member registration form;
Information obtained from Tineco websites such as https://store.tineco.com.my/, Tineco application and social media;
Purchase form;
Cookies;
The video, livestream or other multimedia created for the purposes or reasons as stated in this Personal Data Protection Notice; and/or
Any other sources as stated or indicated in the sections below.

3. Obligatory and Voluntary Disclosure:

You understand that, for some disclosures, it is obligatory to provide and/or to allow the disclosore of the personal data. Failure to provide the personal data may result in the consequence as stated in Clause 15 below, except for Clause 8.

As for Clause 8, you understand that the provision of your personal data is voluntary and optional, and you have not been coerced or compelled to provide. You are aware of the details of use above including the publication of your personal data thereof and you consent to it. You understand that you have the right to refuse to participate and have the right to refuse the publication thereof without facing negative consequences for refusing.

4. Purposes and Reasons For Personal Data Collection

We collect your personal data for the purposes including but not limited to processing your personal data for the purpose of or in connection with:

Membership Programme (as stated in Clause 5);
Contests (as stated in Clause 6);
Website and Portal (as stated in Clause 7);
Processing Your Personal Data In Video, Image, Livestream or Other Multimedia Created (as stated in Clause 8);
Marketing, advertising, recruitment and public viewing for recruitment job vacancy advertisement;
For additional purposes which are stated in Clause 9; and/or
For any other purposes as may be required or permitted by laws within and outside Malaysia.

5. Membership Programme

When you join our membership programme, you will or have provided your personal data. Such personal data may include your name, identity card number, contact details, date of birth, gender, marital status, nationality, preferred language, occupation, monthly income and financial information. You, by enrolment to the TinecoMY Loyalty Programme and/or provision of your personal data, consent to and expressly authorize the collection, receipt, use, retention and transfer, in electronic or other form, of your personal data by SIRCLEHUB SDN BHD. for any or all of the following purposes (“Purpose(s)”):

Performing obligations in the course of or in connection with the provision of the goods and/or services requested by you;
Verifying your identity;
Responding to, handling and processing queries, requests, applications, complaints and feedback from you;
Managing the customer relationship;
Processing payment or credit transactions;
Sending marketing information about the goods or services including notifying you of marketing events, initiatives and promotions, lucky draws, membership, rewards schemes and other promotions;
Complying with any applicable laws, regulations, codes of practice, guidelines or rules, court order, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
Any other purposes for which you have provided the information;
Transmitting to any unaffiliated third parties including third party service providers for and agents of SIRCLEHUB SDN BHD; and relevant governmental and/or regulatory authorities, whether in Malaysia or abroad, for the aforementioned purposes;
Any other incidental business purposes related to or in connection with the above; and/or
For purposes as stated and explained in details in Clause 8.

We and each third party will ensure the data processed for all the purposes described herein is in accordance with the security requirement of the Personal Data Protection Act 2010 and shall only retain the data as long as necessary in order to fulfil its purpose of processing the data in accordance with each other and is responsible for the secure destruction of data when retention of data is no longer needed or necessary.

6. Contests

When you join our contests, we will be processing personal data such as name, identity card, address, contact details and signature. It is mandatory for you to provide the required information failing which we will not be able to process your application to join our contest. We will process your personal data to facilitate your participation in our contests.

Periodically, we will organize contests. If you participate in these contests, we reserve the right to publish and/or use the above mentioned personal data for the purpose of advertisements, commerce and publicity whether online and/or offline. Your personal data may also be published on our website if you are one of the winners. We will never distribute your personal data to a third-party for financial gains.

7. Website and Portal

When you register for an account or use the services provided through our electronic portal such as www.Sirclehub.com.my (“Portal”), we will be processing your personal data such as your name, email address, identity card number, contact detail, billing information and some demographic information such as gender and date of birth. It is mandatory for you to provide us with your name, identity card number, contact information and email address to register for an account and also to use our services.

We will process your personal data for the following purposes:-

To register an account with us;
To process your orders and order fulfillment;
To provide a more personalized experience on our Portal; and/or
For purposes as stated and explained in details in Clause 8.

We may correct or supplement your address information with standardized postal representation in order to ensure that your orders are delivered. We do this since we want to make sure that our members receive the order and to lower costs associated with our programs.

When you visit our Portal, we automatically log your internet protocol (IP) address, your browser type and your access times. We utilize this information to conduct site performance evaluations, to see where visitors are coming from and to keep track of click stream data (the screens our users visit on our site). This data helps us to determine what content our members find most appealing so that we can maximize your enjoyment of the site portal. Log files are not tied to personally identifiable information.

