1. INTRODUCTION

1.1 Welcome to the Aladdin platform, operated by Aladdin Commerce Sdn. Bhd. and its subsidiaries, associates and affiliates (individually and collectively referred to as “Aladdin”, “we”, “us” or “our”). Under applicable privacy laws and regulations (“Privacy Laws”), Aladdin takes its obligations seriously and is committed to protecting the privacy rights and interests of all users of our Aladdin website (the “Platform”) (we refer to the Platform and the services we provide as described in our Platform collectively as the “Services”). We understand the value of the personal data that you have entrusted to us and feel that it is our duty to handle, protect and process your personal data properly. This Privacy Policy (“Privacy Policy” or “Policy”) is intended to help you understand, whether now or in the future, how we gather, use, disclose and/or process the personal data that you have given to us and/or that we have about you, and to help you make an informed decision before providing us with any of your personal data. Please read this Privacy Policy thoroughly.

1.2 “Personal Data” means data, whether real or not, relating to an individual who can be identified from that data, or from that data and other information accessible or likely to be obtained by organisation. Names, identification numbers and contact details are among the typical examples of personal data.

1.3 You acknowledge and agree that you acknowledge the activities, criterias, and/or policies set out in this Privacy Policy by using the Services, registering for an account with us, visiting our website, or viewing the Services, and you hereby consent to us capturing, using, disclosing and/or processing your personal data as defined herein. PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DEFINED IN THIS PRIVACY POLICY. If we update our Privacy Policy, we will post on our website those changes or the amended Privacy Policy. We reserve the right, to change this Privacy Policy, at any time.

2. GATHERING OF PERSONAL DATA BY ALADDIN

2.1 We may/ will gather personal data about you:

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

(b) when you submit any form, including but not limited to, application forms or any other forms relating to our services, either online or in physical form;

(c) when you enter into any agreement or provide other document or information in respect of your interactions with us, or when you use our goods and services;

(d) when you communicate with us, such as through letters, fax, face-to-face meetings, social media platforms, emails and telephone calls (which may be recorded);

(e) when you use our electronic services, or communicate with us through our application or use services on our website. This entails, without restriction, through cookies which we may deploy when you interact with our website or application;

(f) when you conduct transactions through our Services;

(g) when you give us your feedback or complaints;

(h) when you sign up for a contest; or

(i) when you send your personal data to us for any reason.

The above does not appear to be exhaustive and sets out several typical instances of the collection of personal data about you.

2.2 We may collect such information through automatic or passive means when you visit, use or communicate with our Platform using a variety of technologies, that may be downloaded to your device and may set or change settings on your device. Your Internet Protocol (IP) address, computer/mobile device operating system and browser type, mobile device type, mobile device characteristics, unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), and the pages you visit on our website and the times of visit, without limitation, be included in the information we collect. We can collect, use, disclose and/or process this information only for the Purposes, which as defined below.

3. WHAT PERSONAL DATA WILL ALADDIN COLLECT?

3.1 The personal data that Aladdin may collect includes but is not limited to:
• name;
• email address;
• date of birth;
• billing address;
• bank account and payment information;
• telephone number;
• gender;
• when the User signs up to use our Services or website and when the User uses the Services or website, all other information about the User, as well as any other information relevant to how the User uses our Services or website; and
• aggregate data on content the User engages with.

3.2 If you do not want us to collect the personal data/information above, you can opt-out at any time by notifying out Data Protection Officer in writing. However, please note that opting out of collecting your personal data for us or withdrawing your consent to the collection, use or processing of your personal data from us can affect your use of the Services. For instance, opting out of the location information set would cause its location-based function to be disabled.

4. SETTING UP AN ACCOUNT

You would have to set up a user account which entails you to enter definite personal data in order to access certain features of the Services. We request you to provide us with your name and email address when you register and create an account, as well as a selected user name by you. We also request such information about you, such as your telephone number, email address, shipping address, photo identification, bank account details, age, date of birth, gender and interests. You may choose a user name and password upon activating an account. Your user name and password are used so that you can access and maintain your account safely.

