3. INFORMATION COLLECTION AND USE
3.1 We may collect and hold personal information/data (“Personal Information”) about you or someone else whom you have provided us with information of (“Third Party”), that is, information that can identify you or such Third Party, including without limitation full name, postal and email address, other contact details, identification details, payment details, and other information relevant to us providing you with the services you and/or the Third Party are, or someone else you know is, seeking, which we receive from you through our Mobile App, Website, customer service centre, social media sites, walk-in or distribution channels and other distribution channels. You represent and warrant that you have obtained the consent of such Third Party or are otherwise entitled to provide us with their Personal Information and to view or change their information. You agree to indemnify us in the event we suffer any loss or damage as a result of your failure to comply with the same.
3.2 You are responsible for ensuring that the Personal Information you provide us is accurate, complete and not misleading and that such Personal Information is kept up to date.
3.3 Information We Collect
With the purpose of providing you with My Residence and other EZLIVING SOLUTIONS App, Web & Services and to operate in an efficient and effective manner, we need to collect relevant personal information from you. The personal information collected by us may include (but is not limited to) the following:
• Contact information such as your name, date of birth, identification supporting documents (including NRIC or passport number), gender, nationality and race, preferred language, current private and/or business address, installation address, telephone or mobile phone number, fax number, email address.
• Your bank account information or credit card details (which we will not have access to as they will be managed by payment providers)
• The status of My Residence and other EZLIVING SOLUTIONS App, Website & Services you have acquired from us or subscribed to
• How you use My Residence and other EZLIVING SOLUTIONS App, Website & Services (for example traffic data such as date/time guard button is activated, trusted neighbours, visitors pass, announcement page, e-billing/-payment and other communications made and received by you and the date, duration, time and cost of such communications)
• The amount of data that has been received and/or sent by you
• Information about your computer or device used to access our Services, and about your visits to and use of our websites (including your mobile device, IP address, geographical location, operating system, browser type, number of visits, average time spent on the site and pages viewed). The collected information is used to provide an overview of how people are accessing and using My Residence and other EZLIVING SOLUTIONS websites and not for any additional purpose, such as to profile users
• We may do this using cookies, web Beacon or similar technologies. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes.
• Details of the emails and other electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication. We use this to help ensure our communications are useful for you.
3.4 Ways We Collect Your Personal Information
We may collect personal information directly from you when you:
• Communicate with us such as when you submit an application form to use our websites, applications or services (including free trials), downloading My Residence or EZLIVING SOLUTIONS App or when you contact us for any enquiries, including communication by telephone, email, chat services and social media
• Purchase a subscription to our services
• Register or subscribe for our publications such as newsletters, complete any online forms, take part in surveys, post on our blogs, download information such as white papers or other publications or interact with us through our websites
• Respond to any marketing materials we send out
• Commence a business relationship with us such as being our service provider/business partner
• Visit or browse our websites
• Lodge a complaint with us or provide feedback through websites or other channels
• Other than personal information obtained from you directly , we may also obtain your personal information from third parties we deal with or are connected with you (credit reference agencies or financial institutions), and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted
3.5 How We Use Your Data
• To verify your identity
• To assess and process your application(s) /request(s) for My Residence and other EZLIVING SOLUTIONS App, Website & Services
• To administer and manage My Residence and other EZLIVING SOLUTIONS App, Website & Services we provide you including charging, billing, facilitating payments and collecting debts
• To assess and/or verify credit worthiness
• To detect and prevent fraudulent activity
• To keep in contact with you and provide you with any information you have requested
• To engage in business transactions in respect of My Residence and other EZLIVING SOLUTIONS App, Website & Services to be offered and provided to you
• To establish and better manage any business relationship we may have with you
• To process any communications you send us (for example, answering any queries and dealing with any complaints and feedbacks)
• To notify you about benefits and changes to the features of My Residence and other EZLIVING SOLUTIONS App, Website & Services
• To produce data, reports and statistics which shall be anonymised or aggregated in a manner that does not identify you as an individual
• We may also use personal information for internal purposes such as auditing, data analysis, and research to improve EZLIVING SOLUTIONS’s products, services, and customer communications
• To investigate, respond to, or defend claims made against, or involving EZLIVING SOLUTIONS SDN. BHD.
• To conduct our internal marketing and promotional activities. For example, we may use it to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. You can also unsubscribe from any email marketing using the links provided in the emails we send to you.
