Pal Mall Privacy Policy

 

1. INTRODUCTION
 
1.1 Welcome to the Pal Mall platform run by Pal Mall Sdn. Bhd. Pal Mall takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our Pal Mall website and mobile. Users refers to a user who registers for an account with us for use of the Services, including both buyers and sellers. We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.  

1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information. 

1.3 By using the Services, registering for an account with us, visiting our Platform, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will notify you including by posting those changes or the amended Privacy Policy on our Platform. We reserve the right to amend this Privacy Policy at any time. To the fullest extent permissible under applicable law, your continued use of the Services or Platform, including placing of any orders, shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.

1.4 This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.  

1.5 This Policy applies to both buyers and sellers who use the Services except where expressly stated otherwise.

2. WHEN WILL PAL MALL COLLECT PERSONAL DATA? 

2.1 We will/may collect personal data about you:

 

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected. 

 

3. WHAT PERSONAL DATA WILL PAL MALL COLLECT? 

 

3.1 The personal data that Pal Mall may collect includes but is not limited to: 

 

3.2 You agree not to submit any information to us which is inaccurate or misleading, and 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 If you sign up to be a user of our Platform using your social media account (“Social Media Account”), link your Pal Mall account to your Social Media Account or use any social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use any such personal data in accordance with this Policy at all times. 

 

3.4 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. Further information on opting out can be found in the section below entitled "How can you withdraw consent,  request access to or correct information you have provided to us?" . Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services and the Platform.  For example, opting out of the collection of location information will cause its location-based features to be disabled. 

 

4. COLLECTION OF OTHER DATA 

 

4.1 As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you browse our Platform. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our site. 

 

4.2 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more Purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer. 

 

4.3 As when you view pages on our website or mobile application, when you watch content and advertising and access other software on our Platform or through the Services, most of the same information is sent to us (including, without limitation, IP Address, operating system, etc.); but, instead of page views, your device sends us information on the content, advertisement viewed and/or software installed by the Services and the Platform and time. 

 

 

5. HOW DO WE USE THE INFORMATION YOU PROVIDE US? 

 

5.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes: 

(collectively, the “Purposes”). 

 

5.2 You acknowledge, consent and agree that Pal Mall may access, preserve and disclose your Account information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over  Pal Mall or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over Pal Mall; (c) enforce the Pal Mall Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against Pal Mall or other claim that any Content violates the rights of third parties; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of Pal Mall, its users and/or the public.

 

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

 

6. HOW DOES PAL MALL PROTECT AND RETAIN CUSTOMER INFORMATION? 

 

6.1 We implement a variety of security measures and strive to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems.  However, there can inevitably be no guarantee of absolute security.

 

6.2 We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such personal data. If you cease using the Platform, or your permission to use the Platform and/or the Services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you. 

 

7. DOES PAL MALL DISCLOSE THE INFORMATION IT COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES? 

 

7.1 In conducting our business, we will/may need to use, process, disclose and/or transfer your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, which may be located in Malaysia or outside of Malaysia, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. We endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed for the above-mentioned Purposes. Such third parties include, without limitation: 

7.2 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply. Consistent with the foregoing and subject to applicable law, we may use your personal data for recognized legal grounds including to comply with our legal obligations, to perform our contract with you, to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights, or where necessary in connection with a legal claim

 

7.3 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours. 

 

7.4 Pal Mall allows you to share videos from YouTube. By using sharing YouTube Content, you hereby agree to be bound by the Google Privacy Policy (http://www.google.com/policies/privacy).

 

7.5 As set forth in Pal Mall’s Terms of Service, Users (including any employees, agents, representatives, or any other person acting for such User or on such User’s behalf) in possession of another User’s personal data through the use of the Services (the “Receiving Party”) hereby agree that, they will (i) comply with all applicable Privacy Laws with respect to any such data, including any collection, processing, storage or transfer of such data; (ii) allow Pal Mall or the User whose personal data the Receiving Party has collected (the “Disclosing Party”) to remove his or her data so collected from the Receiving Party’s database; and (iii) allow Pal Mall or the Disclosing Party to review what information has been collected about them by the Receiving Party, in each case of (ii) and (iii) above, in compliance with and where required by applicable laws. 

 

7.6 Notwithstanding anything set forth herein, Sellers (including any employees, agents, representatives, or any other person acting for such Seller or on such Seller’s behalf) shall comply with all applicable Privacy Laws and, in respect of any buyer’s personal data received from

Pal Mall, (i) are not permitted to use such buyer’s personal data except as reasonably necessary to respond to buyers’ enquiries and to carry out, respond to, process, deal with or complete a transaction without the buyers’ and Pal Mall’s prior written consent; (ii) should refrain from contacting buyers using such information outside of the Pal Mall platform; (iii) are not permitted to disclose such buyer’s personal data to any unauthorized third parties without the buyer’s and Pal Mall’s prior written consent; (iv) shall employ sufficient security measures to protect each Pal Mall user’s personal data in their possession, retain such data only for as long as necessary for the purposes above and in accordance with the Privacy Laws, and to delete or return such data to Pal Mall upon any request from Pal Mall or as soon as reasonably possible upon completion of the transaction.

 

8. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS TO OR CORRECT INFORMATION YOU HAVE PROVIDED TO US? 

 

8.1 Withdrawing Consent 

 

8.1.1 You may withdraw your consent for the collection, use and/or disclosure and/or request deletion of your personal data in our possession or under our control by sending an email at palmall180221@gmail.com, and we will process such requests in accordance with this Privacy Policy and our obligations under the Privacy Laws and other applicable law. However, your withdrawal of consent may mean that we will not be able to continue providing the Services to you and we may need to terminate your existing relationship and/or the contract you have with us. 

 

8.1.2 Where you share YouTube Content, in addition to withdrawing your consent by emailing us pursuant to Section 13.1.1, you may also revoke Pal Mall’s access to your personal data via the Google security settings page at https://security.google.com/settings/security/permissions.

 

8.2 Requesting Access to or Correction of Personal Data 

 

8.2.1 If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page on the Platform. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email at palmall180221@gmail.com.

 

8.2.2 We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee. 

 

8.2.3 We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances. 

 

9. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US 

 

9.1 If you have any questions or concerns about our privacy practices, we welcome you to contact us by e-mail at palmall180221@gmail.com.