PERSONAL DATA PROTECTION NOTICE

Cloke, Inc (“we” or “us” or "our") respects and is committed to the protection of your personal information and your privacy.  This Personal Data Protection Notice (“Notice”), prepared in accordance with the Personal Data Protection Act 2010 of Malaysia (the “Act”) as well as the General Data Protection Regulation (GDPR) in the European Union, sets out our personal data protection practices that are put in place to protect the personal data of individuals who we deal with. 

 

We value the trust you have placed with us and we respect your privacy.

 

Please note that we may amend this Notice at any time without prior notice and will notify you of any such amendments via our website or by email.

 

Collection of personal data

In the course of your dealings with us, we will request that you provide certain personal data elements to enable us to enter into transactions with you or to deliver the necessary goods, services and/or communications in connection with such transactions.

 

These are necessary for our business process execution, including delivery of notices, services and/or products, customer or channel partner and/or third party vendor relationship management, new product launches and events, planning purposes in connection with future products, including promotional events with our Affiliates and channel partners.

 

What kind of personal data we collect

In order for us to fulfil one or more of our obligations listed in paragraph 2 herein, we will need to collect relevant personal data from you.  The personal data collected by us may include (but is not limited to) the following:

  1. Contact information such as your name, date of birth, identification supporting documents (including NRIC or passport number), nationality, preferred language, current private and/or business address, telephone and/or mobile phone number(s), fax number and email address(es);

  2. The status of products and/or services you have acquired from us or have subscribed to;

  3. How you use the products and/or services;

  4. Your personal interests and preferences to help us tailor offerings on our products and/or services which would suit you best;

  5. The information you provide us regarding your marketing preferences or in the course of participating in surveys, competitions, contests, lucky draws or promotional offers; and/or

  6. CCTV or camera visual recordings when you visit our office premises or participate in any of our events.

 

When and how we collect your personal data

We may collect personal data directly from you when you:

  1. Communicate with us via email, phone, mobile communication applications including but not limited to SMS, WhatsApp, Facebook Messenger;

  2. Submit your information when registering the product/services warranty;

  3. Where you register your interest or subscribe for information on our products and/or service or to our publications (for example newsletters), our websites such as www.elock.com.my, www.elock.co.jp, www.clokesecurity.com, www.scanmypage.com;

  4. Participate in any of our surveys, competitions, contests, lucky draws or promotional offers;

  5. Respond to any marketing materials we send out;

  6. Commence a business relationship with us (applicable to channel partner or third party vendors);

  7. Visit our offices;

  8. Provide feedback to us (for e.g. via our websites or in hard copy) and/or

  9. Subscribe to any of our Subscription Services, which requires us to collect and process payment information from you such as your credit card numbers and billing information, using third-party PCI-DSS compliant payment service providers.

 

Other than personal data obtained from you directly (as detailed above), we may also obtain your personal data from third parties we deal with or who are connected with you and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted.

 

Purpose of collecting personal data

Personal data you provide will be processed by us for, amongst others, the following purposes as applicable:

  1. The delivery of notices, services or products and the marketing of such services or products to you;

  2. In order for you to enter into the necessary agreement and/or contract in relation to the sale and supply of products or for the supply of goods and services;

  3. Such purposes specifically provided for in any particular service or product offered by us;

  4. Conducting marketing, surveys and customer profiling activities in connection with our services and related products;

  5. Our internal record keeping;

  6. Enabling us to send you information by e-mail, telecommunication means (telephone calls or text messages) or social media about products and services offered by our Affiliates, that we think may interest you;

  7. To establish and better manage any business relationship we have with you;

  8. To process any communication you send us (for example, answering any queries and dealing with any customer service complaints and feedbacks);

  9. Post-sales services, such as after-sales maintenance (if any) or customer service related matters;

  10. To provide you with the products and/or services you have requested; and/or

  11. To notify you about benefits and changes to the features of our products and/or services.

 

Failure to supply personal data

The failure to supply such personal data as may be needed may:

  1. Result in us being unable to provide you with the notices, services and/or products requested;

  2. Affect our ability to affect the necessary processes relating to the supply of our products and/or services; and/or

  3. Result in us being unable to update you on our latest products, services, promotions, events, launches and/or security information related updates.

 

Disclosure of your personal data

Personal data provided to us will generally be kept confidential but you hereby consent and authorise us to provide or disclose your personal data to the following categories of parties:

  1. Companies and/or organisations that act as our agents, contractors and/or service providers;

  2. Our channel partners and Affiliates for purposes that are related to the purpose of collecting and using your personal information;

  3. Other parties in respect of whom you have previously given your express consent;

  4. Our auditors, consultants, accountants, lawyers or other financial or professional advisers; and/or

  5. Companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions and providing you with products and/or services that you have requested or subscribed for.

 

Personal data Integrity

We will take all reasonable steps to make sure that the personal data collected, used or disclosed is accurate, complete, not misleading and up-to-date.

 

Personal data security

We will take all reasonable steps to protect the personal data we hold from loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction. We will not keep personal data for longer than is necessary and will take reasonable steps to destroy or permanently de-identify personal data.

 

Data transfer and sharing

Where we consider it necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your personal data to another Affiliate within or outside Malaysia, under conditions of confidentiality and similar levels of security safeguards.

 

Cookies
Cookies are pieces of information that a web server transfers to your computer's hard disk for record-keeping purposes. Cookies can make the web server more useful by storing information about your preferences on a particular site. Our website uses cookies to provide useful features to users. Cookies in and of themselves do not personally identify users, although they do identify a user's computer. Most browsers are initially set up to accept cookies. If you would prefer, you can set yours to refuse cookies. However, you may not be able to take full advantage of the features of our site if you do so.

 

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.

 

Data Subject Rights
You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision. 

 

To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy. 


In certain circumstances, you have the following data protection rights:

  • The right to access: Update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

  • The right of rectification: You have the right to have your information rectified if that information is inaccurate or incomplete.

  • The right to object: You have the right to object to our processing of your Personal Data.

  • The right of restriction: You have the right to request that we restrict the processing of your personal information.

  • The right to data portability: You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

  • The right to withdraw consent: You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

 

Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact the data protection authority of your country or EU Member State.
 

Links Sites
A link from our website to another site does not imply endorsement of that site. Linked sites are not under our control and we will not be held responsible for the content or privacy policies of any linked sites or any links containing other linked sites. If you decide to access any of the third party sites linked to us, you will do this entirely at your own discretion and at your own risk. 

If you access any third party sites using the links provided, the operators of these sites may collect your personal information. Please ensure that you are satisfied with the privacy statements of third-party sites before you submit any personal information. We cannot be held responsible legally or otherwise for the activities, privacy policies or levels of privacy compliance of these third-party sites.these

 

Procedure for Unsubscribing and Opt-Out
You may opt out of receiving email messages at any time by sending a message with "unsubscribe" in the subject line to edm@clokesecurity.com, or by following the instructions placed at the footer of all our marketing emails.

 

Access and Correction

In accordance with the Act including GDPR, and all corrections can be sent to the following email, facsimile, address:

  • Email: edm@clokesecurity.com

  • Facsimile: +603-2166 2982

  • Address: One World Trade Center, 285 Fulton Street, Suite 8500 New York, NY 10007

© 2019 CLOKE Inc.
One World Trade Center, 285 Fulton Street, Suite 8500, New York NY 10007   |   555 California Street, Suite 4925, San Francisco CA 94104
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