5. VIEWING WEB PAGES

As with most websites, when you browse our Platform, your device sends information that may include personal data about you that gets logged by a web server. Usually, this includes but not limited to your IP address, operating system, browser name/version, referring web page, requested page, date/time, and occasionally a “cookie” (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, your personal account is associated with this information. In order to help us to understand how visitors use our Platform, the information is also included in anonymous statistics.

6. COOKIES

6.1 We may administer “cookies” or other features from time to time to allow us or third parties to collect or share information that will help us improve our Platform and the Services we provide, or help us to provide new services and features. “Cookies” are identifiers that we transfer to your computer or mobile device that allow us to identify your computer or device and tell us how and when the Services or website are used or accessed, by how many people and how to monitor movements within our website. We may connect information about cookies to personal data. Cookies often connect to information about which items you have selected and which pages you have visited for purchase. This information is used to keep track of, for example, your shopping cart. Cookies are often used to deliver content that is unique to your interest and to monitor use of the website.

6.2 By selecting the relevant settings on your browser, you can decline the use of cookies. Please note, however, that you will not be able to use the full functionality of our Platform or the Services if you do so.

7. VIEWING AND DOWNLOADING CONTENT AND ADVERTISING

As you view content and advertising and access other software on our Platform or via the Services, as with browsing web pages, most of the same information is sent to us (including, without limitation, IP address, operating system, etc.); but your device sends us information about the content, advertising displayed and/or software installed by the Services and the website and time instead of page views.

8. COMMUNITY & SUPPORT

8.1 We provide customer service assistance via email, SMS and feedback forms. We will ask for your email address and mobile phone number in order to provide customer service. We only use information received from requests for customer support, including but not limited to email addresses, for customer support services and we do not pass to or exchange this information with any third parties.

9. SURVEYS

We may request information from Users time to time through surveys. Participation in these surveys is entirely voluntary, so you have a choice between disclosing your information to us or not. Information requested may include, without limitation, contact information (such as your email address), and demographic information (such as interests or age level). Survey information will be used for the purposes of tracking or enhancing the use and satisfaction of the Services and shall not be distributed to third parties, other than our contractors who assist us in the administration or conduct of the survey.

10. THE USE OF INFORMATION YOU PROVIDE TO US

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

(a) to accept and/or process your request/transaction with us or your transactions or interactions with third parties through the Services;

(b) to manage, operate, deliver and/or oversee your use of and/or access to our Services and our website, as well as your relationship and user account with us;

(c) to handle, operate, oversee and provide you with and to facilitate the provision of our Services, including but not limited to remembering your preferences;

(d) to tailor your experience through the Services to your interests and preferences by displaying content, providing a quicker way for you to access your account and send information to us and, if necessary, enabling us to contact you;

(e) to respond to, process, deal with or complete a transaction and/or to satisfy your requests for certain products and services and inform you of service issues and unusual account activities;

(f) to effectuate our Terms of Service or any other relevant end user license agreements;

(g) to protect personal safety and the rights, property or safety of others;

(h) for identification and/or verification;

(i) to maintain and handle any software updates and/or other updates and support that may be needed from time to time to ensure that our Services operate smoothly;

(j) to deal with or expedite customer service, carry out your instructions, to deal with or respond to any inquiries made by you or on your behalf (or supposed to be given by you);

(k) to contact you or communicate with you via voice call, text message, email and/or postal mail or otherwise for the purposes of maintaining and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You understand and accept that such contact by us may be by means of mailing to your correspondence, documents or notices, which may require the disclosure of some personal data concerning you for the purpose of providing the same as for the external cover of envelopes/mail packages;

(l) to enable other users to communicate or connect with you on the Platform, including to inform you when a private message has been sent to you by another User or when a comment has been posted for you on the Platform;

(m) to conduct research, study and growth activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your user experience;

(n) to enable for audits and surveys to verify, among other things, the size and composition of our target audience and to understand their Aladdin Services experience;

(o) where you give us your prior consent, for marketing purposes and in this regard, to send you, by various means of communication, such as postal mail, email, location-based services or otherwise, marketing and promotional details and materials relating to products and/or services (including, without limitation, third-party products and/or services which Aladdin may collaborate or link with) that Aladdin (and/or its affiliates, associates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. In the case of sending to you marketing or promotional details by voice call, emails or messages to your Malaysia telephone number, if you are in Malaysia, we will not do so unless we have complied with the requirements of Malaysia’s Privacy Laws in relation to use of these latter contact methods in sending you marketing details, or you have specifically consented to the same;

