Introduction of our Privacy Notice

• This is a privacy notice (“Notice”) of Winner Venture Sdn Bhd (Company No. 1285421-A) with its registered address at K-0-8, Kuchai Business Park, Jalan 1/127, off Jalan Kuchai Lama, 58200 Kuala Lumpur (including all of its subsidiaries, brands, related and/or associated companies/brands) for HaloGo’s platforms (the “Platform”) users. These entities are collectively referred to as “HaloGo”, “we”, “us” or “our”. The words “you”, “your” and “customer” include past, current and future customers of the Platform. HaloGo is bound by the Personal Data Protection Act 2010 and all regulations, standards and guidelines as may be prescribed from time to time pursuant to the Personal Data Protection Act 2010.
• We build a range of features and services to ease your use of our products and services. This Notice explains our practices regarding the collection, use, disclosure and transfer of your personal data when you subscribe to and use any of our products and services, including telecommunications network, applications, digital services and solutions, or visit any of our office branches and any of our websites or contact our customer support (collectively referred to as “Services”). Where this Notice is translated into a language other than the English Language, in the event of any inconsistencies, conflicts or discrepancies between the terms set out in the English Language version and that of the other language(s), the English Language version shall prevail.
• 1.1 On this Platform, we take your privacy seriously. We are committed to complying with all data protection/privacy laws which are applicable to us.
• 1.2 This Notice is incorporated as part of the Terms of Use of HaloGo Website (“Terms of Use of HaloGo Website”). Your use of the Platform and/or Service is subject to the Terms of Use of HaloGo Website and this Notice. Unless specifically defined in this Notice, the defined terms shall have the same meaning as defined in the Terms of Use of HaloGo Website.
• 1.3 For the purpose of this Notice, “Personal Data” and “Sensitive Personal Data” shall include the following information:

  Personal Data	Any information, whether recorded in a material form or not, from which the identity of an individual and/or entity is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.
  Sensitive Personal Data	Comprises information as to the individual's physical or mental health or condition, political opinions, religious beliefs or other beliefs of the same nature, commission or alleged commission of any offence or any other Personal Data determined by law.

• 1.4 We will only collect, use, disclose and/or process your Personal Data in accordance with this Notice.
• 1.5 It is important that you read this Notice together with any other applicable notices we may provide on specific occasions when we are collecting, using, disclosing and/or processing Personal Data about you, including our service-specific additional terms as may be provided in the specific Services’ platform, so that you are fully aware of how and why we are using your Personal Data. If the terms in this Notice conflict with any service-specific additional terms, the service-specific additional terms shall prevail for that particular Service.
• 1.6 By clicking or checking “Sign Up”, “Log in”, “Submit”, “I Agree to HaloGo’s Privacy Notice” or similar statements available at the Platform’s registration page, you acknowledge that you have been notified of and understood the terms of this Notice and that you have agreed and consented to the collection, use, disclosure and/or processing of your Personal Data as described and under the terms herein.
• 1.7 We may revise or update this Notice or the service-specific additional terms at any time by posting a revised or an updated version on the Platform. Unless stated otherwise, any revision or update takes effect immediately, including in the circumstances where we launch a new service or feature, or in urgent situations, such as to prevent ongoing abuse of the services or responding to legal requirements. Any changes we make to this Notice in the future will be posted on the Platform and/or any other means and, where appropriate, notified to you, whereupon your continued use of the Services, access to the Platform or use of the Services, including placing orders on the Platform, shall constitute your acknowledgment and acceptance of the changes we make to this Notice, as notified to you. Please check back frequently to see any updates or changes to this Notice.
• 1.8 This Notice applies in conjunction with other notices, contractual clauses and consent clauses that apply in relation to the collection, use, disclosure and/or processing of your Personal Data by us, and is not intended to override them unless we state expressly otherwise.
• 1.9 It is necessary for us to collect and process your Personal Data. If you do not provide us with your Personal Data, or do not consent to this Notice or any amendments to this Notice, we may not be able to render all services to you and you may be required to terminate your relevant agreement with us and/or stop accessing or using the Platform and/or Services.

