1. Collection of Personal Data
1.2. Your Personal Data are collected from a variety of sources including but not limited to the following :-
(a) directly from you by whatsoever means and/or in whatever manner;
(b) obtained independently from publicly available sources or other lawful sources;
(c) through the Site and from cookies used on the Site;
(d) obtained from various entities or divisions within the Group; and
(e) obtained from third parties.
2. Cookies and other Tracking Devices
2.2. From time to time we may permit third party(ies) (including advertisers) to set cookies on our Site for purposes which may include market research, serving advertisements, revenue tracking, to improve functionality of the Site or monitoring for compliance with the relevant user agreements or subscription agreements. We may not have access to these third party cookies and these parties may have their own privacy policies and information generated by such cookies from the use at the Site may be transmitted to and stored at servers of such third parties.
2.3. You may choose to delete or block the cookies by changing the settings on your computer or device. However, choosing to do so may reduce the functionality of the Site, the quality and efficiency of delivery of the services and/or products or may prevent access to registration / subscription-only areas or certain features of the Site.
3.1. We have implemented reasonable technology, policies and measure designed for securing and protecting your privacy from unauthorised access, improper use, disclosure and alteration.
3.2. Whilst we will use its best endeavours to maintain a security plan deemed adequate by us to protect your Personal Data, we make no guarantee that the Site will be free from security breaches, especially due to unauthorised actions of third parties such as, but not limited to spoof attacks, session hacking, sniffing or tampering.
3.3. When you register or subscribe for any services and/or products, you may be assigned with a unique identity consisting of your user identity and/or your password (“Identity”). It shall be your responsibility to keep your Identity secured and not to share or enable anyone to access your Identity (whether or not you have acted negligently or otherwise in the circumstances). We shall not be liable for any breach of security or privacy where it is due to any act or omission by you which enables third party(ies) to access your Identity or the Site and services and/or products through your Identity.
4. Purpose of Collection of Personal Data
4.1. Your Personal Data will be collected, processed and used by us for the following purpose :-
(a) to verify and authenticate your Identity;
(b) for registration of a user account and to manage and maintain your account(s) or subscription(s) with us;
(c) to send you invites to our product launches, promotional materials, updates, special offers and advertisements for marketing purposes;
(d) to provide you with services and/or products offered by us or third parties that you have requested or which we think may be of interest to you or to process any application or otherwise any communication from you to us;
(e) to process your entries and to communicate with you in respect of your participation in any events, activities or contests organized by us;
(f) to process payments relating to any services and/or products;
(g) to respond to your enquiries or complaints and to resolve disputes;
(h) to maintain our records of our customers and prospective customers and our internal record keeping;
(i) for conducting research;
(j) for internal administrative purposes, including but not limited to preparation of and conducting of any assessment, statistics, analysis or internal reports in relation to our customers, potential customers, products and services;
(k) for purposes of preparation and submission of any claims or payments to any party or for any audit/check by any party for whatever purposes related to our business;
(l) to comply with any legal or regulatory and/or to make the necessary disclosures under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular and/or code which are applicable to us and/or for the prevention of crime;
(m) to improve the quality of the services and/or products which may be provided for you;
(n) to automatically scan messages to check for spam, fraud, phishing attacks, computer viruses or malicious computer programming routines, and other malicious activities or illegal or prohibited contents; and
(o) for any other purpose that is incidental to or in furtherance of the Group’s business or purposes.
4.2. It is necessary for us to collect and process your Personal Data for the above purposes to provide you the services and/or products. In the event that you fail to provide Personal Data to us or the Personal Data is not satisfactory to us or you choose to remove your Personal Data, certain services and/or products or features of the Site may not be available to you or we may not be able to provide the full range of benefits of the services and/products offered by us and/or perform our obligations under any potential or existing contract with you. In such an event, we shall not be held liable for the interruption, non-provision or loss of services and/or products and/or for any losses and/or damages arising therein.
5. Disclosure of Personal Data
5.1. Your Personal Data provided to us shall be kept confidential. However, you agree that we may disclose your Personal Data to the following parties as may be necessary or appropriate including and not limited to the following :-
(a) any person to whom we are required to do so by law or in response to any authorities, government agencies and/or industry regulators;;
(b) our financiers, auditors, legal advisors, financial advisors, accountants, consultants and other professional advisors;
(c) third party service and product provider including but not limited to information technology;
(d) our advertisers, network operators, property management companies, contractors or sub-contractors; and/or
(e) our joint venture and/or business partners or any of the companies which is related or affiliated to us.
5.2. When you become a winner in a contest or participate in any of our events, we may publish your name, photographs and other personal information without compensation for advertising and publicity purposes.
5.3. We shall endeavour to ensure that reasonable steps are taken to procure that such third parties shall not use the Personal Data other than for that part of the purpose as set out herein and to adequately ensure the confidentiality of the Personal Data.
7. Transfer of Personal Data
7.1. You hereby consent to us that the Personal Data you have provided to us or to our third party services and/or products providers may be transferred within or outside of Malaysia, where we consider it necessary for the purposes of provision of services and/or products to you. We shall endeavour to ensure that the Personal Data shall not be used other than for that part of the purpose stated herein and to adequately ensure the confidentiality of the Personal Data.
8. Access to Personal Data
8.1. You have the right to:-
(a) request access to your Personal Data;
(b) request correction of your Personal Data which is inaccurate, misleading or not updated;
(c) request us to stop processing your Personal Data for direct marketing;
(d) withdraw your consent to us for the processing of your Personal Data for the purposes set out in herein or to limit the processing of your Personal Data; and/or
(e) make any inquiries regarding your Personal Data,
subject to any applicable legal restrictions and/or contractual conditions.
For the abovesaid purpose, please contact Focus as follows:
By Email : [email protected]
8.2. We reserve the right to charge a fee for the processing of any Personal Data access request.
9. Personal Data Given By You
9.1. You hereby confirm that you have obtained the consent of the relevant person(s)/company(ies) whose Personal Data is provided by you to us for the purposes set out herein.