This Personal Data Protection & Privacy Policy (“Policy”) is created, owned and managed by Cun Cun First Trading Sdn Bhd Company No. 202001028027 (1384347-U) (“Company”).
This Policy applies to:
(1) the Company’s self-owned mobile application called “Cun Cun Mobile Application (“Mobile Application”); and
(2) the Company’s self-owned website at www.cuncun2u.com (“Website”).
Full Consent to the Company
This Policy is created in line to the requirements set pursuant to the Personal Data Protection Act 2010 (“Act”).
By downloading, installing, browsing, using, purchasing, subscribing, interacting, communicating and/or viewing the Company’s Mobile Application and/or Website, you (as the user and/or member of the Mobile Application and/or Website) hereby agree and give full consent to the Company (including, but not limited to, the Company’s employees, representatives, merchants, retailers, suppliers and/or agents) to collect, use, record, keep, utilise, disclose and/or share your personal information and data (“Personal Data”) for purposes and in the manner as set out in this Policy.
Your full consent and agreement in regard to your Personal Data as set out in this Policy shall be valid, binding, effective and/or legal from the date and time you download, install, browse, use, purchase, subscribe, interact, communicate and/or view the Company’s Mobile Application and/or Website and shall last as long as it is deemed necessary and useful for the Company to keep and held your Personal Data.
This Policy supplements but does not supersede nor replace any other consents you may have previously provided to the Company in respect of your Personal Data.
Changes and Amendments
Kindly be noted that this Policy may be revised, changed and/or amended from time to time to keep up with the changes to the Act and/or any other laws in Malaysia. In such event, you hereby agree to adhere and comply with whatsoever changes made to this Policy by the Company.
Personal Data
“Personal Data” refers to any personal information, data, records, documents and/or details, whether true or not, of an individual who can be identified from:
(a) that personal information, data, records, documents and/or details; or
(b) that personal information, data, records, documents and/or details to which the Company has or are likely to have access, including data in the Company’s records as may be updated from time to time.
Examples of Personal Data which you may provide to the Company (depending on the nature of your interaction with us) usually include, but not limited to, your name, NRIC/Passport No. or other identification number, credit card details, banking details, telephone number(s), mailing address, email address, personal health information, personal interest and hobby, shopping preferences and/or any other information relating to any individuals which you may have provided us during your interaction with us through the Mobile Application and/or Website.
Purpose of Collection of Personal Data
Generally, the Company collects Personal Data in the following ways:
(1) when you submit any information, details, data, documents and/or forms during your downloading, installing, browsing, using, purchasing, subscribing, interacting, communicating and/or viewing the Company’s Mobile Application and/or Website;
(2) when you interact with the Company through any communication channels available or acceptable to the Company;
(3) when you conduct any transaction and/or payment on the Company’s Mobile Application and/or Website;
(4) when you submit any request and/or complaints to the Company;
(5) when you participate, responded or convey your interest in any of the Company’s marketing and/or promotional activities on various platforms and channels (online and offline);
(6) when you responded to any request by the Company seeking your Personal Data in connection with your relationship with us as our Customer and user of our services and facilities; and
(7) when you submit your Personal Data to us for any other reasons not stated above.
When you are downloading, installing, browsing, using, purchasing, subscribing, interacting, communicating and/or viewing the Company’s Mobile Application and/or Website, you generally do so anonymously. We do not, on our Mobile Application and/or Website, automatically collect Personal Data unless you provide such information of your Personal Data to us.
Third Party Personal Data
If you provide us with any Personal Data of another party or relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of another party or third party to provide us with their Personal Data for the respective purposes.
Accuracy and Completeness of Personal Data
The Company shall not any point of time be held liable or responsible for any impact or issues relating to the accuracy and/or completeness of the Personal Data provided to the Company.
Instead, you should ensure that all Personal Data submitted to the Company is complete, accurate, true and correct.
Kindly be reminded that any inaccuracy, incomplete and/or false Personal Data provided to the Company may cause the Company to be unable to provide you with certain services, response, communication and/or transaction whatsoever. In such circumstances, the Company shall never howsoever be held accountable and liable.