(p) to respond to legal processes or to comply with or as needed by any relevant law, governmental or regulatory requirements of any relevant jurisdiction, including but not limited to fulfilment of disclosure requirements in compliance with the requirements of any law binding on Aladdin or on its related companies or affiliates;

(q) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;

(r) to carry out due diligence or other screening activities (including but not limited to background checks) in accordance with legal or regulatory obligations or our procedures for risk management that may be required by law or that may have been put in place by us;

(s) to audit our Services or Aladdin’s business;

(t) to prevent or investigate any actual or alleged violations of our Terms of Service, fraud, illegal activity, omission or misconduct, whether related to your use of our Services or to any other matter arising out of your relationship with us;

(u) to store, host, back up of your personal data (whether for disaster recovery or otherwise), whether within or outside of your jurisdiction;

(v) to deal with and/or facilitate a business asset transaction or a potential business asset transaction, whether such transaction involves Aladdin as a participant or involves only a related company or affiliate of Aladdin as a participant or involves Aladdin and/or any one or more of Aladdin’s related company or affiliates as participant(s), and there may be other third-party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the organisation’s business or assets; and/or

(w) any other reasons that we inform you of at the time of obtaining your consent.

(collectively, the “Purposes”).

10.2 You accept, consent and agree that Aladdin 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 Aladdin 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 Aladdin; (c) enforce the Aladdin Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against Aladdin 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 Aladdin, its users and/or the public.

10.3 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.

11. SHARING OF INFORMATION FROM THE SERVICES

Our Services allow Users to share personal information with each other, in almost all occasions without Aladdin’s involvement, to complete transactions. In a typical transaction, Users may have access to each other’s name, user ID, email address and other contact and postage information. Our Terms of Service require that Users in possession of another User’s personal data (the “Receiving Party”) must (i) comply with all applicable Privacy Laws; (ii) allow the other User (the “Disclosing Party”) to remove him/herself from the Receiving Party’s database; and (iii) allow the Disclosing Party to review what information have been collected about them by the Receiving Party.

12. HOW DOES ALADDIN SAFEGUARD AND MAINTAIN CUSTOMER INFORMATION?

12.1 We apply a range of security measures and work hard to keep your personal information safe on our systems. Personal information about users is held behind password-protected networks and is only available to a restricted number of workers with exclusive access privileges to such systems. However, there can never be a definite guarantee of protection.

12.2 Personal data will be held in compliance with the Privacy Laws and/or other applicable regulations. Furthermore, we will delete or anonymize your personal data as soon as it is fair to conclude that (i) the purpose for which it was collected is no longer served by its preservation, and (ii) preservation is no longer required for any business or legal purposes. We may continue to store, use, and/or disclose your personal data in compliance with this Privacy Policy and our obligations under the Privacy Laws after you stop using the Platform, or your permission to use the Platform and/or the Services is discontinued or revoked. We can securely discard of your personal data without prior notice to you, subject to applicable law.

13. DOES ALADDIN DIVULGE THE INFORMATION IT GATHERS FROM VISITORS WITH THIRD PARTIES?

13.1 For one or more of the aforementioned Purposes, we will and/or may need to disclose your personal data to our third-party service providers, agents, associates or related companies, and/or other third parties, whether located in Malaysia or outside of Malaysia. Such third-party service providers, agents, associates, related companies, and/or other third parties will be collecting your personal data for one or more of the aforementioned Purposes, either on our behalf or otherwise. Third parties include, but are not limited to:

(a) our subsidiaries, affiliates, associates and related companies;

(b) other users of our Platform for one or more of the aforementioned Purposes;

(c) agents, contractors, service providers and any other third parties we utilise to support our business, which include but not limited to those which provide administrative or other services to us such as logistics service providers, mailing houses, telecommunication companies, information technology companies and data centres;

(d) a customer or other successor in the event of a divestment, merger, reorganization, restructuring, dissolution or other sale or transfer of any or all of Aladdin’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Aladdin about our Service Users is among the assets transferred; or to a counterparty in a business asset transaction that Aladdin or any of its affiliates or related companies is involved in; and

(e) third parties to whom we disclose personal data for one or more of the Purposes, and who, in exchange, collect and process your personal data for one or more of the Purposes.

13.2 Among other things, this may entail sharing statistical and demographic info about our Users and usage of the Services with advertisements and programming suppliers.

13.3 For avoidance of doubt, given that Privacy Laws or other relevant laws grant an establishment such as us to collect, use or disclose your personal data without your consent, such permission allowed by the laws will continue to apply.

13.4 Third parties may illegally intercept or access personal data transmitted to or contained on the website, technology may malfunction or fail to operate as anticipated, or someone may gain access to, abuse or misuse information which is beyond our control and of not our fault. Nevertheless, we will also use appropriate security measures to protect your personal information as required by the Privacy Laws; But however, there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure occurs as a result of malicious and sophisticated hacking by malcontents through no fault of our own.

14. INFORMATION ON CHILDREN

Children under the age of 13 are not permitted to use the Services. It is out of our knowledge of collecting or storing personal data or non-personally identifiable information from children under the age of 13, and no part of our Platform or other Services is targeted for children under the age of 13. Please do not authorize children under your care to conform personal data to Aladdin as a parent or legal guardian. If Aladdin receives personal data about a child under the age of 13 in your custody, you hereby consent to the processing of that child’s data and endorse and agree to be bound by this Policy on behalf of that child. We will shut down any accounts used solely by such children, and we will remove and/or erase any personal data we believe was submitted by a child under the age of 13 without parental consent.

15. INFORMATION COLLECTED BY THIRD-PARTIES

15.1 Google Analytics, a web analytics tool offered by Google, Inc. (“Google”), is used on our Platform. To help the website analyse how Users use the Platform, Google Analytics uses cookies, which are text files stored on your computer. Google will transmit and store the information produced by the cookie about your use of the website (including your IP address) on servers in the United States. Google can use this information to evaluate your website usage, compile website activity reports for website operators and provide other services related to website activity and Internet use. Google may also relay this information with third-parties as needed by law or if those third-parties process the data on behalf of Google. Google will not connect your IP address to any other information it has.

15.2 Aladdin and third parties may make software applications downloads available for you to use on or through the Services from time to time. These applications may distinctly access and permit a third-party to sight your identifiable information, such as your name, user ID, computer IP address or other information such as any cookies you may have previously installed or that were installed for you by a third-party software application or website. Furthermore, these applications may request that you provide additional information to third-parties directly. Aladdin does not own or operate any of the third-party products or services rendered by these applications. You are recommended to read the terms and other policies issued by such third-parties on their websites or otherwise.

16. SECURITY AND THIRD-PARTY WEBSITES DISCLAIMER 

16.1 WE CANNOT WARRANT THE SECURITY OF YOUR PERSONAL DATA AND/OR OTHER INFORMATION ON THIRD-PARTY WEBSITES WHICH YOU HAVE PROVIDED. We do apply a range of security measures and work hard to keep your personal information with us is safe. Personal information about users is held behind password-protected networks and is only available to a restricted number of workers with exclusive access privileges to such systems, and are obliged to keep it confidential. We use a safe server when you place orders or access your personal information. Any personal data or confidential information you provide is encrypted and stored in our databases, where it will be accessed only for the purposes mentioned above.

16.2 We may choose diverse third-party websites to connect to and frame within the Platform in order to provide you with more value. We may also engage in co-branding and other partnership to provide our visitors with social commerce, other services and features. These associated sites have their own privacy policy and security arrangements. Even if the third party is associated with us, we have no authority over these associated sites, which all have their own privacy and data collection policies. We will not obtain data collected by our co-brand partners or third-party websites (even if provided on or through our Platform).

16.3 Thus, we will assume no obligation or liability for the content, protection sorting (or lack thereof) and activities of these linked sites. You visit these related sites at your own risk because they are just for your convenience. Nevertheless, we want to protect the reputation of our Platform and the links that are posted on it, so any input about these connected sites is welcomed (including but not limited to, if a specific link does not work).

