This Privacy Policy (“Policy”) describes how we collect, store, process and use your personal data (as defined in the Personal Data Protection Act 2010), the personal data of any third party individual, and your business data (collectively referred to as "Data") as required to be provided by the you in the course of you utilising our websites
https://www.centry.digital/ (the “Platform”) and services, including when you purchase or use a product or service, download e-document or sign up to newsletter (“Personal Data”) provided by Centry Digital Sdn. Bhd. (or referred to as “Centry, “us”, “our”, “we”). Please read this Policy carefully. By providing us your Personal Data, using our Platform and communicating with us, you hereby consent to the processing of your Personal Data in accordance with this Policy.
1. General
1.1
If you are a user of our Platform and services, the provision of your Data is voluntary. However, if you do not provide your Data, we will not be able to process your Data for the purposes outlined in this Policy and may cause us to be unable to provide our products and/or services to or accept payments from you.
1.2
If you are an agent, vendor, supplier, service provider or strategic partner, the provision of your Data is mandatory and failure to provide your Data may cause us to be unable to engage you to provide services and/or products or issue payments to you for services and/or products provided.
1.3
If you provide us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
1.3.1
give consent on his/her behalf to the processing of said Data;
1.3.2
receive on the Data provider's behalf any privacy notice; and
1.3.2
give consent to the transfer of their Data abroad.
2. Information Collected
2.1
We may need to and/or may be required to collect, record, hold, use, disclose and store ("process") Personal Data, Business Data and financial information about you and your business, in order to enable us to deal with your inquiries and/or provide our product or services to you and your business, including but not limited to:
2.1.1
to establish your personal identification and background; and/or
2.1.2
to establish your financial standing and creditworthiness (where required).
2.1.2
establish your business identity, operations, and relationships.
2.2
We collect the following personal and business information from you, by itself or through third parties:
2.2.1
personal identification information, such as identity card number or passport number and passport expiry date);
2.2.2
date of birth or age;
2.2.3
nationality and country of residence;
2.2.4
residential address, business address and service address;
2.2.5
information about your business, such as company name, registration number, business type;
2.2.6
billing information and address;
2.2.7
occupation or job title;
2.2.9
business registration documents;
2.2.10
financial statements;
2.2.11
business plans and projections;
2.2.12
information about your business operations, such as employee count, annual revenue, and industry sector;
including any other information as required by us from time to time.
2.3
We may also collect Data of third parties, including information of the business, directors, shareholders, partners, officers or other beneficiaries.
2.4
We may also collect personal and business information of third parties, including personal and business information of directors, shareholders, partners, officers or other beneficiaries on our application forms.
2.5
We may obtain this information from you directly and from a variety of sources, including but not limited to:
2.5.1
through your relationship with us, for example information provided by you in our enquiry or application forms, when using our Platform, when taking part in our surveys, competitions, activities and promotions, when you message or communicate with us by phone, email or other correspondence methods and during financial reviews;onal identification information, such as identity card number or passport number and passport expiry date);
2.5.2
through your verbal and/or written communications with us and/or our authorised agents;
2.5.3
through any photos/videos collected by us and/or our authorised agents;
2.5.4
from third parties connected with you, such as your partners, directors, shareholders, employers, employees, joint account holders, guarantors, subject to your prior consent;
2.5.5
from an analysis of the way you use and manage your account(s) with us; and/or
2.5.6
from such other sources in respect of which you have given your consent to disclose information relating to you and/or where not otherwise restricted.
3. Use of Your Personal Data
3.1
Other than as stated above, we may use your Personal Data for one or more of the following purposes:
3.2
Where you are a user of the Platform
3.2.1
to perform our obligations in respect of any contract entered into with you;
3.2.2
to send invoices and receipts;
3.2.3
to process payments;
3.2.4
to assess your order for any of our product and/or services;
3.2.5
to process your subscriptions;
3.2.6
to verify your financial standing through credit reference checks;
3.2.7
to manage and maintain your relationship with us;
3.2.8
to provide you with information on our and/or third-party’s products, services and offers which may be of interest to you;
3.2.9
to improve and/or to develop new product and/or services;
3.2.10
to notify you about benefits and changes to the features of our product and/or services;
3.2.11
to notify you of software updates that affect our product and/or services provided to you;
3.2.12
to process your participation in any offers, competitions, events, activities, contests, polls, surveys or promotions; and/or
3.2.13
to use Cookies (as defined herein) to enhance our processes, advertising, notifications, authentication, security and compliance, analytics and/or preference management.