Your demographic information (gender, date of birth, etc.) will be used for several security purposes, to ensure you are who you say you are and in fact you are paying with your credit cards and not someone using your stolen credit cards.

If you choose to use our referral service to tell a friend about our site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. We do not store this information and uses it for the sole purpose of sending this one-time email.

From time to time we may send out messages alerting you that products are available, to remind you about providing feedback or for promotional offers. In addition, you will receive communication from us 1) if you contact us for a particular reason, 2) to receive your orders, or 3) we need to contact you for administrative purposes such as winning a contest. Administrative e-mails will not contain promotional materials. If you choose to receive our newsletters, they will contain promotional materials from our Portal.

We may use session cookies to provide a seamless experience on the site Portal and to combine with our log files so that we can understand our site traffic and analyze our demographic information in aggregate form. Cookies are pieces of information that your browser stores on your computer’s hard drive which identify you when you enter the Portal. The ability to select samples on our site is not cookie-driven. If you have set your browser to reject cookies, our site Portal will not identify you when you enter and you will need to manually type in your ID and password.

We may also collect information about you in connection with social networking sites. When you interact with our social networking pages such as Facebook, Twitter and YouTube, we may collect personal data such as your name, nickname and comments. We may use the information we collected about you for the purposes listed at Clause 9 below.

8. Processing Personal Data In Video, Image, Livestream or Other Multimedia Created

Background & Purposes: If you sign or acknowledge the consent form provided by the Company or agree to the terms in any other manners to provide consent, the Company will be entitled to record, capture, or broadcast videos, images, livestreams, or other multimedia that may include you. These also includes your personal data, such as your physical appearance and other information that can be inferred from the video, image, livestream, or other multimedia. The videos, images, livestreams, and/or other multimedia and the contents thereof will then be published and/or uploaded to platforms such as social media platforms, Sirclehub websites, other platforms mentioned below and/or others where the Company deems appropriate. It could also be utilized as marketing and advertising materials and other purposes as mentioned in this Privacy Notice.
Personal Data: The personal data that we will collect for this purpose includes but are not limited to your name, voice, physical appearance, any other identifiable information such as the current company that you work for (applicable to the Company’s employees), the location of my employment (applicable to the Company’s employees) and location and/or seller information associated with your purchases, in and/or from images, videos, livestream and other multimedia, and any other personal data required.
Details of the Purposes: We will process, publish and/or upload the video, livestream or other multimedia thereof to platforms such as social media, website and/or others where we deem appropriate for the following purposes and reasons:
- For enhancement of the Company’s digital presence and engagement with the Company’s customers and/or audience in innovative ways on social media platforms;
- For everyone to be aware of the mission of the Company;
- For other purposes relating to marketing, advertising, public viewing for recruitment job vacancy advertisement; and/or
- For any other purposes as stated by the Company from time to time as permitted by the applicable laws.
Voluntary Disclosure and Rights: You understand that the provision of your personal data is voluntary and optional, and you have not been coerced or compelled to provide. You are aware of the details of use above including the publication of your personal data thereof and you consent to it. You understand that you have the right to refuse to participate and have the right to refuse the publication thereof without facing negative consequences for refusing. You understand that you have the right to access to the video, image, livestream or other multimedia created by contacting us and the details of contact are stated in section “Contacting Us” of this Privacy Notice.
Retention Period: Any personal data supplied by you will be retained by us for a period we deems fit and necessary for the fulfilment of the purposes mentioned.
Security Measure: We take these measures to protect your personal data by ensuring your personal data is kept as required by Personal Data Protection Act 2010 and by ensuring our staff not to misuse your personal data.

9. Other Purposes

Other than the purposes stated above, we will generally process your personal data:-

For fulfilment purposes;
For research, statistical, data matching and product development; and/or
To communicate with you for all the above purposes;

10. Disclosure

Your personal data will also be disclosed to following categories of parties, platforms and/or places (within or outside Malaysia) for all the purposes stated in this Privacy Notice. It includes but not is not limited to the followings:

Related companies of Sirclehub Sdn Bhd (Related Companies are as defined in section 7 of the Companies Act 2016);
Any relevant authorities or bodies;
The appointed courier to deliver your purchased product;
Auditors, outsourced professional;
Licensees, Business Associates, agents and service providers of the Company;(Business Associate refers to an external party with whom the Company has, or plans to establish, some form of business relationship. This may include clients, customers, joint ventures, joint venture partners, consortium partners, outsourcing providers, contractors, consultants, subcontractors, suppliers, vendors, advisers, agents, distributors, representatives, intermediaries and investors.)
Online & offline platforms, including but not limited to social media platform (for the purpose of Clause 8) ;
Tineco websites
Public (for the purpose of Clause 8); and/or
Any other person and/or organizations which the Company may think fit.

