Privacy Policy

This Privacy Policy was last updated on 21 December 2020.

Introduction
RockAcc Solutions Sdn Bhd is referred to in this Privacy Policy as “we”, “us”, or “our”. We are a privacy conscious organisation and this Privacy Policy explains how we protect visitors’ information gathered via this Website.

To process, administer and/or manage your relationship with us, we will necessarily need to collect, use, disclose and/or process your personal data and/or personal data provided by you. We will only process your personal data in accordance with the Personal Data Protection Act 2010, the applicable regulations, guidelines, orders made under the Personal Data Protection Act 2010 and any statutory amendments or re-enactments made of the Personal Data Protection Act 2010 from time to time (collectively referred to as the “PDPA”) as well as this Privacy Policy.

By using this Website you are agreeing to the use of your information as described in this Privacy Policy.

If you have any questions regarding this Privacy Policy, please contact webmaster services using the email address in the Contact page.

If you are a corporate entity/an organisation, references to the term “you” and “your” shall also include your employees, representatives and agents.

Information collection
As a visitor, you do not have to submit any personal information in order to use the Website. This Website only collects personal information that is specifically and voluntarily provided by visitors for the purpose the personal information is collected. Such information may consist of, but is not limited to, your name, current job title, company address, email address and telephone and fax numbers. Do not provide personal information to us, unless you consent to our use of that information for its legitimate business purpose.

We may also store and maintain any content that you provide, including but not limited to postings on any blogs, forums, wikis and other social media applications and services that we may provide.

We do not usually seek sensitive information (e.g., data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation) from visitors. We will, where necessary, obtain your explicit consent to collect and use such information.

Personal Data Collection
The term “personal data” means any information in our possession or control that relates directly or indirectly to an individual to the extent that the individual can be identified or are identifiable from that and other information in our possession such as name, address, telephone number, email address, fax number, NRIC No, date of birth, email address, job title, etc. The types of personal data collected depend on the purpose of collection. We may “process” your personal data by way of collecting, recording, holding, storing, using and/or disclosing it.
Your personal data may be collected from you during your course of dealings with us in any way or manner including pursuant to any transactions and/or communications made from/with us. We may also collect your personal data from a variety of sources, including without limitation, at any meetings, events, seminars, conferences, talks, road shows, customer satisfaction surveys organised and/or sponsored by us and/or other affiliated companies, as well as from publicly available sources.

In addition, we may also receive, store and process your personal data which are provided or made available by any third parties, credit reference bodies, regulatory and law enforcement authorities, for reasons including delivery of our services, performance of conditions of agreements and/or to comply with our legal and regulatory obligations. We may also store and maintain any content that you provide, including but not limited to postings on any blogs, forums, wikis and other social media applications and services that we may provide.

Purpose of Personal Data Collected
We may collect, use and process your personal data and/or personal data furnished by you for the following purposes (collectively referred to as the “Purposes”):

• to assess, process and provide services to you;
• to facilitate, process, deal with, administer, manage and/or maintain your relationship with us;
• to consider and/or process your application/transaction with us;
• to respond to your enquiries or complaints or resolve any issues and disputes which may arise in connection with any dealings with us;
• to administer and process any payments related to services requested by you;
• to facilitate your participation in, and our administration of, any events including meetings, seminars, conferences, talks, road shows, contests or campaigns;
• to facilitate your participation or posting of any contents in any forums, bulletin boards, discussions, blogs, wikis and other social media applications and services that we may provide;
• to conduct credit reference checks and establish your credit worthiness, where necessary, in providing you with our services;
• to carry out due diligence or other monitoring or screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that may have been put in place by us;
• to administer and give effect to your commercial transactions with us;
• to process any payments related to your commercial transactions with us;
• to provide you with information and/or updates on services offered by us and/or events, conferences, talks and seminars organised by us and selected third parties which may be of interest to you from time to time by phone call, email, fax, mail, social media and/or any other appropriate communication channels;
• to provide you with reference materials through any appropriate communication channels including to allow you to download publications or documents from this Website;
• to send you seasonal greetings messages, corporate gifts and newsletters from time to time;
• to send you invitation to join our events, promotions, mailing lists as well as conferences, talks and seminars;
• to monitor, review and improve our events and services;
• to process and analyse your personal data either individually or collectively with other individuals;
• to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our services;
• to share any of your personal data with the auditor for our internal audit and reporting purposes;
• to share any of your personal data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
• to share any of your personal data with a third party necessary for the preparation of legal documents or contract to be entered by you;
• to maintain and improve customer relationship;
• to maintain and update internal record keeping, files and contact lists;
• to detect, investigate and prevent any fraudulent, prohibited or illegal activity or omission or misconduct;
• to enable us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
• to transfer or assign our rights, interests and obligations under any agreements entered into with us;
• to meet any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;
• to comply with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies, ministries, statutory bodies or other similar authorities;
• to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
• for direct marketing purposes via phone call, email, fax, mail, social media and/or any other appropriate communication channels;
• for internal administrative purposes;
• for audit, risk management and security purposes;
• for our storage, hosting back-up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Malaysia; and/or
• for other purposes required to operate, maintain and better manage our business and your relationship with us,

