隐私政策

Last Updated: 16 February 2022

https://rewardslink.world/ is operated by TOGL Technology Sdn. Bhd. (“我们”，“我们” or “我们的”), a private limited company incorporated under the laws of Malaysia since 2017 and developed Rewardslink, a social media mobile application.

This privacy notice describes our collection, use, disclosure, and retention of personal data in relation to Rewardslink and its ancillary websites, apps, services, and platforms, and your use of them, our marketing and provision of products and services, our interactions with you in-person, by calling us, or by mail, and otherwise during the operation of our business (“奖励您”）。

Please read this section carefully as it sets out our privacy notice which informs you of our privacy practices, the way your personal data is collected online, how that information is used and how we share, transfer and protect that information.

Your use of Rewardslink or your provision of information to us constitutes your acknowledgment of the terms of this privacy notice. We are fully committed to protecting the information relating to identified or identifiable natural persons. Please do not send us any of your personal data if you do not want it to be used in the ways described in this privacy notice.

We have appointed a Data Protection Officer (“DPO”) as we are recommended to do so under Malaysian laws and you may contact our DPO with questions about our personal data processing activities or the contents of this notice at by emailing dataprivacy@togltechnology.com.

Under the Malaysian Personal Data Protection Act 2010, data is legally recognised as personal data only in respect of commercial transactions, which means any transaction of a commercial nature, whether contractual or not, which includes any matters relating to the supply or exchange of goods or services, agency, investments, financing, banking and insurance, but does not include a credit reporting business carried out by a credit reporting agency under the Credit Reporting Agencies Act 2010.

To allay concerns whether a nominal user of social media would enjoy the protection offered by the PDPA considering that the PDPA only regulates personal data in the context of commercial transactions and for the purposes of the Personal Data Protection Act 2010 and lack of ambiguity, the data user is TOGL Technology Sdn. Bhd. and we will endeavour to our best efforts to maintain compliance with the Personal Data Protection Act 2010.

In accordance with the requirement of Malaysian data protection and privacy law, this Privacy Statement is issued in both English and Bahasa Malaysia. In the event of any inconsistencies or discrepancies between the English version and the Bahasa Malaysia version, the English version shall prevail.

A. What Information Do We Collect, Our Use Of Your Personal Data And Why?

When you use Rewardslink we may ask you for information about yourself, including your name, identification card number or passport number address, email address and other ancillary information for the purposes of user verification which is standard practice across various international social media platforms.

In addition to the information you provide, we may also collect information about you and your use of our website through the use of automatic data collection tools. These tools collect certain standard information about your access and computer, such as your browser type, operating system and language, access times and your Internet Protocol (IP) address. We use the information for statistical reporting and do not link it to any named individuals.

TOGL Technology Sdn. Bhd. will not intentionally collect any information about visitors to this website who are under eighteen years of age. If TOGL Technology Sdn. Bhd. becomes aware that a child has provided any information this will immediately be deleted from TOGL Technology Sdn. Bhd.’s records.

We may collect the following personal data from you:

• personal information such as your full name as stated in passport or identity card, passport or identity card registration number, personal profile photo and nationality
• 联系信息，例如手机号码和电子邮件地址
• 地理位置信息：包括GPS信息、WLAN接入点、蓝牙、基站等传感器信息获取的精确地理位置信息，以及网络位置信息（如基站、IP、WLAN）获取的大致地理位置信息
• address book from mobile phone number, camera, microphone, photo and storage of data files including but not limited text, pdf, audio, image and video
• payment information such as your bank account number, bank account holder full name and details, bank swift code and other ancillary bank account details
• 通过安装在我们分支机构或场所的闭路电视摄像机记录您的图像
• 在我们的任何公司活动或第三方开放日期间记录您的照片
• 记录您拨打我们客户服务的电话
• 当您与我们建立业务关系时的职能或职位
• 向我们申请工作时的简历或简历
• 当您亲自、通过电话或柜台联系我们时（例如，当您联系我们进行任何查询、投诉、评论或反馈时，我们可能会保留这些通信记录）
• 当您参与内部或通过指定的第三方进行的任何调查、问卷、竞赛、竞赛、优惠或促销活动时
• 当您与我们建立业务关系时（例如，作为服务提供商或业务合作伙伴）
• when we collect information about you from third parties we dealt with or are connected with you (payment collector, credit reporting agencies or financial institutions

B. Scope Of Privacy Notice

This privacy notice applies when we receive any personal information from you including in the following circumstances:

• when you request information from us or provide information to us;
• when you or the organisation you work for engages us for our services or uses Rewardslink;
• when you or the organisation you work for are a counterparty to a contract with us;
• when you apply for a role or work placement opportunity or recruitment event with us;
• when you complete application forms on our website; and
• when you visit our websites and online services (including our mobile app, Rewardslink)

C. Who Do We Share Your Personal Data With?

TOGL Technology Sdn. Bhd. may also be required to disclose your personal information to:

1. respond to duly authorised information requests from the police and governmental authorities;
2. comply with any law, regulation, subpoena or court order;
3. help prevent fraud or to enforce or protect the rights and properties of We or its subsidiaries; or
4. protect the personal safety of We employees, third party agents or members of the public.

We do not share, rent or trade your personal data with third parties for marketing or promotional purpose.

