Collection of Personal Data
“Personal Data” means information about you, from which you are identifiable, including but not limited to your name, nationality, address, telephone number, fax number, bank details, credit card details, gender, resident status, financial background, email address, company details, your photo, any information about you and your company which you have provided to TRACTIVE in registration forms, application forms or any other similar forms and/or any information about you and your company that has been or may be collected, stored, used and/or processed by TRACTIVE from time to time and includes sensitive personal data such as your identification card number, passport number, business documents, race, ethnic origin, education background, and data relating to health, religious or other similar beliefs.
The provision of your Personal Data is voluntary. However, if you do not provide TRACTIVE your Personal Data, TRACTIVE will not be able to process your Personal Data for the Purposes and Additional Purposes outlined below and may cause TRACTIVE to be unable to provide services or products to or accept payments from you.
In addition to the Personal Data you provide to TRACTIVE directly, TRACTIVE may collect your Personal Data from publicly available sources or from third parties, for example:
by using TRACTIVE apps and websites, which includes all apps and websites operated by TRACTIVE and under the names of its respective brands (respectively “Apps” and “Websites”). Your personal data may also be collected from cookies used on the Websites.
Purposes of Processing
TRACTIVE may use and process your Personal Data for business transactions, payment and financial services activities of TRACTIVE which shall include, without limitation the following (“Purposes”):
Where you are a customer of the services provided by TRACTIVE:
and you agree and consent to TRACTIVE using and processing your Personal Data for the Purposes and in the manner as identified in this Policy.
Marketing and Promotional Purposes
TRACTIVE may also use and process your data for other purposes such as (“Additional Purposes”):
by way of post, telephone call, short message service (SMS), online messaging service, by hand and/or by email.
Unsubscribe and Revocation of Consent
If you wish to unsubscribe to the processing of your Personal Data for Additional Purposes by TRACTIVE, please click on the link “Unsubscribe” which is embedded in the relevant email or message in order not to receive any such messages in the future. Please note that if you unsubscribe, we may still send you product and subscription-related messages, such as tax invoices.
If you wish to revoke the consent that TRACTIVE has obtained from you for the Purposes stipulated herein, please notify TRACTIVE using the contact details stated below.
Transfer of Personal Data
Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than your home nation or otherwise in the country, state and city in which you are present while using any services provided by TRACTIVE (“Alternate Country”), to companies under TRACTIVE which are located outside of your home nation or Alternate Country and/or where TRACTIVE’s servers and/or service providers and partners are located outside of your home nation or Alternate Country. You understand and consent to the transfer of your Personal Data out of your home nation or Alternate Country as described herein.
Disclosure to Third Parties
Your personal data may be transferred, accessed or disclosed to third parties for the Purposes and Additional Purposes. Further, TRACTIVE may engage other companies, service providers or individuals to perform functions on its behalf, and consequently may provide access or disclose to your Personal Data to such service providers or third parties. The third parties include, without limitation:
Your Personal Data may also be shared in connection with a corporate transaction, such as the formation of a joint venture, a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up.
Access & Correction Requests and Inquiries, Limiting the Processing of Personal Data
Subject to any exceptions under applicable laws of your home nation or Alternate Country, you may request for access to and/or request correction of your Personal Data, request to limit the processing of your Personal Data for the Additional Purposes and/or make any inquiries regarding your Personal Data by contacting:
Tractive Data Protection Officer
Tractive Sdn Bhd
A-2-28, Jalan PJU 1/43, Aman Suria, 47301 Petaling Jaya, Selangor, Malaysia.
Subject to any laws of your home nation or Alternate Country, TRACTIVE reserves the right to impose a fee for access of your Personal Data in the amounts as permitted therein.
In respect of your right to access and/or correct your Personal Data, TRACTIVE has the right to refuse your requests to access and/or make any correction to your Personal Data for the reasons permitted under law, such as where the expense of providing access to you is disproportionate to the risks to your or another person’s privacy.
Additionally, we may share non-personally identifiable information from or 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 facilitate the display of targeted advertising.
If you do not wish for your Personal Data to be collected via Cookies on the Websites, 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 this information through your mobile device settings, or by submitting your details here.
Links to Third-Party Websites
Personal Information from Minors and Other Individuals
As a parent or legal guardian, please do not allow the minor (individuals under 18 (eighteen) years of age) under your care to submit Personal Data to TRACTIVE. In the event that such Personal Data is provided to TRACTIVE, you hereby consent to the processing of the minor’s Personal Data and personally accept and agree to be bound by this Policy and take responsibility for his or her actions.
In some circumstances you may have provided Personal Data relating to other individuals (such as your spouse, family members or friends) and in such circumstances you represent and warrant that you are authorized to provide their Personal Data to TRACTIVE and you have obtained their consent for their personal data be processed and used in the manner as set forth in this Policy.
Acknowledgement, Consent, and Data Retention
By communicating with TRACTIVE, using TRACTIVE’s services, purchasing products from TRACTIVE or by virtue of your engagement with TRACTIVE, you acknowledge that you have read and understood this Policy and agree and consent to the use, processing and transfer of your Personal Data by TRACTIVE as described in this Policy.
TRACTIVE shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to communicate with TRACTIVE, by continuing to use TRACTIVE’s services, purchasing products from TRACTIVE or by your continued engagement with TRACTIVE following the modifications, updates or amendments to this Policy, such actions shall signify your acceptance of such modifications, updates or amendments.
In the event of any conflict between the English and other language versions, the English version shall prevail.
© Tractive 2022