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1.1 SSAM (referred to here as “SSAM”, “we”, “us” or “our”) is owned and operated by SSAM Management Sdn. Bhd. SSAM is dedicated to safeguarding the privacy and security of your personal data.

1.2 This Privacy Policy (“Policy”) explains how we collect, maintain, use, disclose, and protect your personal data (as defined in the Personal Data Protection Act 2010) as well as the personal data of any third party individual you are required to provide when using our websites (the “Platform”), including when you purchase a product or service, download our e-documents, or subscribe to our newsletter (“Personal Data”). It also explains your rights and how the law protects you.

2.1 At SSAM, we value your privacy and strive to protect your Personal Data as provided by you when using the Platform, in compliance with Malaysian laws.

2.2 Before using our services, please read this Policy in full, as it is intended to help you make informed decisions regarding how we collect and process your Personal Data.

2.3 SSAM will only collect and use your Personal Data in accordance with applicable laws (including the Personal Data Protection Act 2010), this Policy, and/or the privacy terms in any agreement(s) you may have or enter into with SSAM.

2.4 This Policy explains:

2.4.1 the type of Personal Data we collect about you and how we collect it;

2.4.2 how we use your Personal Data;

2.4.3 the parties with whom we may share your Personal Data;

2.4.4 your rights with respect to your Personal Data; and

2.4.5 the choices we offer, including how to access and update your Personal Data.

2.5 By providing us your Personal Data, using our products and/or services and communicating with us, you hereby consent to the processing of your Personal Data in accordance with this Policy.

2.6 If you provide us with information on behalf of someone else, you confirm that the individual has authorised you to act on their behalf and agreed that you may:

2.6.1 provide consent on their behalf to the processing of their Personal Data;

2.6.2 receive any privacy notices on their behalf; and

2.6.3 give consent to the transfer of their Personal Data abroad.

2.7 If you are a user of our Platform, the provision of your Personal Data is voluntary. However, if you choose not to provide your Personal Data, we may be unable to process it for the purposes outlined in this Policy, which may affect our ability to provide our products and/or services to you or accept payments from you.

2.8 If you are an agent, vendor, supplier, service provider, or strategic partner, providing your Personal Data is mandatory, and failure to do so may prevent us from engaging you to provide services and/or products or from issuing payments for services and/or products provided.

3.1 As part of registering for a user account with SSAM and to enable us to handle your enquiries or to provide you with our products and/or services, we may need to collect, record, hold, use, disclose, and store (“process”) Personal Data and financial information about you, including but not limited to:

3.1.1 to establish your personal identification and background; and/or

3.1.2 verifying your financial status and creditworthiness (where required).

3.2 We collect the following personal information from you:

3.2.1 contact details, including your name, email address, postal address, and telephone number;

3.2.2 personal identification information (e.g. identity card number or passport number);

3.2.3 nationality;

3.2.4 age or date of birth;

3.2.5 billing information, residential address and billing address;

3.2.6 information about your business, such as company name, address, business type, owner, directors’ and shareholders’ details;

3.2.7 bank account information, including statements; and

3.2.8 professional title or occupation,

including any other information required by us from time to time for the purposes specified in this Clause 3.

3.3 We may also collect the personal information of third parties when you add the names of directors, shareholders, partners, officers or other beneficiaries in our application forms. Collecting a third party’s personally identifiable information may be necessary to process and register your order for certain products or services.

3.4 The information you provide when you register with us may include data that may identify an individual, such as name, personal identification number, home or office address, email address, phone number, etc. Additionally, it may include business information that relates to personal and business relationships between yourself and other individuals and organisations (“User Data”).