• To maintain records required for security, claims or other legal purposes
• To comply with legal and regulatory requirement
• For any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities
3.6 Data Disclosure
As a part of providing you with My Residence and other EZLIVING SOLUTIONS App, Website & Services and the management and/or operation of the same, we may be required or need to disclose information about you to the following third parties:
• Law enforcement agencies
• Government agencies
• Companies and/or organizations that act as our agents, contractors, service providers (including their subcontractors) and/or professional advisers
• Companies and/or organizations that assist us in processing and/or otherwise fulfilling transactions and providing you with My Residence and other EZLIVING SOLUTIONS App, Website & Services that you have requested or subscribed for
• Our business associates and other parties for purposes that are related to the purpose of collecting and using your personal information
• Other parties in respect of whom you have given your express or implied consent
• Subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to My Residence and other EZLIVING SOLUTIONS App, Website & Services
• Strategic partners that work with EZLIVING SOLUTIONS to provide better products and services, or that help EZLIVING SOLUTIONS market to customers. For example, when you inquire about My Residence and other EZLIVING SOLUTIONS services, EZLIVING SOLUTIONS may send your email with your personal or non-personal information to Authorized Resellers for sales follow-ups. Personal information will only be shared by EZLIVING SOLUTIONS to provide EZLIVING SOLUTIONS services to you; it will not be shared with third parties for their marketing purposes.
Please note that EZLIVING SOLUTIONS uses data processors that may collect, store and process your data on behalf of us. The selected processors offer sufficient guarantees with regard to technical and organizational security measures for the processing of your personal data. They are used for the following purposes:
• Hosting of our applications or services
• Customer relationship management system
• Payment service platform
• Provide user support tools, such as website live chat
• Provide web visit and usage analytics
3.7 Please note that it is necessary for EZLIVING SOLUTIONS to process your personal information for the Purpose, and without which EZLIVING SOLUTIONS will not be able to provide the product and/or service that you have requested from EZLIVING SOLUTIONS or to perform and/or carry out any of the above mentioned Purposes. If you fail or decline to provide us with Personal Information stated in paragraph 3.1 above, we may not be able to perform and/or carry out any of the Purposes and may need to terminate any product and/or service provided to you. In some circumstances, you may have provided personal and financial information relating to others (e.g. joint-applicant, spouse, related parties and/or emergency contact persons) for the Purpose. In such cases, you represent and warrant that you had or have their consent or are otherwise entitled to provide their information to EZLIVING SOLUTIONS.
4. MARKETING AND PROMOTIONAL COMMUNICATIONS
4.1 We may use the Personal Information provided to send you information on products and services, and special or promotional offers, newsletters or customer survey forms and questionnaires unless you have indicated that you do not wish to receive such materials.
4.2 You may opt out of receiving any communications from us at any time by clicking on the unsubscribe option in the Mobile App Settings or contact us with your request (see the CONTACT US section below).
5. SECURITY OF YOUR PERSONAL INFORMATION
5.1 We will take reasonable steps to protect any Personal Information we receive from you via our Mobile App or Website from misuse and loss and from unauthorized access, modification or disclosure. We may hold your information in either electronic or hard copy form or retain third parties to hold that information on our behalf. Where required by applicable laws, Personal Information will be destroyed or de-identified when no longer needed.
5.2 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 servers, central database and 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, Singapore, India, the United States and the United Kingdom.
5.3 However as the Website and Mobile App is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us and you do so at your own risk.
6. LINKS TO OTHER APPLICATIONS AND WEBSITES
6.1 Our Mobile App and Website may contain links to websites or applications operated by third parties (“Third Party Applications or Websites”). We are not responsible for the privacy practices or the content of Third Party Applications or Websites. Third Party Applications and Websites are responsible for informing you about their own privacy practices.
7. ACCESS AND CORRECTION
7.1 You may request access to any Personal Information we hold about you or any Third Party whose Personal Information you had provided at any time by contacting us (see the CONTACT US section below). Where we hold information that you are entitled to access, we will endeavour to provide you with suitable means of accessing it (e.g. by emailing or mailing it to you).
7.2 If you believe that Personal Information we hold about you is incorrect, incomplete or inaccurate, then you may request to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the Personal Information stating that you disagree with it. You may also, at any time hereafter, request, in writing, to limit the processing of your Personal Information (including personal data of others provided by you).
7.3 You may at any time make written inquiries and, upon payment of a prescribed fee, request, in writing, for access to, or correction of, your Personal Information or limit the processing thereof (including personal data of others provided by you) . In accordance with the Malaysian Personal Data Protection Act 2010, and to the extent not limited by any other applicable law (if applicable), we may:
(1) charge a fee for processing your request for access or correction to the Personal Information; and
(2) refuse to comply with your request for correction to the Personal Information and give you a reason for our refusal.
(1) maintain your session and required details during the application, subscription, registration process and during transactions (session cookie);
(2) collect online usage data for statistical/analytics purposes (analytics cookie); and
(3) direct you to the correct landing page based on your geo-location (geo-targeting cookie).
8.2 You may instruct your browser, by changing its setting, to stop accepting cookies or to prompt you before accepting a cookie from the websites that you visit. Our Website or Mobile App will not function properly if the cookie setting is disabled.
9. CONTACTING US
Personal Data Protection c/o Legal Division
EZLIVING SOLUTIONS SDN. BHD.