3.2.14
to assess and analyse your business needs and preferences;
3.2.15
to provide tailored business solutions and services;
3.2.16
to conduct business intelligence and market research;
3.2.17
to evaluate potential business partnerships or collaborations.
3.3
Where you are our agent, vendor, supplier, service provider or strategic partner:
3.3.1
for the purposes of engaging you to provide products and/or services to us or our users;
3.3.2
to facilitate or enable any checks as may be required by us in order to engage you;
3.3.3
to process payments relating to any products and/or services you have provided;
3.3.4
to verify your financial standing through credit reference checks;
3.3.5
to provide feedback to you, so that you are able to identify specific areas for improvement; and/or
3.3.6
to contact you in relation to the provision of your products and/or services.
3.4.1
to respond to your enquiries, feedback and complaints;
3.4.2
to improve the quality, efficiency and utilisation of our services;
3.4.3
to maintain, update, consolidate and improve the accuracy of our database records;
3.4.4
to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
3.4.5
to conduct research for data analytical purposes including but not limited to data mining and analysis of your transaction with us;
3.4.6
to meet the disclosure requirements of any law binding on us;
3.4.7
for audit, compliance and risk management purposes;
3.4.8
to assess financial and insurance risks;
3.4.9
to transfer or assign our rights, interests and obligations under any of your agreement(s) with us;
3.4.10
to protect or enforce our rights to recover any debt owing to us;
3.4.11
to maintain the safety and security of our services;
3.4.12
for crime detection, prevention and prosecution;
3.4.13
to detect, prevent and address any technical issues arise from our services; and/or
3.4.14
for any other purpose that is required or permitted by any law, regulations and/or guidelines.
3.5
We have the right to use your photos, images and recordings for our marketing, advertising and publicity purposes without any payment of royalty or image fees to you. We may also publish your name and photo on our Platform at our sole and absolute discretion when you become a winner in a contest which you participate in that we may from time to time organise. If you do not agree to such use, please write to us.
3.6
We will seek your separate consent for any other purposes which do not fall within the purposes stated above.
4. Disclosure of Your Personal Data
4.1
As a part of providing you with our products and/or services and the management and/or operation of the same, we may disclose your Personal Data (to the extent necessary) to the following third parties:
4.1.1
companies and/or organisations that act as our service providers, strategic partners and/or licensors;
4.1.2
companies and/or organisations that assist us in providing value added services that you have requested;
4.1.3
your advisers (including but not limited to company secretary, accountants, valuers, adjustors, auditors, tax agents or consultants, lawyers, bankers, financial advisers or other professional advisers) which are authorised by you;
4.1.4
any person notified by you as authorised to give instructions or to use the account(s) or products and/or services on your behalf;
4.1.5
any rating agency, insurer or insurance broker or direct or indirect provider of credit protection;
4.1.6
any financial institutions, merchants, e-wallet service providers, VISA International Services Association, MasterCard International Incorporated and other card associations in relation to any credit card and/or debit card issued to you;
4.1.7
any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us;
4.1.8
Immigration Department, Companies Commission of Malaysia and their appointed agencies; foreign embassies, consulates and their appointed agencies; and other relevant government departments/agencies, statutory authorities and industry regulators in connection with any investigation or enquiries;
4.1.9
fraud and crime prevention agencies for the purposes of assessing the risk of crime, fraud and money laundering and this is a condition of us entering into any contract with you;
4.1.10
our IT service providers who provide technical infrastructure services, software and development work, analyse how our services are used, or provide customer service to you; and/or
4.1.11
other parties in respect of whom you have given your express or implied consent.
4.1.12
business partners or potential business partners, subject to appropriate confidentiality agreements;
4.1.13
professional advisors such as auditors, tax consultants, and legal advisors, as necessary for the provision of their services.
4.2
With your authorisation, we may disclose your User Data (and any Personal Data related thereto) through our service to a third-party. If you authorise this disclosure, the use and disclosure restrictions contained in this Policy will not apply to such third party. We do not control the privacy practices of any third parties.