We will also disclose your personal data to any other party to whom such disclosure is required by law or regulatory requirement or pursuant to a Court order. If we are merged or acquired by another entity, the personal data may be transferred to such entity as a part of the merger or acquisition.

11. Marketing

Unless you opt-out, we will process your personal data for present and future marketing purposes. If you have opted to be contacted for these purposes, we may contact you by way of telephone, electronic communications or by post.

We mainly communicate with you through email, if you wish to unsubscribe the direct marketing communications, you can find and click on the unsubscribe link in each of the promotional email, and we will opt you out from the mailing listing without any cost.

12. Security

Efforts will be made to ensure that any personal data held by us is kept up-to-date and is protected against any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction.

We may regularly review the security measures in safe keeping your personal data and only authorized staffs are allowed to handle the Personal Data.

13. Retention Period of Personal Data

Any personal data supplied by you will be retained by us for a period we deems fit and necessary for the fulfilment of the purposes or is required to satisfy legal regulatory, accounting requirements or to protect our interests (“the Retention Period”).

Upon expiry of the Retention Period and/or after we cease to process your personal data, we will take all necessary action to permanently delete and destroy your personal data.

14. Right of Access To Personal Data

In accordance with Personal Data Protection Act 2010 (“the Act”), you may request to access and/or modify and/or alter and/or update your personal data, subject to the followings:

We may charge an administration fee for processing your request for access; and/or
We may refuse to comply with your request for access or correction in accordance with the Act.

15. Consequence

In accordance with Personal Data Protection Act 2010 (“the Act”), you may request to access and/or modify and/or alter and/or update your personal data, subject to the followings:

Except for the purpose of Clause 8, failure of provide requested personal data or withdrawal of your consent may result in our company being a) unable to process the relevant application/form, b) unable to provide all or part(s) of the services, benefits and other related provisions c) to discontinue, cancel, withdraw and/or terminate the provision of the services, benefits, and other related provisions without prior notice.
For Clause 8, you understand that the provision of your personal data is voluntary and optional, and you have not been coerced or compelled to provide. You are aware of the details of use above including the publication of your personal data thereof and you consent to it. You understand that you have the right to refuse to participate and have the right to refuse the publication thereof without facing negative consequences for refusing.

16. Your Rights

You have the rights to:

Correct / update your personal data;
Access your personal data which we process and keep with us;
Limit the use of your personal data (For avoidance of doubt, the limitation does not include processing of mandatory personal data); and/or
Withdraw your consent for us to process your personal data by providing written notice to the Company. The consequence of the withdrawal of consent is as stated in Clause 3 and Clause 15 for the respective scenarios or situations.

17. Contacting Us

You can contact us to correct your personal data, to withdraw your consent, to exercise the afore-mentioned rights or submit your inquiry in regards to the processing of your personal data at:

Customer Service Department

Sirclehub Sdn Bhd
Address: Level G Lot 16, Medan, 28, Jalan Klang Lama, Wilayah Persekutuan, 58200 Wilayah Persekutuan, Wilayah Persekutuan Kuala Lumpur, Malaysia
Phone: +60127114600
Email: askwarranty.my@gmail.com

18. Additional Conditions:

You have the rights to:

As a subscriber of our Portal, you may correct or update your personal data by clicking on the ‘My Account’ link at the top of any page, entering your ID, password and birth date when prompted and clicking the Edit Information button. The changes you make will be reflected in our databases instantly. If you wish to deactivate your account, you may contact our member services group through the ‘My Account’ section, or the ‘Contacting Us’ section;
Any request of access or correction of personal data may be subject to a fee and also to any privacy or data protection laws. Where you elect to limit our right to process the personal data, you may contact us in writing. For avoidance of doubt, the limitation does not include processing of mandatory personal data;
We have the right to amend the Privacy Notice at any time and if we do so, we will post those changes on our website www.Sirclehub.com.my. By continuing to be our member or using our services, you are deemed to have accepted to the changes. For the purpose of Clause 8, to the fullest extent permissible under applicable law, you shall be deemed to have agreed to the amendment and/or revision; and/or.