D. Use Of Your Personal Data

You agree that we may use your personal data for the following purposes:

• 验证您的身份
• 管理和维护您的帐户或与我们签订的合同
• 通知您有关服务的好处和更改
• 在您的授权下向您提供和改进我们的服务；
• 访问通讯录以在服务中邀请和寻找朋友
• 访问相机以拍摄照片并录制视频以发布Rewardslink并在Rewardslink中执行任何视频通话和直播功能
• 在Rewardslink中访问麦克风以进行即时消息语音注释、视频和/或音频通话以及实时流功能
• 我们会根据大致地理位置信息对应的城市和/或区，向您展示并推荐您所在地区（市、区、县等）的当地信息
• 包括满足审计要求、服务计费和便利付款
• 执行您的指示或回应您提交给我们的任何查询、投诉、评论或反馈
• 汇编信息以供相关监管机构分析和报告
• 根据您与我们的任何协议转让或转让我们的权利、利益和义务
• 更新、整合和提高我们记录的准确性
• 管理竞赛、竞赛、优惠或促销活动
• 生成匿名或聚合的数据、报告和统计数据，这些数据、报告和统计数据不会将您识别为个人
• 出于分析目的进行研究，包括但不限于数据挖掘和分析您与我们的交易
• 评估金融和保险风险
• 进行调查、问卷调查并向您提供我们提供的信息或我们认为您可能感兴趣的信息，如果您已同意出于此类目的与您联系
• 从事与向您提供和提供的服务有关的商业交易
• 遵守适用于我们的适用法律、法规、指南或行业准则项下的任何法律或监管义务
• 用于对提供给您的服务进行内部管理
• 维护安全、索赔或其他法律目的所需的记录
• 为我们的员工提供培训
• 进行营销和信息技术活动（例如，市场研究）
• 出于相关交易或查询的目的，向已被确定为您或您的授权代表的人
• 向与我们签订合同以向我们提供服务（例如代表我们进行分析）的第三方用于上述任何目的。当我们向第三方披露您的个人数据时，我们将确保此类数据仅用于向我们提供服务
• 用于任何法律、法规、指南和/或相关监管机构要求或允许的任何其他目的。

E. Accuracy Of Your Personal Data And Your Rights

TOGL Technology Sdn. Bhd. strives to keep your personal information accurately recorded. You have the right to obtain a copy of the information we hold about you and/or to ask us not to process your personal data (or not to pass your personal data to third parties).

If you would like copies of your personal data, or if you would like us to correct any factual inaccuracies in that information, or if you would like that information blocked or deleted from our records, then please contact the DPO of TOGL Technology Sdn. Bhd. at dataprivacy@togltechnology.com.

You can ask us to correct or complete your personal data by contacting us at any time. To the extent reasonably possible, we will inform anyone who has received your personal data of any corrections we make to it.

If you would like to obtain further information on how to limit the processing of your personal information or have any further query, please contact the DPO of TOGL Technology Sdn. Bhd. at dataprivacy@togltechnology.com as well.

F. How Do We Keep Your Personal Information Secure?

We take reasonable technical and organisational security measures (e.g. data encryption and access restriction to such encrypted data) to prevent the loss, misuse, alteration or unlawful disclose of information you provide to us. Our security measures are in place to help protect against the loss, misuse and alteration of the information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we ensure that our systems adhere to market security standard so as to help safeguard against such occurrences.

G. Retention Of Your Personal Data

We will store your personal data for no longer than is necessary for the purposes for which it was collected or provided to us (unless a legal or insurance obligation requires us to keep it for longer period such as operational, legal, regulatory, tax or accounting requirements).

H. Rights To Your Personal Data

i. Deactivating & Deleting
You may ask to have the information on your account deleted or removed by sending your request to dataprivacy@togltechnology.com which we shall send an acknowledgement of receipt email thereof. We will try to do so promptly and, to the extent reasonably possible, we will inform anyone who has received your personal data of your request. However, we must keep track of certain transaction information, if any, such as past purchases and similar information, for legal or tax compliance purposes, to satisfy insurance obligations or in the event of legal claims, so we may not be able to fully delete your information in certain circumstances.

ii. Access
You may contact us at any time in order to request access to the personal data we hold about you. We will confirm whether we are processing your personal data, provide details of the categories of personal data concerned and the reasons for our processing. We can also provide you with a copy of your personal data on request though we will have to be mindful of the rights of others within any relevant records when doing so.

iii. Restriction
In certain circumstances, it may be possible to require us to limit the way in which we process your personal data (i.e. require us to continue to store your personal data, but not otherwise process it without your consent).

iv. Receiving/transferring your personal data
In certain circumstances (where we process your data based on consent or pursuant to a contract with you, and the processing is carried out by automated means), you may ask us to send you the personal data we hold on you in an electronic, structured and user-friendly format, or you may ask us to send this data to another entity.

v. Object
Where we are processing your personal data without your consent to pursue our legitimate interests, you may object to us processing your personal data. Where we are using your personal data to contact you for marketing purposes, you may object to such processing at any time.

vi. Complaints
We encourage you to contact us before making such complaint to the relevant authorities, so that we can try to resolve any concerns you have.. If you have a complaint about how we have wrongly used your personal data, you have the right to complain to the Personal Data Protection Commissioner stationed in the Personal Data Protection Department addressed at Level 6, Ministry of Communications and Multimedia Complex, Lot 4G9, Persiaran Perdana, Precinct 4 Federal Government Administrative Center, 62100 Putrajaya, Malaysia and may be emailed to at webmaster@pdp.gov.my.

I. Changes To Privacy Notice

Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.