Privacy Policy

Introduction

When will FreedomMall collect Personal Information?

We will collect your Personal Information directly from you:

2.1 when you register and/or use our Services or Platform, or open an account with us; 

2.2 when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services;

2.3 when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services; 

2.4 when you interact with us, such as telephone calls, social media platforms, email including when you interact with our customer service agents; 

2.5 when you use our electronic services, or interact with us via our application or use Services on our Platform. This includes, without limitation, through cookies which we may deploy when you interact with our application or website; 

2.6 when you grant permissions on your device to share information with our application or Platform;

2.7 when you carry out transactions through our Services; 

2.8 when you provide us with feedback or complaints; or

2.9 when you submit your personal data to us for any reason.

What personal information will FreedomMall collect?

3.1 The Personal Information, which we will collect, includes but not limited to: 

3.1.1 Personal Information such as name, surname, age, date of birth, nationality, gender, identification card, passport;

3.1.2 Contact information such as billing and/or delivery address, address as appear on identification card or passport, telephone number, email address;

3.1.3 Bank account and payment information;

3.1.4 Information sent by or associated with the device(s) used to access our Services or Platform; 

3.1.5 Information about your network and the people and accounts you interact with;

3.1.6 Photographs or audio or video recordings;

3.1.7 Government issued identification or other information required for our due diligence, know your customer, identity verification, or fraud prevention purposes; 

3.1.8 Marketing and communications data, such as your preferences in receiving marketing(e.g. Newsletter and Email marketing) from us and third parties, your communication preferences and history of communications with us, our service providers, and other third parties; 

3.1.9 Usage and transaction data, including details about your searches, orders, the advertising and content you interact with on the Platform, and other products and services related to you;

3.1.10 Device information, information of your activity and interactions with the Platform such as IP address, location data;

3.1.11 Any other information about the User when the User signs up to use our Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses our Services or Platform; and 

3.1.12 Any other information which you provide to us in our Platform.

3.2 You agree to submit any information to us which is true and accurate. You agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify the information provided by you. 

3.3 You may withdraw your consent from us to collect, use or process your Personal Information at any time by notifying our Data Protection Officer in writing pursuant to our internal procedures if you do not want us to collect the aforementioned information. However, this may affect your use of the Services and the Platform e.g. your ability to use some features of the Services and the Platform may be limited.

Cookies

We may also collect certain information about Users through the use of “Cookies” and other tracking technologies to enhance the User’s experience. Cookies are small files that a User’s browser places in the User’s computer. These technologies may be used in analyzing trends, administering the Site, remembering Users’ settings (e.g. language preference), and/or tracking Users’ movements around the Site. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still be able to use our Platform, but your ability to use some features or areas of our Platform may be limited.

How do we use the information you provide us?

5.1 We will collect, use, disclose, or process your Personal Information for the following purposes:

5.1.1 To manage, operate, provide, administer your use of and/or access to our Services and our Platform (including, without limitation, remembering your preference), as well as your relationship and user account with us (Lawful basis: Contract);

5.1.2 To consider and process your application and transaction with us or your transactions or communications with third parties via the Services (Lawful basis: Contract); 

5.1.3 To respond to, process, deal with or complete a transaction and/or to fulfill your requests for certain products and services and notify you of service issues and unusual account actions (Lawful basis: Contract);

5.1.4 To enforce our Terms and Conditions of Service or any applicable agreements (Lawful basis: Contract); 

5.1.5 For identification, verification, due diligence, or know your customer purposes (Lawful basis: Legal Obligation);

5.1.6 To deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by you (Lawful basis: Legitimate Interest);

5.1.7 To contact you or communicate with you for the purpose of managing your relationship with us or your use of our Services (Lawful basis: Contract); 

5.1.8 For marketing and advertising, and in this regard, to send you by various mediums and modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom we may collaborate or tie up with) that we may be selling, marketing or promoting, whether such products or services exist now or are created in the future. (Lawful basis: Consent); and

5.1.9 For other purposes as required and/or permitted by applicable laws and regulations, or required by relevant authorities or court orders  (Lawful basis: Legal Obligation).

5.2 As the purposes for which we will collect, use, disclose or process your personal information depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purposes at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the PDPA. 

How does FreedomMall protect your Personal Information?

All your Personal Information is kept confidential and in order to protect your Personal Information, we have in place various security procedures, technical and organizational measures to safeguard your Personal Information. 

Technical measures include appropriate actions to address online security, risk of data loss, alteration of data, or unauthorized access, taking into consideration the risk presented by the processing and the nature of the Personal Information being processed. e.g. using a strong encryption method while exchanging data, implementing a firewall, and customer or service-to-service TLS connections etc.

Organizational measures include implementing an access control policy to restrict access to Personal Information solely to authorized persons with a legitimate need to know for the purposes of the processing operations and conducting security awareness programs for our employees.

Therefore, we maintain security arrangements in respect of Personal Information to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. However, we cannot guarantee the security of information transmitted over the internet is impenetrable.

Retention of Personal Information

We will retain your Personal Information for as long as necessary during the period you are a customer or under relationship with us, or for as long as necessary in connection with the purposes set out in this Privacy Policy, unless law requires or permits a longer retention period. We will erase, destroy or anonymize your Personal Information when it is no longer necessary or when the period lapses.

Does FreedomMall disclose the collected information to outside parties?

In order to conduct our business, we may need to disclose or transfer your Personal Information to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, which may be located in foreign countries, for the purpose as described in Clause 5. We will take steps and measures to ensure that your Personal Iata is securely transferred, and the receiving parties have an appropriate level of personal data protection standard or as allowed by laws.

Personal Information of an individual under the age of 20

In the event that the User is under the age of 20, we shall not collect the Personal Information of the child until we obtain the consent from the holder of parental responsibility over the child. Furthermore, we will close any accounts used exclusively by such children and will remove or delete any Personal Information which we believe was submitted without parental consent by any child under the age of 20. 

What rights do you have?

You are entitled to: 

10.1 request access to your personal information kept under our responsibility, or request that we disclose how the personal information was obtained if it was obtained without your consent;

10.2 request to obtain your personal information if we organize such personal information in automatic machine-readable or usable format and can be processed or disclosed by automatic means; to request us to send or transfer the personal information in such format directly to other data controllers if doable by automatic means; and to request to obtain the personal information in such format sent or transferred by us directly to other data controller unless not technically feasible.

10.3 request that we delete, destroy, temporarily suspend or restrict the use of your personal information, or convert it into information that cannot be used to identify who you are (this right only pertains to instances when we fail to comply with the obligations under PDPA);

10.4 request that we make your personal information accurate, up-to-date, complete, and not misleading; 

10.5 be informed, upon your request, how your personal information is being processed;

10.6 object to the processing of personal information unless the processing is necessary for the performance of a task carried out for reasons of public interest; and

10.7 not be subject to a decision based solely on an automated process if such decision adversely affects your legal rights.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request.

Data Breach Notification

We will notify the Office of the Personal Data Protection Committee without delay and, where feasible, within 72 hours after having become aware of it, unless such personal data breach is unlikely to result in a risk to the rights and freedoms of you. If the personal data breach is likely to result in a high risk to the rights and freedoms of you, we will also notify the personal data breach and the remedial measures to you without delay through our website, SMS, email address, telephone or registered mail (if applicable).

How to contact us

If you have any questions about this Privacy Policy or would like to exercise your rights, you can contact us by contacting our Data Protection Officer, [email protected]