The Company understand that from time to time, certain Personal Data requires updating. Therefore, you hereby agree to provide your latest updated Personal Data to the Company by contacting and updating the Company accordingly. The main purpose of providing the Company with the latest updated Personal Data is to ensure that the Company will be able to provide effective services to you (especially in communicating the latest promotional and/or marketing campaign relating to the Mobile Application and/or Website).
Personal Data of Person Under 18 Years Old
The Company will never knowingly collect or solicit Personal Data from individuals under the age of eighteen (18) without first obtaining verifiable parental consent.
If you are under the age of 18, you should not provide any Personal Data to the Company.
In any event, if the Company is or become aware that a person under 18 has provided Personal Data without verifiable parental consent (as may be the case where the information is provided via the Mobile Application and/or Website), the Company will remove such Personal Data as soon as practicable to do so.
Purposes for the Collection, Use and Disclosure of Your Personal Data
Generally, the Company collects, uses and discloses your Personal Data for the following purposes:
(1) responding to, processing and handling your queries, feedback, complaints and/or requests;
(2) verifying your identity;
(3) processing your membership and/or registration for the Mobile Application and/or Website;
(4) managing all administrative matters involving your interactions, downloading, installing, browsing, using, purchasing, subscribing, interacting, communicating and/or viewing the Company’s Mobile Application and/or Website;
(5) requesting for your feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for the Company to design its services, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of the Mobile Application and/or Website (as relevant);
(6) preventing, detecting and/or investigating a crime or any suspicious activity to minimise any commercial risk on the Mobile Application and/or Website;
(7) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(8) in connection with any claims, actions or proceedings (including, but not limited to, drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
(9) conducting any form of investigations including, but not related to, those relating to disputes, billing, fraud, offences, prosecutions etc.;
(10) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on the Company (including, but not limited to, responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations);
(11) personalising your experience with the Company, the Mobile Application and/or Website and conducting market research, understanding and analysing customer behaviour, location, preferences and demographics in order to improve the service offerings on the Mobile Application and/or Website;
(12) administering debt recovery and debt management (in the event of any payment disputes etc); and/or
(13) any other purposes which are related to the Mobile Application and/or Website which are not stated above.
Disclosure of Personal Data
The Company will take reasonable steps to protect your Personal Data against unauthorised disclosure pursuant to the Act.
Subject to the provisions of the Act and any applicable laws in Malaysia, your Personal Data may be disclosed, for the purposes listed below (where applicable), to the following entities or parties, whether they are located overseas or in Malaysia:
(1) amongst the Company’s employees, representatives, merchants, members, subsidiaries, related companies and/or affiliates (as applicable) for marketing and promotional purposes relating to the Mobile Application and/or Website;
(2) amongst the Company’s agents, contractors, sub-contractors or third-party service providers who provide services to the Company, such as courier services, telecommunications, information technology, payment, printing, billing, debt recovery, processing, technical services, transportation, training, market research, call centre, security, or other services to the Company, the Mobile Application and/or Website;
(3) amongst vendors or third-party service providers and the Company’s marketing and business partners in connection with marketing promotions, products and services of the Mobile Application and/or Website;
(4) our corporate clients, business partner, investor, assignee or transferee (actual or prospective) and/or any potential collaborator to facilitate business, asset, growth, monetary and corporate transactions (which may extend to any merger, acquisition or asset sale);
(5) external banks, credit card companies, other financial institutions and their respective service providers concerning the activities or matters relating to the Mobile Application and/or Website;
(6) the Company’s professional advisers such as consultants, auditors and/or lawyers;
(7) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
(8) any other party who is related to our Mobile Application and/or Website who are stated above.
In general, kindly be noted that your Personal Data will only be disclosed for purposes related to the Mobile Application and/or Website only and will be pursuant to the Act.
Safekeeping & Security of Personal Data
The Company will protect all Personal Data against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Data, regardless of the format in which it is held.