3.5 We may obtain this information from you directly and from a variety of sources, including but not limited to:

3.5.1 through your relationship with us, such as information provided by you in enquiry/application/registration forms, when signing up for a user account with us, when using our products and/or services, when participating in SSAM’s customer surveys, competitions, activities, and promotions, when you contact us by phone, email, or other means, and during financial reviews;

3.5.2 through your verbal and/or written communications with us and/or our authorised agents;

3.5.3 through any photos/videos collected by us and/or our authorised agents;

3.5.4 from third parties connected with you, such as your partners, directors, shareholders, employers, employees, joint account holders, guarantors, subject to your prior consent;

3.5.5 from an analysis of the way you use and manage your account(s) with us; and/or

3.5.6 from other sources where you have consented to disclose information relating to you and/or where such disclosure is not restricted.

4.1 In addition to the uses specified above, we may use your Personal Data for one or more of the following purposes:

4.2 If you are a user of the Platform:

4.2.1 to fulfil our contractual obligations with you;

4.2.2 to manage your user account;

4.2.3 to send invoices and receipts;

4.2.4 to evaluate your order for any of our products and/or services;

4.2.5 to provide you with any products and/or services you have purchased;

4.2.6 to process your subscriptions and to deliver the products and/or services to you;

4.2.7 to handle payments related to purchased products and/or services;

4.2.8 to verify your financial standing through credit reference checks;

4.2.9 to manage and maintain your relationship with us;

4.2.10 to provide you with information on our and/or third-party’s products, services and offers which may be of interest to you;

4.2.11 to improve our products and/or services and to develop new products and/or services;

4.2.12 to inform you of benefits and updates to our products, services, and/or Platform;

4.2.13 to notify you of software updates that affect products and/or services provided by us;

4.2.14 to process your participation in any offers, competitions, events, activities, contests, polls, surveys or promotions; and/or

4.2.15 to utilise Cookies (as defined herein) to enhance our processes, advertising, notifications, authentication, security and compliance, analytics, and/or preference management.

4.3 If you are an agent, vendor, supplier, service provider, or strategic partner:

4.3.1 for the purpose of engaging you to supply products and/or services to us or our users;

4.3.2 to facilitate any necessary checks before engagement;

4.3.3 to handle payments related to the products and/or services you have supplied;

4.3.4 to verify your financial standing through credit reference checks;

4.3.5 to provide you with personalised feedback, enabling specific areas for improvement; and/or

4.3.6 to contact you in relation to the provision of your products and/or services.

4.4 General:

4.4.1 to respond to your enquiries, feedback and complaints;

4.4.2 to enhance the quality, efficiency, and use of SSAM’s services;

4.4.3 to maintain, update, consolidate and improve the accuracy of our database records;

4.4.4 to create data, reports, and statistics that are anonymised or aggregated to avoid identifying individuals;

4.4.5 to conduct data analysis, including data mining and analysis of your transactions with us;

4.4.6 to fulfil legal disclosure obligations binding on SSAM;

4.4.7 for audit, compliance and risk management purposes;

4.4.8 to evaluate financial and insurance risks;

4.4.9 to transfer or assign our rights, interests and obligations under any of your agreement(s) with us;

4.4.10 to protect or enforce our rights to recover any debt owing to us;

4.4.11 to maintain the safety and security of our services;

4.4.12 for crime detection, prevention and prosecution;

4.4.13 to detect, prevent and address any technical issues arise from our services; and/or

4.4.14 for any other purpose that is required or permitted by any law, regulations and/or guidelines.

4.5 We have the right to use your photos, images and recordings for our marketing, advertising and publicity purposes without any payment of royalty or image fees to you. We may also publish your name and photo on the Platform at our sole and absolute discretion when you become a winner in a contest which you participate in that we may from time to time organise. If you do not agree to such use, please write to us.