and you agree and consent to us using and processing your personal data for the Purposes in the manner as identified in this Privacy Policy. If you do not consent to us processing your personal data for one or more of the Purposes, please notify us at the contact details below.

We will seek your separate consent for any other purposes which do not fall within the categories stated above.

Consequences of Not Consenting to this Privacy Policy
The collection of your personal data by us may be mandatory or voluntary in nature depending on the Purposes for which your personal data is collected. Where it is mandatory for you to provide us with your personal data, and you fail or choose not to provide us with such data, or do not consent to the above or this Privacy Policy, we will not be able to provide our services or otherwise deal with you, if at all.

Log information and Cookies
Cookies may be used on some pages of our site. “Cookies” are small text files placed on your hard drive that assist us in providing a smoother website experience. It is our policy to use cookies to make navigation of our websites easier for visitors and to facilitate efficient navigation experience. Site statistics are compiled by third parties, and therefore your IP address will be passed to third parties for statistical reporting only.

Where we collect information through our website, we automatically collect certain non-personal information regarding website use that does not identify you including but not limited to Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time of your access to the website, the operating system you are using, the sections of the website you visit, the content you download from website and the internet address of the website from which you linked directly to this website. We may use non-personal information to compile tracking information reports regarding site user demographics and site traffic patterns. None of the tracking information in the reports can be connected to your identities.

If you are concerned about cookies, most browsers permit individuals to decline cookies by changing the privacy settings on your browser. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.

In order to properly manage our website we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters. This is to ensure that our website presents the best web experience for visitors and is an effective information resource.

Disclosure of Personal Data to Third Parties
We will not sell, rent, transfer or disclose any of your personal data to any third party without your consent. However, we may disclose your personal data to the following third parties, for one or more of the above Purposes:

• your immediate family members and/or emergency contact person as may be notified to us from time to time;
• successors in title to us;
• any person under a duty of confidentiality to which has undertaken to keep your personal data confidential which we have engaged to discharge our obligations to you;
• any party in relation to legal proceedings or prospective legal proceedings;
• our auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our business on a strictly confidential basis, appointed by us to provide services to us;
• any party nominated or appointed by us either solely or jointly with other service providers, for purpose of establishing and maintaining a common database where we have a legitimate common interest;
• data centres and/or servers located within or outside Malaysia for data storage purposes;
• storage facility and records management service providers;
• payment channels including but not limited to banks and financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to us in connection with our services;
• government agencies, law enforcement agencies, courts, tribunals, regulatory/professional bodies, industry regulators, ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities;
• our business partners, third-party service providers, vendors, contractors or agents, on a need to know basis, that provide related services in connection with our business, or discharge or perform one or more of the above Purposes and other purposes required to operate and maintain our business;
• financial institutions and merchants in connection with your commercial transactions with us;
• the general public when you become a winner in a contest, participate in our events, conferences, talks and seminars by publishing your name, photographs and other personal data without compensation for advertising and publicity purposes;
• any third party (and its advisers/representatives) in connection with any proposed or actual reorganisation, merger, sale, consolidation, acquisition, joint venture, assignment, transfer, funding exercise or asset sale relating to any portion of RockAcc Solutions Sdn Bhd; and/or
• any other person reasonably requiring the same in order for us to operate and maintain our business or carry out the activities set out in the Purposes or as instructed by you.

We recognise that your personal data is valuable and we take all reasonable measures to protect your personal data while it is in our care.

Retention
The personal data you submit to us will only be retained for as long as is required for the purposes for which it was collected or as required by law. Your personal data is then destroyed or anonymised from our records and system in accordance with our retention policy in the event your personal data is no longer required for the said purposes unless its further retention is required to satisfy a longer retention period to meet our operational, legal, regulatory, tax or accounting requirements.

Blogs, Forums, Wikis and other Social Media
This Website may host various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data or other information that you contribute to any Social Media Application can be read, collected and used by other users of that Social Media Application over whom we have little or no control. Therefore, we are not responsible for any other user’s use, misuse or misappropriation of any personal data or other information that you contribute to any Social Media Application.