The Personal Data We Collect From You

• 2.1 During the course of your use of the Platform and the provision of the Services, we may collect Personal Data from you, which includes but is not limited to:
  • (a) Identity data, such as your name, identity number, gender, profile picture, date of birth;
  • (b) Contact data, such as billing address, delivery address, email address and phone numbers;
  • (c) Account data, such as bank account and payment details;
  • (d) Transaction data, such as details about payments to and from you, and other details of products and Services you have purchased from us;
  • (e) Technical data, such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Platform;
  • (f) Profile data, such as your username and password, purchases or orders made by you, your interests, preferences, feedbacks and survey responses;
  • (g) Usage data, such as information on how you use the Platform, products and Services or view any content on the Platform;
  • (h) Location data, such as when your device uses Global Positioning System (GPS) data or when your device communicate with cell towers, Wi-Fi routers or access points and/or with other technologies, including the satellites and other location information;
  • (i) Biometric data, such as image of your identity document, voice files, and facial images when you upload videos of yourself to the Platform;
  • (j) Marketing and communications data, such as your preferences in receiving marketing from us, additional information for winning of contests, and our third parties and your communication preferences; and
  • (k) Beneficiary data, such as beneficiary’s name, identity number, gender, relationship, mailing address, contact numbers and bank account.
• 2.2 During the course of your use of the Platform and the provision of the Services, we may receive Personal Data from you in the following situations:
  • (a) When you create an account with us;
  • (b) When you apply for any of the Services or purchase any products available on the Platform;
  • (c) When you use any of the features or functions available on the Platform or Services, including the recording of any user-generated content to be uploaded on the Platform, and registering and managing of the products;
  • (d) When you subscribe to our publications or marketing collaterals;
  • (e) When you enter a competition, promotion or survey;
  • (f) When you participate in any activity or campaign on the Platform;
  • (g) When you log in to your account on the Platform or otherwise interact with us via an external service or application, such as Facebook or Google;
  • (h) When any other user of the Platform posts any comments on the content you have uploaded on the Platform or when you post any comments on other users’ content uploaded to the Platform;
  • (i) When a third party lodges a complaint against you or the content you have posted on the Platform; and
  • (j) When you access or use mobile games using our Services; and
  • (k) When you interact with us online and offline, including when you interact with our in-house or outsourced customer service agents.
• 2.3 During the course of your use of the Platform and the provision of the Services, we may also receive your Personal Data from third parties for the purposes set out in this Notice or any other terms.
• 2.4 You must only submit Personal Data which is accurate and not misleading and you must keep it up to date and inform us of any changes to the Personal Data you have provided to us. We shall have the right to request for documentation to verify the Personal Data provided by you as part of our customer verification processes.
• 2.5 We will only be able to collect your Personal Data if you voluntarily submit the Personal Data to us or as otherwise provided for under this Notice. Unfortunately, if you choose not to submit your Personal Data to us or subsequently withdraw your consent to our use of your Personal Data, we may not be able to provide you with the Services or access to the Platform.
• 2.6 You may access and update your personal information submitted to us at any time as described in Clause 5 below.
• 2.7 If you provide the Personal Data of any third party to us, you represent and warrant that you have obtained the necessary consent from that third party to share and transfer his/her Personal Data to us, and for us to collect, use and disclose that data in accordance with this Notice.

