Privacy Policy

Last Updated: 16 February 2022

http://101.200.123.16/ is operated by TOGL Technology Sdn. Bhd. (“we”, “us” or “our”), 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 (“Rewardslink”).

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
• contact information such mobile phone number and email address
• geographic location information: including precise geographic location information obtained by GPS information, WLAN access point, Bluetooth, base station and other sensor information, and approximate geographic location information obtained by network location information (such as base station, IP and WLAN)
• 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
• recording of your image via CCTV cameras installed at our branches or premises
• recording of your photograph during any of our corporate events or third-party open day
• recording of calls placed by you to our customer services
• function or post when you commence a business relationship with us
• resume or CVs when you apply job with us
• when you contact us in person, by a phone call or over the counter (for example when you contact us for any enquiries, complaints, comments or feedbacks, we may keep record of that correspondences)
• when you participate in any surveys, questionnaires, competitions, contests, offers, or promotions done internally or via an appointed third party
• when you commence a business relationship with us (for example, as a service provider, or business partner)
• 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:

• to verify your identity
• to manage and maintain your account or contract with us
• to notify you about benefits and changes to the services
• to provide and improve our Services to you subject to your authorization:
• to access address book to invite and find friends in the Services
• to access camera to capture photo and to record video to post it Rewardslink and to perform any video calls and live stream features in Rewardslink
• to access microphone for instant messaging voice note, video and/or audio calls and live stream features in Rewardslink
• we will show you and recommend the local information of your region (city, District, county, etc.) based on the city and / or district corresponding to the approximate geographic location information
• including fulfilling audit requirements, billing for services, and facilitating payments
• to carry out your instructions or to respond to any enquiries, complaints, comments or feedbacks that you have submit to us
• to compile information for analysis and in reports for relevant regulatory authorities
• to transfer or assign our rights, interests and obligations under any of your agreements with us
• to update, consolidate and improve the accuracy of our records
• to administer competitions, contests, offers, or promotions
• to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual
• to conduct research for analytical purposes including but not limited to data mining and analysis of your transactions with us
• to assess financial and insurance risks
• to conduct surveys, questionnaire, and provide you with information from us or which we feel may interest you, where you have consented to be contacted for such purposes
• to engage in business transactions in respect of services to be offered and provided to you
• to comply with any legal or regulatory obligations under the applicable laws, regulations, guidelines or industry codes that applies to us
• for internal management of the services being provided to you
• to maintain records required for security, claims or other legal purposes
• to provide training for our staff
• to conduct marketing and information technology activities (for example, market research)
• to persons who have been identified as being you or your authorised representative(s) pursuant, for the purpose of the relevant transaction or enquiry
• to third parties with whom we have contracted to provide services to us (such as analysis on our behalf) for any of the purposes described above. Where we disclose your personal data to third parties we shall ensure that such data is used only to provide services to us
• for any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities.

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.