In this regard, the Company uses various methods and procedures to safeguard your Personal Data, including physical measures, technical tools and/or organisational controls.
Online security is also a priority and therefore, the Company shall incorporate various security measures such as encryption and authentication tools to protect your Personal Data from any unauthorized use. Firewalls are utilized to protect the Company’s servers and network from any unauthorized users accessing and tampering with files and other information that the Company store.
While it is impossible for the Company to provide any absolute guarantee that there shall be no loss, theft, misuse and/or stealing of Personal Data, it is the Company’s upmost priority to always ensure that reasonable efforts have been put in place to prevent any unfortunate breach of security of the Personal Data. This includes the Company installing appropriate security measures on its systems and network.
Consent for the Company to Retain Personal Data
You hereby agree and consent to the Company to retain your Personal Data for so long as the Company deemed fit for the purposes set out in this Policy.
Use of Cookies, Web Beacons, and Similar Technologies on the Mobile Application & Website
When you are downloading, installing, browsing, using, purchasing, subscribing, interacting, communicating and/or viewing the Company’s Mobile Application and/or Website, the Company (or any of the service providers engaged by the Company) may use cookies, web beacons, and other similar technologies for collecting and storing certain information and Personal Data to help the Company to provide you with a better, faster and safer Mobile Application and/or Website browsing experience.
The certain information and Personal Data collected by the Company (or any of the service providers engaged by the Company) may recognise you as a visitor, potential customer, members etc. and may collect information such as how you arrived at the Mobile Application and/or Website, the type of browser you are using, the type of operating system you are using, your IP address, your click stream information and time stamp (for example, which section or link on the Mobile Application and/or Website that you have viewed, the time the pages were accessed and the time spent per web page etc.).
The use of cookies, web beacons and similar technologies by the Company (or any of the service providers engaged by the Company) on the Mobile Application and/or Website has different functions. They are either necessary for the functioning of the Mobile Application and/or Website, to help the Company to improve its performance, or to provide you with extra functionalities. It may also be used to deliver content that is more relevant to you and your interests, or to target advertising to you on or off our Mobile Application and/or Website.
Third-Party Sites
Our Mobile Application and/or Website may contain links to other website or applications operated by third parties.
We are not in way howsoever be responsible for the data protection practices of the websites operated by third parties that are linked on our Mobile Application and/or Website.
Therefore, we encourage our Mobile Application and Website’s users and visitors to learn or enquire about the data protection practices of such third-party websites. Some of these third-party websites may be co-branded with our logo or trade mark, even though they are not operated or maintained by us.
Once you have left or close the Company’s Mobile Application and/or Website, you should check the applicable data privacy policy of the third-party website to determine how they will handle any personal data and/or information they collect from you.
Contacting Us
The Company has procedures in place in order to receive and respond to enquiries about this Policy and/or practices relating to its handling of Personal Data. Any complaint or enquiry in relation to the Mobile Application, Website or this Policy should be made in writing and addressed as shown below:
Updates and Amendments
This Policy, the Company’s Mobile Application and/or Website will continuously be reviewed against upcoming new technologies, business practices and our customers’ needs. As we update and diversify our products and/or services, this Policy may evolve and change from time to time.
Therefore, the Company hereby reserves the right to change and/or revise this Policy at any time. In such circumstances, an updated version of this Policy will be posted on the Mobile Application and/or Website, as appropriate.
Governing Laws
The Company’s Mobile Application, Website and this Policy shall be based on the laws of Malaysia.
Any disputes to the Company’s Mobile Application, Website and this Policy shall be subject to the exclusive jurisdiction of the courts in Malaysia only.
The Company at all times reserves all rights and discretion to initiate any actions against any users or members who violate the Mobile Application, Website and/or this Policy (including, but not limited to, legal action and lodging of reports with the relevant authorities including the police).
English Version to Always Prevail
In circumstances that this Policy is translated to any other languages and there’s confusion, conflict, ambiguity, uncertainty and/or dispute on of the clauses herein, the Parties hereby agree that the English Version of this Policy shall always prevails over any other languages’ version of this Policy, as applicable.
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