Accuracy of Personal Data
When personal data is collected by us, we assume responsibility for keeping an accurate and up-to-date record of your personal data once you have submitted and verified the data. We do not assume responsibility for verifying the ongoing accuracy of the personal data. You will promptly update us in the event of any change to your personal data. If we are informed by you that any of your personal data which we have collected is no longer accurate, we will only make appropriate corrections based on the updated information provided by you. We are committed to providing reasonable and practical access to you for the opportunity to identify and correct any inaccuracies. When requested and practical, we will delete identifying information from current operational systems.

Access to Personal Data
Visitors who have any problem accessing their profiles, or would like to request a copy of their personal data should contact webmaster services using the contact us link. In all cases we will treat requests to access personal data or change personal data in accordance with applicable legal requirements.

Your Rights
In addition to the above, to the extent that the applicable law allows, you have the right to request for access to, request for a copy of, request to update or correct, your personal data held by us. We may charge a small fee (such amount as permitted by the PDPA) to cover the administration costs involved in processing your request to access your personal data. Notwithstanding the foregoing, we reserve our rights to rely on any statutory exemptions and/or exceptions to collect, use and disclose your personal data.

You have the right at any time to request us to limit the processing and use of your personal data (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes).

You also have the right, by notice in writing, to inform us on your withdrawal (in full or in part) of your consent given previously to us subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be effected. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us or the contract that you have with us will have to be terminated.

Information Security
We have, where practicable, put in place reasonable commercial standards of technology and operational security to protect all information provided by you from unauthorised access, disclosure, alteration, or destruction.

The Internet is not a secure medium. However, we have put in place various security procedures with regard to this Website and your electronic communications with us. All our employees and data processors, who have access to, and are associated with the processing of your personal data, are obliged to respect the confidentiality of your personal data.

Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may be routed through a number of countries before being delivered – this is the nature of the World Wide Web/Internet.

We cannot and do not accept responsibility for any unauthorised access or interception or loss of personal data that is beyond our reasonable control.

Cross Border Transfer
Personal data collected by us may be disclosed or transferred to entities located outside Malaysia or where you access this Website from countries outside Malaysia. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in Malaysia under the laws of Malaysia. In addition, our information technology storage facilities and servers may be located in other jurisdictions outside of Malaysia and your personal data may be stored on servers located outside Malaysia. By submitting data to us, you are providing explicit consent for cross border transmission of data collected for the fulfilment of your requests. We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of Malaysia shall not use your personal data other than for that part of the Purposes and to adequately protect the confidentiality and privacy of your personal data.

Changes to this Privacy Policy
We may modify or amend this Privacy Policy from time to time at our discretion with reasonable prior notice to you. We will notify you of any amendments via announcements on this Website or other appropriate means. Please check this Website from time to time to see if there are amendments to this Privacy Policy. When we make changes to this Privacy Policy, we will also amend the revision date at the top of this page. We encourage you to periodically review this Privacy Policy to be informed about how we are protecting your personal data.

Any amendments to this Privacy Policy will be effective upon notice to you. By continuing to communicate with us, use our services, and/or access to this Website after being notified of any amendments to this Privacy Policy, you will be treated as having agreed to and accepted those amendments.

Family and Children’s Privacy Protection
We understand the importance of protecting children’s privacy in the interactive online world. This Website is not designed for or intentionally targeted at minors (under 18 years of age or younger). It is not our policy to intentionally collect or maintain personal data about anyone under the age of 18. To the extent that you have provided (or will provide) personal data of minors or individuals not legally competent to give consent, you confirm that you are the parent or guardian or person who has parental responsibility over them or the person appointed by court to manage their affairs or that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their personal data in accordance with this Privacy Policy.

To the extent that you have provided (or will provide) personal data about your family members, spouse, other dependents (if you are an individual), directors, shareholders, employees, representatives, agents (if you are a corporate entity/an organisation) and/or other individuals, you confirm that you have explained (or will explain) to them that their personal data will be provided to, and processed by us and you represent and warrant that you have obtained their consent to the processing (including disclosure and transfer) of their personal data in accordance with this Privacy Policy.

Questions or Complaints
If you have any questions or concerns regarding your privacy, or have any further queries, or would like to make a complaint or data access or correction request in respect of your personal data, please direct them to webmaster services using the email address in the Contact page or write to us at the contact details below:

Privacy Office
Address: Suite 25.04A, Level 25 Menara Zurich, 15 Jalan Dato’ Abdullah Tahir, 80300 Johor Bahru, Johor
Contact Number: +607 267 0170
Email Address: privacy@rockacc.com