1. Your Personal Data
- your name, NRIC, passport or other identification numbers, gender, date of birth, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
- information about your use of SMG’s website and services, including cookies and IP address, but only to the extent that SMG may identify you from such information;
- information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.
2. Collection of Personal Data
2.1 Generally, SMG collects your Personal Data in the following ways:
- when you submit forms relating to any of our products or services;
- when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;
- when you request that we contact you;
- when you are contacted by, and respond to, our marketing representatives and agents;
- when you respond to our request for additional Personal Data;
- when you ask to be included in an email or other mailing lists;
- when you respond to our promotions and other initiatives;
- when we receive references from business partners and third parties, for example, where you have been referred by them;
- when you submit your Personal Data to us for any other reason.
2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with our products and services you have requested.
3. Purposes for the Collection, Use, and Disclosure of Your Personal Data
3.1 Generally, SMG collects, uses and discloses your Personal Data for the following purposes:
- responding to your queries and requests and responding to complaints;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- verifying your identity;
- to manage, verify and complete transaction with you (where applicable);
- to develop, enhance, market and provide products and services to meet your needs;
- (d) protecting and enforcing our contractual and legal rights and obligations;
- compliance with any applicable rules, laws, and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
- any other purpose relating to any of the above.
3.2 In addition, SMG may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
- If you submit advertisements to us or any of our online advertising portals:
- to verify and process your personal particulars and payments made for the posting of the advertisements;
- communicating with you to inform you of changes and development to SMG policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
- resolving complaints and handling requests and enquiries; and
- conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you.
3.3 In addition, where permitted under the Act, SMG may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):
- providing services, products, and benefits to you, including promotions, loyalty and reward programs;
- matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by SMG or other third parties;
- administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions, and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions, and lucky draws;
- sending you details of products, services, special offers, and rewards, either to our customers generally, or of particular products and services which may be of interest to you;
- conducting market research, understanding and determining customer location, preferences, and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programs; and
- to improve the content of our sites.
3.4 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4. Disclosure of Personal Data
4.1 SMG will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Malaysia:
- SMG affiliates;
- agents, contractors or third-party service providers who provide operational services to SMG, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services to SMG;
- vendors or any third-party business partners who offer goods and services or sponsor contests or other promotional programs on SMG’s sites, whether in conjunction with us or not; and
- anyone to whom we transfer or may transfer our rights and duties.
5. Parental Advisory
5.1 One or more of our services are not catered to user under the age of 13 as our services may provide access to music or other content that contains explicit content including use of profane language and/or sexual references. If you are, please obtain your parent/guardian’s permission before using and/or accessing our services. Please do not provide us with your personal data unless you have obtained permission from your parent/guardian. Parental discretion is advised for all users below 13. We encourage parent/guardian to monitor their children’s internet usage and to help enforce our policy by instructing their children never to provide personal data through the service without your permission. If you have reason to believe that a child under the age of 18 has provided personal data to us through our services, please contact us and we will endeavour to delete that information from our database. Otherwise all personal data provided by a user shall be deemed to have been submitted by a user above 18 or has obtained the relevant permission from their parent/guardian.
6. Online Tracking and Advertising
6.2 We, along with the Authorized Third Parties, also may use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and third parties use beacons for a variety of purposes, including to analyze the use of the websites and products and/or services offered by SMG and (in conjunction with cookies) to provide content and advertisements that are more relevant to you.
6.4 Due to differences between using apps and websites on mobile devices, you may need to take additional steps to disable tracking technologies in mobile applications. Many mobile devices allow you to opt-out of targeted advertising for mobile applications using the settings within the mobile application or your mobile device. For more information, please check your mobile settings. You also may uninstall our applications using the standard uninstall process available on your mobile device or app marketplace.
7.1 When you interact with us on our websites, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as the number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into the website.
7.2 SMG uses “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. Most cookies are “session cookies,” meaning that they are automatically deleted from your device at the end of a session. You are always free to decline cookies if your device permits, although in that case you may not be able to use certain features of our services and you may be required to re-enter your password more frequently during a session.
7.3 This information is aggregated by the Authorized Third Parties and provided to SMG to assist in analysing the usage of SMG websites. Such data is also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other Internet portals.
7.4 Pages on SMG websites may be coded with software which enables Authorized Third Parties to track visitors to our web sites.
7.5 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.
8. Third-Party Sites
8.1 Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third-party websites. Some of these third-party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third-party website to determine how they will handle any information they collect from you.
9. Storage and Retention of Personal Data
9.1 Your Personal Data shall be stored and backed up securely in an environmentally-controlled location. Only authorized people with user ID and password from our company have access to the information. It may be necessary to transfer your Personal Data to third party services providers based/located outside Malaysia. By continuing to use the websites, products and/or services of SMG, you hereby consent to such transfer.
9.2 Any Personal Data supplied by you will be retained by us as long as necessary for the fulfilment of the Purposes stated in paragraph 3 above or as required to satisfy legal regulatory, accounting requirements or to protect our interests. We till take reasonable steps to destroy or permanently anonymize Personal Data if it is no longer needed for such purposes.
10. Withdrawal, Access and Correction of your Personal Data
10.1 Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, you may request by writing to us not to process your Personal Data for any of the purposes or for the advertising or marketing purposes enumerated in paragraph 3 above.
10.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to SMG on your behalf.
10.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, SMG may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with SMG and your being in breach of your contractual obligations or undertakings, and SMG’s legal rights and remedies in such event are expressly reserved.
11.2 We have implemented security policies, rules and technical measures to protect your Personal Data from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. All our employees and data processors, who have access to and are associated with the processing of Personal Data, are obliged to respect the confidentiality of your information.
11.3 While we cannot guarantee that loss, misuse or alteration of data will not occur; we make reasonable efforts to prevent such unfortunate occurrences.You must remember to log off after accessing and/or using our services and/or close the browser window after use so that no unauthorized party can have access. You must not, at any time, divulge your Personal Data to any third party.
12. Governing Law