Use and Disclosure of Personal Data

• 3.1 The Personal Data we collect from you or via third parties may be used by us, or shared with or transferred to third parties (including related companies, third party service providers and their service providers and related companies, third party agents, and companies located both inside and outside your home country), for certain purposes, which include but are not limited to the following:
  • (a) To facilitate your use of the Services or access to the Platform, including responding to your queries, feedback, claims or disputes through our in-house and outsourced customer service agents;
  • (b) To process orders you have submitted through the Platform;
  • (c) To process payments that you make through the Platform for our products, whether sold by us or a third party agent that will be processed by our agent;
  • (d) To deliver the products you have purchased through the Platform whether sold by us or a third party agent. We may pass your personal information on to a third party in order to make delivery of the product to you (for example to our courier or supplier);
  • (e) To update you on the delivery of the products, whether sold through the Platform by us or a third party seller, and for customer support purposes;
  • (f) To compare information, and verify with third parties in order to ensure that the information is accurate;
  • (g) To administer your account with us;
  • (h) To verify and carry out financial transactions in relation to payments you make online;
  • (i) To audit the downloading of data from the Platform;
  • (j) To improve the layout or content of the pages of the Platform and customise them for users;
  • (k) To identify visitors on the Platform;
  • (l) To carry out research on our users’ demographics and behaviour;
  • (m) To audit and conduct necessary actions in relation for the purpose of managing and administering the use of services, products and standard operation procedures on the Platform;
  • (n) To provide you with information we think you may find useful or which you have requested from us, including information about our or third party agents’ products and services, provided you have indicated that you have not objected to being contacted for these purposes;
  • (o) To allow other users to identify you via the "Find Agent" (or similar function) as a user of the Service, to allow you to find other users and to connect with them on the Platform, and to support the socializing function of the Services;
  • (p) To promote the Services and use the information that you give to us, such as user-generated content (including video content) that you can choose to broadcast on our Platform, as part of our advertising and marketing campaigns to promote the Platform;
  • (q) To process any complaints, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Platform;
  • (r) To display on scoreboards on the Platform in relation to campaigns, mobile games or any other activity;
  • (s) To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
  • (t) We may also use your personal information to send you marketing or promotional materials about our products and services from time to time, unless you choose to opt-out from receiving these materials; and
  • (u) We may also conduct automated-decision making processes in accordance with any of these purposes.
• 3.2 You may unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies.
• 3.3 In exceptional circumstances, we may be required to disclose personal information, such as when there are grounds to believe that the disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes, or for fulfillment of legal and regulatory requirements and requests.
• 3.4 We may share and permit the sharing of your personal data with third parties and our affiliates for any of the above mentioned purposes, including but not limited to, facilitating your use of the Services, completing a transaction with you, managing your account and our relationship with you, marketing and fulfilling any legal or regulatory requirements and requests as deemed necessary by us. In sharing your personal data with them, we endeavor to ensure that the third parties and our affiliates keep your Personal Data secure from unauthorized access, collection, use, disclosure, processing or similar risks, retain your Personal Data only for as long as they need your Personal Data to achieve the above mentioned purposes, and to deal with the Personal Data only in accordance with this Notice. Our affiliates and the said third parties cannot use the Personal Data that we shared with them for their own purposes and must delete or return the Personal Data to us once they have fulfilled their purposes in relation to the use of the Personal Data.
• 3.5 We may also use, share and/or transfer your Personal Data across our Platform(s) and Services, including but not limited to new websites and applications which are owned and operated by us to facilitate your use of and access to the Services.
• 3.6 If you are located in Malaysia, we may transfer or permit the transfer of your personal data outside of Malaysia for any of the purposes set out in this Notice.
• 3.7 By providing us with Personal Information or using our services on our Mobile App or Website, you consent to the transfer, storage and processing of Personal Information to where our (or our contractors, vendors and/or service providers) servers, data centres, database(s) and/or system facilities are located and/or operated, which may be outside your country of domicile or the location where you access our Mobile App or Website to provide Personal Information, and which may include, among others, Malaysia, Asia countries, Australia, the United States, the United Kingdom and the European Union.
• 3.8 When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.
• 3.9 Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of the safeguards permissible by laws.

Withdrawal of Consent to Continued Use, Disclosure and/or Processing of Personal Data

• 4.1 When you are signed in to our Services, you can always review and update your information and preferences by visiting the Platform and/or Services you use.
• 4.2 You may communicate the withdrawal of your consent to the continued use, disclosure, transfer and/or processing of your Personal Data including Personal Data relating to others who may be identified from that Personal Data for any of the purposes and in the manner as stated above at any time, by contacting us at [email protected].
• 4.3 Please note that if you communicate your withdrawal of your consent to our use, disclosure or processing of your Personal Data for the purposes and in the manner as stated above, we may not be in a position to continue to provide the Services to you or perform on any contract we have with you, and we will not be liable in the event that we do not continue to provide the Services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.

Updating Your Personal Data

• 5.1 It is important that the Personal Data you provide to us is accurate and complete for you to continue using the Platform and for us to provide the Services. You are responsible for informing us of changes to your Personal Data, or in the event you believe that the Personal Data we have about you is inaccurate, incomplete, misleading or out of date.
• 5.2 You can update your Personal Data at any time by accessing your account on the Platform. If you are unable to update your Personal Data through your account, you can do so by contacting us at [email protected].
• 5.3 We take steps to share the updates to your Personal Data with third parties and our affiliates with whom we have shared your Personal Data if your Personal Data is still necessary for the above-stated purposes.