4.6 We will obtain your separate consent for any other purposes not included within the purposes stated above.

5.1 As part of providing our products and/or services and managing and/or operating the same, we may disclose your Personal Data (to the extent required) to the following third parties:

5.1.1 companies and/or organisations that serve as our service providers, strategic partners, and/or licensors;

5.1.2 companies and/or organisations that assist us in delivering value-added services that you have requested;

5.1.3 your advisers (including, but not limited to, accountants, valuers, adjustors, auditors, tax consultants, solicitors, bankers, financial advisers, or other professional advisers) authorised by you;

5.1.4 any person notified by you as authorised to give instructions or to use the account(s) or products and/or services on your behalf;

5.1.5 any rating agency, insurer or insurance broker or direct or indirect provider of credit protection;

5.1.6 any financial institutions, merchants, e-wallet service providers, VISA International Services Association, MasterCard International Incorporated and other card associations in relation to any credit card and/or debit card issued to you;

5.1.7 any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us;

5.1.8 Immigration Department, Companies Commission of Malaysia and their appointed agencies; foreign embassies, consulates and their appointed agencies; and other relevant government departments/agencies, statutory authorities and industry regulators in connection with any investigation or enquiries;

5.1.9 fraud and crime prevention agencies to assess the risk of crime, fraud, and money laundering, which is a condition of us entering into any contract with you;

5.1.10 our IT service providers who supply technical infrastructure services, software and development work, analyse how our services are used, or provide customer service to you; and/or;

5.1.11 other parties in respect of whom you have given your express or implied consent.

5.2 With your permission, we may disclose your User Data (and any associated Personal Data) through our service to a third party. If you authorise this disclosure, the restrictions on use and disclosure in this Policy will not apply to such third parties. We do not control the privacy practices of any third parties.

5.3 Although we currently have no affiliates, if we acquire any in the future, we may disclose your Personal Data to a parent company, any subsidiaries, or other companies under common control (collectively, “Affiliates”), and we will require our Affiliates to honour this Policy.

5.4 Your Personal Data may also be disclosed as part of any merger, acquisition, joint venture, debt financing, sale of SSAM or its business assets, as well as in the event of insolvency, bankruptcy, or receivership, where Personal Data could be transferred to third parties as one of our business assets. In such cases, we will endeavour to notify you before your Personal Data is transferred, but you may not have the right to opt out of or object to any such transfer.

5.5 Clauses 5.1 and 5.2 are, at all times, subject to any applicable laws (including regulations, standards, guidelines, and/or obligations) to SSAM, whether inside or outside Malaysia.

6.1 If you have granted permission, we may contact you by post, telephone, SMS, text/picture/video online instant messaging, email, or other means of correspondence about our, our strategic partners’, sponsors’, or advertisers’ products, services, promotions, special offers, events, or activities that may be of interest to you.

6.2 We do not and will not disclose, rent, sell or otherwise make available your Personal Data to third parties for direct marketing purposes.

6.3 You may opt out at any time if you prefer not to receive marketing communications, notifications, and materials from us.

6.4 You may select whether to continue receiving newsletters, updates, promotional materials, festive greetings, or other communications. Additionally, you may “opt out” of any category of subscription, marketing, or promotional email from us by following the unsubscribe instructions or using the unsubscribe links in the emails we send to you. However, as long as you remain a user with us, you may not “opt out” of receiving user-related notifications and materials from us.

In addition to the situations outlined above, we will treat your Personal Data as private and confidential and will not disclose it to anyone except in the following situations:

7.1.1 when you have given permission for us to disclose your Personal Data according to this Policy;

7.1.2 when required or permitted by law;

7.1.3 when required or authorised by any order of court, tribunal, or authority, whether governmental or quasi-governmental, with jurisdiction over SSAM;

7.1.4 when we may transfer rights and obligations under this Policy; and/or

7.1.5 when we are required to fulfil our obligations to any relevant regulatory authority.

8.1 Where indicated, it is necessary for you to provide your Personal Data to allow us to process your application for our products and/or services. Should you choose not to provide the required Personal Data, we may be unable to process your application/request or provide you with our products and/or services.

8.2 You confirm that all your Personal Data is true, accurate and complete and that none of the Personal Data provided is misleading or outdated. If your Personal Data changes, you will promptly notify us of any such changes.

9.1 We can assist you in accessing and correcting your Personal Data provided to us, subject to the following conditions:

9.1.1 You may access your Personal Data by submitting a request to enquiries@ssam-group.com, subject to payment of the relevant processing fee (if applicable). We will make reasonable efforts to provide a copy of the requested Personal Data within twenty-one (21) days of receiving your completed Access Request Form and the processing fee.

