This Privacy Statement sets out how Kosumy ETA and all its operations and business units (collectively referred to as “Kosumy ETA”, “us” or “we”) collect, store and handle personal data (as defined below) of individuals in accordance with the Personal Data Protection Acts (“PDPA”) or equivalent laws and regulations of your country.
At KOSUMY ETA, we value your trust and are committed to protecting your personal data. By providing your personal data to us, you are consenting to this Privacy Statement and the collection, use, access, transfer, storage and processing of your personal data as described in this Privacy Statement. If you are a corporation providing personal data of third parties, you warrant and represent to KOSUMY ETA that you have obtained the required consent of the parties involved for the processing of their personal data to this Privacy Statement.
This Privacy Statement explains the following:
- What, when and how we collect your personal data.
- How we use your personal data.
- When we share or disclose your personal data.
- How we store and safeguard your personal data.
- How long we will retain your personal data.
- When we transfer your personal data abroad.
- Your right to access and correct your personal data.
- Your right to limit the use of your personal data.
Collecting your personal data
KOSUMY ETA collects many kinds of personal data in order to operate effectively and provide you the best products, services and experiences possible. Personal data refers to any information which relates directly or indirectly to you as a natural person. This includes any information that can be used to distinguish, identify or contact you. For the purposes of this Privacy Statement, personal data encompasses sensitive personal information which relates to information relating to your health, political opinions, religious belief, etc.
Contact information such as your name, birthdate, identification supporting documents (including NRIC or passport number), gender, nationality and race, preferred language, current private and business address, installation address, telephone or mobile phone number, fax number and email address.
- Your credit card information and bank account details.
- The equipment you use when accessing our products and/or services such as your computer system and mobile devices to help us customise the service for you.
- The location of your computer system and mobile devices.
- The status of the products and/or services you use.
- Your personal interests and preferences to help us tailor offerings of our products and/or services which would suit you best.
- Clickstream data when you visit any of our websites including how you interact with our services, including your browser, IP address, location, cookies or other unique IDs, the pages you visit and features you use.
- Your resume and information therein for our own recruitment or job matching services.
- Your social media account name and certain information contained therein, e.g. the posts or the ‘likes’ you make.
- Information in audio and/or video format including voice, video, closed-circuit television (“CCTV”) and security recording.
- Images including photographs.
- Any such information as we deem necessary or appropriate from time to time in connection with your business relationship with us.
To the extent that you will fully and voluntarily disclose to us any personal data of any individual, we shall assume, without independent verification, that you have obtained such individual’s consent for the disclosure as well as processing of the same in accordance with this Privacy Statement.
How and when we collect may include but is not limited to:
1. Collect directly from you when you:
a. Communicate with us via online, call, physical hardcopies or other available means (for example when you furnish us your business card during marketing event or contact us for any enquiries).
b. Newsletter update.
c. Register, install, use or subscribe for our products and/or services. Certain location-enabled products may transmit your location information to us.
d. Participate in any form of seminars, courses, workshops and certification conducted by us.
e. Participate in any of our surveys.
f. Enter into or participate in any competitions, contests or loyalty programmes run/organised by us.
g. Respond to any marketing activities relating to our products and/or services.
h. Commence a business relationship with us.
i. Commence an employment relationship with us.
j. Visit any of our offices.
k. Use our websites (please refer below for more details).
l. Use social media websites that engage us.
m. Lodge a complaint or provide feedback to us.
n. Obtain from other sources or third parties where you have given consent for the disclosure of your information and/or where otherwise lawfully permitted.
a. Some of our websites may invite you to register and provide information about yourself. We use the information you provide to personalise your online experience and to deliver the content most suited to your needs. Such websites also provide an opportunity for you to update your registration information should you no longer wish to receive information from us.
b. Our websites may include links to third-party websites whose privacy practices may differ from those of KOSUMY ETA. If you submit personal data to any of those websites, your personal data is governed by the privacy statements on those websites. We encourage you to review the privacy statements of those websites you visit.
c. Our websites may include features that integrate with social media sites. When you engage with us through social media sites, you may allow us to have access to certain information from your social media account.
d. Cookies (i.e., small text files placed on your computer or device when you first visit the site) may be used on some of our websites. Most browsers now recognise when a cookie is offered and permit you to refuse or accept it. If you are not sure whether your browser has this capability, you should check with the software manufacturer. Cookies are primarily used to enhance your online experience and are not used to track the navigational habits of identified visitors, unless we obtain your permission to do so. If you visit our websites to read or download information, much of the information we do collect is statistical only (e.g. the domain from which you access the Internet, the date and time you access our websites, and the Internet address of the websites from which you linked directly to our websites) and not personally identifiable. We use this information about the number of visitors and their use of the websites in aggregate form to make our websites more useful and attractive to you.
Using your personal data
KOSUMY ETA uses the information we collect for one or more of the following purposes:
- To verify your identity.
- To keep in contact with you.
- To conduct marketing activities relating to our products and/or services.
- To assess, process and manage your application and/or request for our products and/or services.