Accessing Your Personal Data

• 6.1 If you would like to request information about your Personal Data which we have collected, or enquire about the ways in which your Personal Data may have been used, disclosed, transferred or processed by us within the past year, please contact us at [email protected]. In order to facilitate the processing of your request, it may be necessary for us to request further information relating to your request.
• 6.2 We reserve the right to charge a reasonable administrative fee for retrieving your Personal Data records. If so, we will inform you of the fee before processing your request.
• 6.3 We will respond to your request as soon as reasonably possible. If we are unable to respond to your request within forty-five (45) days from the date of your request, we will inform you in writing. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable data protection laws).

Security of Your Personal Data

• 7.1 To safeguard your Personal Data from unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
  • (a) Restricting access to Personal Data to individuals who require access;
  • (b) Maintaining technology products to prevent unauthorised computer access; and
  • (c) Using 128-bit SSL (secure sockets layer) encryption technology when processing your financial details.
• 7.2 If you believe that your privacy has been breached by HaloGo, please contact us at [email protected].
• 7.3 You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
• 7.4 Your password is the key to your account. Please use unique numbers, letters and special characters, and do not share your Platform’s password to anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your password, you may lose substantial control over your Personal Data and other data submitted to HaloGo. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us at [email protected] and change your password. If you are using a shared device, you are reminded to log out of your account, clear the history of the application and/or website including but not limited to the cache and cookies, and close the application and/or website when you are finished with using a shared device.

Retention of Personal Data

• 8.1 We will only retain your Personal Data for as long as we are either required to by law or as is relevant for the purposes for which it was collected.
• 8.2 We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the Personal Data was collected, and is no longer necessary for any legal or business purposes.
• 8.3 You may request deletion of your account in this platform by accessing account settings or similar functions available or by emailing us at [email protected]. Deleting your user account will remove data associated with your account’s functionality within the Platform. The account deletion is irreversible once it is final. We may retain some personal information as necessary to comply with our legal and compliance obligations, to resolve disputes and enforce our agreements.

Children and Minors Under 12 Years of Age

• 9.1 HaloGo does not sell products for purchase by children under 12 years of age, nor does it intend to provide any of the Services or the use of the Platform to children under 12 years of age. We do not knowingly collect any Personal Data relating to children under 12 years of age.
• 9.2 You hereby confirm and warrant that you are currently 12 years old or above and you are capable of understanding and accepting the terms of this Notice. If you are under 12 years old, you may use our Platform only with the involvement of a parent or guardian.
• 9.3 As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to HaloGo. In the event that such Personal Data of a minor is disclosed to HaloGo, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Notice and take responsibility for his or her actions.
• 9.4 We will not be responsible for any unauthorised use of the Services on the Platform by yourself, users who act on your behalf or any unauthorised users. It is your responsibility to make your own informed decisions about the use of the Services on the Platform and take necessary steps to prevent any misuse of the Services on the Platform.

Collection of Computer Data

• 10.1 We or our authorised service providers may use cookies, web beacons, and other similar technologies for storing data to help provide you with a better, faster, safer and personalised experience when you use the Services or access the Platform.
• 10.2 When you visit the Platform through your computer, mobile device, or any other device with internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website. This data may include but not be limited to:
  • (a) Your computer or device's IP address;
  • (b) Browser type;
  • (c) Webpage you were visiting before you came to the Platform;
  • (d) The pages within the Platform which you visit; and
  • (e) The time spent on those pages, items and data searched for on the Platform, access times and dates, and other statistics.
• 10.3 This data is collected for analysis and evaluation in order to help us improve our website and the services and products we provide.
• 10.4 Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognize a particular device or browser and help us to personalise the content to match your preferred interests more quickly, and to make the Services and the Platform more convenient and useful to you.
• 10.5 You may be able to manage and delete cookies through your browser or device settings. For more information on how to do so, visit the help material of your browser or device.
• 10.6 Web beacons are small graphic images that may be included on our Service and the Platform. They allow us to count users who have viewed these pages so that we can better understand your preference and interests.

Halo Go's Right to Disclose Personal Data

• 11.1 You acknowledge and agree that HaloGo has the right to disclose your Personal Data to any legal, regulatory, governmental, tax, law enforcement or other authorities or the relevant right owners, if HaloGo has reasonable grounds to believe that disclosure of your Personal Data is necessary for the purpose of meeting any obligations, requirements or arrangements, whether voluntary or mandatory, as a result of cooperating with an order, an investigation and/or a request of any nature by such parties. To the extent permissible by applicable law, you agree not to take any action and/or waive your rights to take any action against HaloGo for the disclosure of your Personal Data in these circumstances.

Third Party Sites

• 12.1 The Platform may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.