9.1.2 Please note that SSAM may have to withhold access to your Personal Data in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential nature or in the event where we receive repeated requests for the same information. However, we will notify you of the reasons for not being able to fulfil your request.

9.1.3 If your data access request is successful and 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 correct such Personal Data.

9.1.4 You may also assist us in keeping your Personal Data (such as your current mailing address) up-to-date, which will enable us to serve you better.

9.1.5 If you wish to correct or update the Personal Data you have previously provided, you may write to us or notify us at the address provided in Clause 9.1. We will make reasonable efforts to comply with your request to correct your Personal Data within twenty-one (21) days of receiving your written request.

9.1.6 Please note that SSAM may exercise discretion in allowing the correction or update requested or may require further documentary evidence of the new information to avoid fraud and inaccuracies.

Subject to our contractual rights and obligations under relevant laws and regulations, you may exercise your choice regarding the disclosure, retention, and use of your Personal Data by SSAM. Should you wish to do so, please contact us at:

10.1.1 Tel: +6011-1880 1285

10.1.2 Email: enquiries@ssam-group.com

Your Personal Data may be transferred to, stored, used, and processed in a jurisdiction other than your company’s country of incorporation, your home country, or the country, state, or city in which you are located while using any SSAM-provided services (“Alternate Country”), to companies located outside your home country or Alternate Country and/or where SSAM’s servers and/or service providers and partners are located outside of your home country or Alternate Country. You understand and consent to the transfer of your Personal Data outside your home country or Alternate Country as described here.

12.1 SSAM, its affiliates, licensors, and third-party partners may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes referred to as “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID), and similar technology (“Cookies”) in connection with your use of the Platform. Cookies may have unique identifiers and may be stored, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of our products and/or services, such as your browser type, search preferences, IP address, data on advertisements displayed to you or clicked on, and the date and time of your usage. Cookies may be persistent or stored only for the duration of a session.

12.2 SSAM may permit third parties to use Cookies on the Platform to collect the same type of information for the same purposes as SSAM. Third parties may associate the information they collect with other information they have about you from other sources. We do not bear responsibility for, nor do we have access to or control over, the Cookies they use.

12.3 Additionally, we may share non-personally identifiable information about you with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to enable targeted advertising.

12.4 If you do not wish for your Personal Data to be collected via Cookies on the Platform, you may deactivate Cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also be able to limit our sharing of some of these information through your mobile device settings.

The Platform may include links to websites operated by third parties. Please be aware that SSAM is not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information directly to these sites, the privacy policies and terms of service of those sites will apply, and SSAM shall bear no responsibility for the data processing practices or privacy policies of these sites.

14.1 As a parent or legal guardian, you are responsible for ensuring that a minor (any individual under eighteen (18) years of age) under your care does not submit personal data to SSAM independently. In the event that such data is provided to SSAM, you hereby consent to the processing of the minor’s personal data, personally accept and agree to be bound by this Policy, and assume responsibility for his or her actions.

14.2 In some circumstances where you may have provided Personal Data relating to other individuals (such as your spouse, family members, friends, business partners, shareholders or directors), in such circumstances you represent and warrant that you are authorised to provide their personal data to SSAM and you have obtained their consent for their Personal Data be processed and used in the manner as set forth in this Policy.

Should you have any queries, concerns or complaints in relation to this Policy or how we handle your Personal Data, kindly contact us at:

15.1.1 Tel: +6011-1880 1285

15.1.2 Email: enquiries@ssam-group.com

16.1 SSAM reserves the right to modify, update, or amend the terms of this Policy at any time by posting the updated Policy on the Platform. By continuing to communicate with SSAM or use SSAM’s products and/or services following any modifications, updates, or amendments to this Policy, you acknowledge that such actions constitute your acceptance of these modifications, updates, or amendments.