4.3
We may disclose your Personal Data to a parent company, any subsidiaries or other companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to honour this Policy.
4.4
Your Personal Data may also be disclosed as part of any merger, acquisition, joint venture, debt financing, sale of Centry or our business assets, as well as in the event of an insolvency, bankruptcy or receivership in which Personal Data could be transferred to third parties as one of our business assets. In such an event, we will attempt to notify you before your Personal Data is transferred, but you may not have the right to opt out of, or object to, any such transfer.
4.5
The above Clauses 5.1 and 5.2 shall be subject, at all times, to any laws (including regulations, standards, guidelines and/or obligations) applicable to us (whether in or outside Malaysia).
5. Disclosure for Marketing and Promotional Purposes
5.1
If you have given us your permission, we may contact you by mail, telephone, SMS, text/picture/video online instant messaging, email or other correspondence methods about our or our strategic partners’, sponsors’ or advertisers’ products, services, promotions, special offers, events or activities that may be of interest to you.
5.2
We do not and will not disclose, rent, sell or otherwise make available your Personal Data to third parties for direct marketing purposes.
5.3
If you prefer not to receive any marketing communications, notifications and materials from us, you can opt out at any time.
5.4
You may select whether or not you wish to continue to receive newsletters, updates, promotional materials, festive greetings or other communications. In addition, you may “opt out” of receiving any category of subscription, marketing or promotional email from us by following the unsubscribe instructions or using the unsubscribe links within the emails that we send to you. Please note, however, that as long as you remain as a user with us, you may not “opt out” of receiving user-related notifications and materials from us.
6. When do we disclose your personal data?
6.1
Save as set out above, we will otherwise treat your Personal Data as private and confidential and will not disclose your information to anyone except in any of the following situations:
6.1.1
where you have given permission for us to disclose your Personal Data in accordance with this Policy;
6.1.2
where we are required or permitted to do so by law;
6.1.3
where required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over us;
6.1.4
where we may transfer rights and obligations under this Policy; and/or
6.1.5
where we are required to meet our obligations to any relevant regulatory authority.
7. completeness of personal data
7.1
Where indicated, it is obligatory for you to provide your Personal Data to us to enable us to process your application for our products and/or services. Should you decline to provide such obligatory Personal Data, we may not be able to process your application/request or provide you with our products and/or services.
7.2
You confirm that all your Personal Data is true, accurate and complete and that none of the Personal Data provided is misleading or outdated. In the event of any change to your Personal Data, you will promptly update us on any such change.
8. your rights to access and correct your personal data
8.1
We can assist you to access and correct your Personal Data and Business Data provided to us, and the following will apply:
8.1.1
You may have access to your Personal Data by making a request via hello@centry.digital, subject to payment of the relevant processing fee (if applicable). We will use reasonable efforts to provide you with a copy of the requested Personal Data within twenty-one (21) days of receiving your duly completed Access Request Form and the processing fee.
8.1.2
Please note that we may have to withhold access to your Personal Data in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential nature or in the event 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.
8.1.3
Where your request for data access is successful and you are of the opinion that such Personal Data held by us is inaccurate, incomplete, misleading or where relevant, not up-to-date, you may make a request to correct such Personal Data.
8.1.4
You can also assist us to keep your Personal Data (such as your current mailing address) up-to-date, as it will enable us to serve you better.
8.1.5
In the event you wish to correct or update your Personal Data previously provided to us, you may write in or notify us at the address provided in Clause 8.1. We will use reasonable efforts to comply with your request to correct your Personal Data within twenty-one (21) days of receiving your written request.
8.1.6
Please note that we may use our discretion in allowing the correction or update requested or may require further documentary evidence of the new information to avoid fraud and inaccuracy.
9. exercising your choices in respect of the disclosure and use of your personal data
9.1
Subject always to our contractual rights and obligations under relevant laws and regulations, you may exercise your choice in respect of the disclosure, retention and use of your Personal Data by us. Should you wish to do so, kindly contact us at:
- Tel: +603 2027 8620
- Email: hello@centry.digital
10. transfer of personal data
10.1
Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than the jurisdiction of your company’s incorporation, your home nation or otherwise in the country, state and city in which you are present while using any services provided by us (“Alternate Country”), to companies which are located outside of your home nation or Alternate Country and/or where our servers and/or service providers and partners are located outside of your home nation or Alternate Country. You understand and consent to the transfer of your Personal Data out of your home nation or Alternate Country as described herein.