- To provide you with the products and/or services you have requested.
- To administer and manage the products and/or services we provided to you, or any other business relationship we may have with you.
- To investigate, respond to and resolve any product and/or service issues, billing queries, complaints or other enquiries that you submitted to us.
- To assess and/or verify your credit worthiness.
- To detect and prevent fraudulent activities.
- To engage in business transactions in respect of products and/or services to be offered and provided to you.
- To help us monitor and improve the performance of our products and/or services.
- To maintain and develop our business systems and infrastructure.
- To enable staff training and quality assurance.
- To notify you about benefits and changes to the features of our products and/or services.
- To produce data, reports and statistics which shall be used by our management.
- To investigate, respond to, or defend claims made against, or involving us.
- To maintain records required for security, claims or other legal purposes.
- To comply with legal and regulatory requirements.
- For any other purposes that are required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities.
Sharing or disclosing your personal data
As a part of our operations, we may be required to disclose your personal data:
- To comply with the law or respond to legal process or lawful requests, including law enforcement and government agencies of your respective country.
- To protect our rights or property or customers, including enforcing the terms governing your use of our products and/or services.
- To act on a good faith belief that access or disclosure is necessary to protect the personal safety of KOSUMY ETA employees, customers or the public.
- With companies and/or organizations that we have hired to provide services on our behalf including our agent, contractors, service providers or professional advisers. When we share information with these companies, they are not allowed to use it for any other purpose and must keep them confidential.
- As part of corporate transactions such as a merger or sale of assets.
- With other parties in respect of whom you have given your express or implied consent.
- However, it may be necessary for us to engage third party companies, service providers or individuals to perform certain services on our behalf. In such event, you hereby agree and consent that we may disclose and transfer your Personal Data to the third parties, within or outside Malaysia, including without limitation, as follows:
a. Our affiliated companies;
b. Banks and financial institutions;
c. Insurance providers;
d. Administrative management companies;
e. External advisors and other professional advisors, such as lawyers; and
f. Such other party as we deem necessary for the purposes mentioned above.
g. We shall also disclose and transfer the information to any statutory bodies, regulatory bodies and/or governmental authorities where legally required to do so.
Storing and safeguarding your personal data
KOSUMY ETA is committed to safeguard your personal data. Personal data collected may be stored and processed in your country or any other country where KOSUMY ETA or its affiliates, subsidiaries or service providers maintain facilities. We use a variety of physical, organizational and technological measures and procedures to help protect your personal data from unauthorised access, process, use or disclosure and accidental loss or unlawful destruction. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. Other procedures include locked filing cabinets, restricted access to offices, security clearances and limiting access on a “need to know” basis and use of passwords and encryption.
Procedures for implementing these measures will be communicated to all KOSUMY ETA employees and third parties to ensure compliance with this principle. For example, we will even enter into written agreements with companies and/or organizations who process personal data in accordance with our instruction and incorporating KOSUMY ETA’s own data protection standards as a minimum.
Retaining your personal data
We may retain your personal data and that of other individuals that you provide to us for a reasonable period in accordance with commercial requirements and at all times subject to prevailing legal requirements.
Transferring your personal data abroad
It may be necessary for us to transfer your personal data outside your country if any of our affiliates, subsidiaries or service providers who are involved in providing part of KOSUMY ETA products and/or services are located in other countries. You consent to us transferring your personal data outside your country in these instances. We shall take reasonable steps to ensure that any such foreign entities are contractually bound not to use your personal data for any reason other than to provide the products and/or services they are contracted by us to provide and to adequately safeguard your personal data.
Right to access and correct your personal data
We can assist you to access and correct your personal data held by us. Where you wish to have access to your personal data in our possession, or where 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 us by contacting us via the contact details provided below. We will use reasonable efforts to comply with your request to access or correct your personal data within 5 working days of receiving your request.
Right to limit use of your personal data
If you do not wish your personal data to be utilized for the purposes of marketing from us, you have the right to request that we stop contacting you. Such request may be made via the contact details provided below. Your last written instructions to us will prevail. You are responsible for providing accurate and complete personal data to us about yourself. If you opt not to supply us with your personal data or withdraw or limit the use of your personal data, we may reject your application and/or request for our products and/or services or we may not be able to continue providing you with the products and/or services you have requested.
Changes to our Privacy Statement
We will occasionally update our Privacy Statement to reflect customer feedback and changes in our products and/or services. When we post changes to a statement, we will revise the "last updated" date at the top of the statement. If there are material changes to the Privacy Statement, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review our Privacy Statement for the products and/or services you use to learn how KOSUMY ETA is protecting your personal data.
KOSUMY ETA affiliated entities
The following entities are included in KOSUMY ETA affiliated entities:
- CWC & ENG PLT
- Fusion ETA Sdn. Bhd.
- ETA Corporate Advisory Sdn. Bhd.
- Altomate Corporate Service Sdn Bhd
How to Contact Us
Should you have any queries, concerns or complaints in relation to this Privacy Statement, kindly contact us by using the following: