Privacy Policy
Effective as of 31 July, 2021

This privacy policy (the "Privacy Policy") is intended to inform you of our policies and practices regarding the collection, use and disclosure of any information you submit to us. This includes "Personal Information," which is information about you that is personally identifiable such as your name, e-mail address, user ID number, delivery and billing addresses and other non-public information that is associated with the foregoing.

This Policy may change over time to reflect changes in the law, changes in our business practices, procedures and structure, and the community's changing privacy expectations.  Amendments, modifications or changes to this Policy will be posted at this URL and will be effective when posted. Your continued use of this Site following the posting of any amendment, modifications or change to this Policy shall constitute your acceptance thereof.  If you do not agree with the terms in this Policy, please do not use this Site and do not provide any information to us. Unless otherwise defined in this Policy, the terms used in this Policy have the meaning given to them in our Terms of Service, which you can access here: Terms & Conditions


Restrictions

This Policy covers your access to our Services and to this Site. Our Site is not directed to and is not intended for access and use by persons under the age of 18.  We do not intentionally collect or use Personal Data from users that we have reason to believe are under the age of 18.


User Consent

By accessing or otherwise using our platform, you agree to the terms and conditions of this Privacy Policy, which is incorporated into and forms a part of our terms of service you expressly consent to the processing of your Personal Information according to this Privacy Policy.

Your Personal Information will be processed and stored in Malaysia governed by the Personal Data Protection Act 2010 (“PDPA”). Your Personal Information will not be used or disclosed for purposes for which you have not given consent or which are not permitted under applicable law.


Collection of Personal Information

The type of Personal Data (defined below) and Other Data (also defined below) we collect depends on how you are specifically interacting with this Site how you are using our Services. Generally, we gather Personal Data and Other Data as described below.

Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, usage data, phone numbers, and unique device identifiers ("Personal Data"). We may need to collect and process Personal Data in order to provide requested information, products or Services to you (including this Site) or because we are legally required to do so.

• Account Registration
We request Personal Data from you if this Site requires registration. The registration process requests that you provide your name, email address, address, phone number, company affiliation, if any, and other similar information. This information must be stored on this Site, and is accessible to anyone with whom you share your username and password. For this reason, please safeguard your username and password carefully and do not disclose them to any other person.

• Voluntary Disclosure
We may collect Personal Data voluntarily provided by you, including in emails to this Site, online forms, order and registration forms, surveys, promotion participation, phone calls and online chats with our customer service and through other means.

• Payment Services
We may use third-party payment Services (each, a "Payment Service") to collect payments made through this Site. If you wish to make a payment through this Site, you may be directed to a webpage that is hosted by the Payment Service (or the Payment Service's service providers) and not by us. Any Personal Data that you provide through a Payment Service page will be collected by the Payment Service and not by us, and will be subject to the Payment Service's privacy policy, rather than this Policy. We have no control over, and are not responsible for, the Payment Service's use of information collected through the Payment Service page.

• Log data
We may collect log data, such as network and connection information (including Internet Service Provider [ISP] and Internet Protocol [IP] addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.

• Usage information
We may collect usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information), content interactions (including searches, views, downloads, and prints), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction, and similar data.

• Other Means
We may collect information through various other means, including from selected third-party business partners who work with us in relation to our Services and that we may utilize to deliver certain content, products, or Services or to enhance your experience. From time to time, we may also acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our Services.

We ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through this Site or otherwise to us.


Use and Disclosure of Personal Information

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent, or otherwise share for marketing purposes the Personal Information that we collect from third parties, unless you or authorise us to do so.

Personal Information collected is to provide you access, to process orders, to improve, better tailor the features, performance, and support of our platform and to offer you additional information, opportunities, promotions and functionality from us.

We may share some or all of your Personal Information with our affiliated and group companies that are under a common control, so that they may send daily deal emails to you, in which case we will require them to honor this Privacy Policy.

We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to:
a) comply with relevant laws or to respond to subpoenas or warrants served on us; or
b) to protect and defend our rights or property, you, or third parties.

For your information, in certain circumstances your personal information may be stored in a server which is located outside Malaysia. In this instance, we would endeavour to bind the service provider in an agreement that ensures a high standard of privacy protection.


Disclosure of Personal Information to Third Parties

Whenever required by law, we will disclose your information to the government bodies, authorities or third parties pursuant to a subpoena or other legal process accordingly. Further, we may also use or disclose your information as permitted by law to protect the rights or property of Bugworks, our customers, our website, or its users. We may also disclose your information, whether in part or in full,to our contracted or authorised companies such as our data processors. We may also disclose your information, whether in part or in full for marketing and advertising purposes of Bugworks' services.

If you choose to register and transact with Bugworks, your personal information may be shared where necessary and only on a need to know basis with companies within the Bugworks Group of Companies so as to serve you in the most efficient and effective manner.

Bugworks may disclose your personal information to the following parties for the purposes stated below:-

• Companies and/or organisations that act as our agents, contractors, service providers and/or professional advisers
• Companies and/or organisations that assists us in processing and/or fulfilling transactions and providing you with Products and/or Services that you have subscribed or requested
• Law enforcement agencies
• Government agencies

In certain instances, we reserve the right to disclose your personal information to our preferred merchants and strategic partners. We take reasonable steps to ensure that agreements with our merchants and/or strategic partners include appropriate privacy and confidentiality obligations.

If you do not wish your personal information to be shared with these third parties, please email us at hello@bugworks.com.my. Your latest written instructions to us will prevail.

Your personal information will not be disclosed to any unauthorized third party.


Security

We may store your Personal Data. This information is retained and used in accordance with existing laws, rules, regulations, and other policies.

While there is no such thing as “perfect security” on the Internet, we will take reasonable steps to insure the safety of your Personal Data. Personal Data is stored on our server and is not publicly accessible.  To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we take reasonable precautions and have security measures in place to protect the loss, misuse and alteration of the information under our control.  Although we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information.  We are not responsible for any breach of its security or for the actions of any third parties that may obtain any Personal Data.  You are prohibited from violating or attempting to violate security for or otherwise interfering with the operation of this Site.  We do not make, and expressly disclaim, any representation or warranty, express or implied, regarding the security or integrity of this Site and your Personal Data.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by sending an email to hello@bugworks.com.my.


Our Advertising

We may use third-party advertising companies to serve advertisements regarding products and Services that may be of interest to you when you access and use this Site, our apps and other websites or online services, based on information relating to your access to and use of this Site and other websites or online services on any of your devices, as well as on information received from third parties.  To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags).  They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.


Third Party Websites

Our website may contain links to other sites (the "Linked Sites"). We are not responsible for the privacy policies or practices of such other Linked Sites. You agree to waive any claim against us with respect to the Linked Sites.


Your Consent and Rights

The following outlines the choices you have with respect to the collection and use of your personal information by us.

• How to opt out- If you do not want to receive communications and/or services from Bugworks website, please email us at hello@bugworks.com.my. Your latest written instructions to us will prevail.

• What if I receive an email, message or another contact I am not expecting- Along with every e-mail marketing communication sent to you, we provide you the opportunity to discontinue receiving future marketing communications (i.e., unsubscribe). Simply follow the unsubscribe process or directions provided in the email.

• How do I know whether I am opted in- You can always review or update any personal information that we may have collected about you. To do this, log in to your profile on our website or application and look for a checked box for marketing materials. If the box for marketing materials in your profile is unchecked but you continue to receive marketing materials from Bugworks, kindly write in to us at hello@bugworks.com.my.

You are accorded with rights stipulated in the Personal Data Protection Act 2010 and we will be abide by the provisions in PDPA.


Retention Period

We will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Policy, or authorized by you. We will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you).  We depend on you to update or correct your Personal Data whenever necessary.

We will retain Personal Data about you for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).


Cookie Policy

We collect certain types of information when you access or use the Website, including cookies and similar tracking technologies.

Cookies are small data files that are placed on your computer or mobile device when you visit the Website. Cookies are used by the Website in order to make the Website work, or to work more efficiently, as well as to provide reporting information.

You may turn off cookies in your browser via settings. You can cookies on your browser refusing cookies. You may delete cookies. If you turn off cookies, you can continue to use the Website and browse its pages, but the Website and certain services will not work properly.


Contact and Revisions

If you have questions or concerns about our Privacy Policy, please contact us at hello@bugworks.com.my.

This Privacy Policy is subject to occasional revision at our discretion. If you object to any such changes, you must cease using our platform and any further use shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

PRIVACY POLICYTERMS & CONDITIONS