11. Cookies
11.1
We, our affiliates, licensors, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of our Platform. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of our products and/or services, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.
11.2
We may allow third parties to use Cookies on our Platform to collect the same type of information for the same purposes we do for ourselves. Third parties may be able to associate the information they collect with other information they have about you from other sources. We do not necessarily have any responsibility, access to, or control over the Cookies they use.
11.3
Additionally, we may share non-personally identifiable information from or about you with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.
11.4
If you do not wish for your Personal Data to be collected via Cookies, you may deactivate Cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also be able to limit our sharing of some of these information through your mobile device settings.
12. links to third-party websites
12.1
Our Platform may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information directly to such sites, the privacy policy and terms of service on those sites are applicable and we shall not be responsible for the information processing practices or privacy policies of such sites.
13. personal data from minors and other individuals
13.1
As a parent or legal guardian, you are under the obligation to not allow a minor (individuals under eighteen (18) years of age) under your care to submit personal data to us in their own capacity. In the event that such personal data is provided to us, you hereby consent to the processing of the minor’s personal data and personally accept and agree to be bound by this Policy and take responsibility for his or her actions.
13.2
In some circumstances where you may have provided Personal Data relating to other individuals (such as your spouse, family members, friends, business partners, shareholders or directors), in such circumstances you represent and warrant that you are authorised to provide their personal data to us and you have obtained their consent for their Personal Data be processed and used in the manner as set forth in this Policy.
14. Business Data Specific Provisions
14.1
Protection of Confidential Business Information: We recognise that some Business Data may constitute trade secrets or other confidential information. We will implement appropriate measures to protect such sensitive business information from unauthorised access or disclosure.
14.2
Data Retention for Business Purposes: We may retain your Business Data for longer periods than Personal Data, as necessary for legitimate business purposes, regulatory compliance, and historical record-keeping.
14.3
Business Data Portability: Upon request, we will provide you with a copy of your Business Data in a structured, commonly used, and machine-readable format, to the extent technically feasible.
14.4
Business Continuity: In the event of a change in ownership or control of Centry due to merger, acquisition, or sale of assets, we will ensure the confidentiality of your Business Data and provide notice before Business Data is transferred or becomes subject to a different privacy policy.
14.5
Aggregate Business Data: We may use aggregate, anonymized Business Data for industry analysis, demographic profiling, and other commercial purposes. Such aggregate data will not identify your business specifically.
14.6
Aggregate Business Data: We may use aggregate, anonymized Business Data for industry analysis, demographic profiling, and other commercial purposes. Such aggregate data will not identify your business specifically.
14.6.1
All data produced by Centry's services as a result of our engagement with clients ("Service-Generated Data") will not be shared with any parties not related to the engagement between Centry and the client by default.
14.6.2
Service-Generated Data may only be shared under the following circumstances:
a) With the explicit written consent of the client;
b) If required by law or by officers/authorities enforcing the law;
c) If the data is made public by way of data submission to any parties/authorities that will make the data public as part of regulatory or legal requirements;
d) If the data is shared by the clients themselves with the public.
14.6.3
In the event that we are required to disclose Service-Generated Data due to legal obligations or law enforcement requests, we will make reasonable efforts to notify the client, unless prohibited by law.
14.6.4
We will implement appropriate technical and organizational measures to protect Service-Generated Data from unauthorized access, disclosure, alteration, or destruction.
14.6.5
Clients have the right to request information about any sharing of their Service-Generated Data that has occurred, subject to legal restrictions.
15. enquiries or complaints
14.1
Should you have any queries, concerns or complaints in relation to this Policy or how we handle your Personal Data, kindly contact us at:
- Tel: +603 2027 8620
- Email: hello@centry.digital
16. Amendment
We shall have the right to modify, update or amend the terms of this Policy at any time, and from time to time, by placing the updated Policy on the Platform. By continuing to communicate with us, continuing to use our products and/or services following the modifications, updates or amendments to this Policy, you acknowledge that such actions shall signify your acceptance of such modifications, updates or amendments.