17. WILL ALADDIN TRANSMIT YOUR INFORMATION OVERSEAS?

Your personal data and/or information may be transmitted to, stored or processed outside of your country. In the vast majority of cases, your personal data will be processed in Malaysia, where our servers are located and our central database are housed. Aladdin may only transmit your information out of country in accordance with Privacy Laws.

18. HOW DO YOU REQUEST ACCESS TO OR CORRECT INFORMATION YOU HAVE GIVEN TO US OR WITHDRAW YOUR CONSENT? 

18.1  Withdrawing Consent

18.1.1 By sending an email to our Personal Data Protection Officer at the email address mentioned below in Section 19.2, you may withdraw your consent for the collection, use, and/or disclosure of your personal data in our possession or under our control. We will process such requests in compliance with this Privacy Policy and our responsibilities under the Privacy Laws and other relevant laws. Note that, if you withdraw your consent, we will be unable to continue offering the Services to you, and we may need to end our current relationship and/or contract with you.

18.1.2 You can revoke Aladdin’s access to your personal data where you have shared YouTube Content through the Google security settings page at https://security.google.com/settings/security/permissions, in addition to withdrawing your consent by emailing us as described in Section 18.1.1.

18.2 Requesting Personal Data Access and/or Correction

18.2.1 If you have an account with us, you can use the Account Settings page on the Platform to access and/or correct your personal data that we currently have in our possession or control. If you do not have an account with us, you may send a written request to us requesting access to and/or correction of your personal data currently in our possession or control. We will need enough details from you to verify your identity as well as the essence of your request in order to respond to your request. Thus, please send your written request to our Personal Data Protection Officer at the email address specified in Section 19.2 below.

18.2.2 In the case of a request for access to personal data, once we have received appropriate information from you, we will make every effort to provide you with the requested personal data within 30 days (or, if you are resident in Malaysia, 21 days). If we are unable to reply to you within 30 days (or 21 days if you are a Malaysian), we will notify you of the earliest possible time when we will be able to provide you with the details you have requested. Please note that some forms of personal data might be excluded from your access request due to Privacy Laws.

18.2.3 When we have enough details from you to deal with your request for personal data correction, we will:

(a) within 30 days, we will correct your personal information (or, if you are resident in Malaysia, 21 days). Given that we are unable to do so within the specified time, we will inform you of the earliest possible time when the correction can be made. Please note that certain forms of personal data may be excluded from your correction request, and that certain situations may necessitate us not making a correction despite your request; and

(b) we will forward the corrected personal information to every other institution to which the personal information was divulged by us within a year before the date the correction was made, except where the other institution does not need the corrected personal data for any business or legal purpose.

18.2.4 Regardless of subparagraph (b) above, if you so request, we may send the corrected personal data only to specific institutions to which we disclosed the personal data within a year prior to the date the correction was made.

18.2.5 For the handling and processing of your requests for access to your personal data, we will charge you an appropriate fee. We will provide you with a written estimate of the amount we will charge if we decide to charge. Note that unless you agree to pay the fee, we are not obliged to respond to or deal with your access request.

18.2.6 We reserve the right to decline to correct your personal information in compliance with the requirements of Privacy Laws, which require and/or allow an institution to refuse to correct personal data in specific circumstances.

19. CONTACT US FOR ANY OF YOUR QUESTIONS, CONCERNS OR COMPLAINTS.

19.1 Please contact us at support@aladdingroup.biz if you have any questions or complaints about our privacy policy or your interactions with the Services.

19.2 If you have a complaint or concern about how we handle your personal data or how we comply with Privacy Laws, we encourage you to contact us.

Please send us an email with your complaint or concern:

E-mail: dpo.my@aladdingroup.biz and Attention it to the “Personal Data Protection Officer”.

Please send all legal notices to legal@aladdingroup.biz and Attention it to the “Legal Counsel”.

19.3 If you are sending a complaint via email or letter, specifying that it is a Privacy Law complaint in the subject header will help us respond to your complaint quickly by forwarding it to the appropriate staff within our organisation. You may, for example, make the subject header “Privacy Complaint.”

We will make every effort to resolve any issue or concern you may have in a reasonable and timely manner.

20. TERMS AND CONDITIONS

Please read the Terms of Service, which establishes the use, disclaimers, and restrictions of liability for the Platform and Services, as well as other applicable policies.