Privacy Policy

Privacy Policy

1. This policy sets out how we handle your personal information if you are a corporatetrainer.com.my user or visitor to our Sites. It applies across all our sites, including corporatetrainer.com.my (the “Sites”) and our products, features, services, software applications, programs, add-ons, extensions, plug-ins, and other technologies we may develop or use from time to time (the “Products”).

2. All our employees, agents and contractors are responsible for protecting personal information collected and processed by Daphmar Capital Sdn. Bhd. It is the responsibility of all our employees, agents and contractors to assist in the protection of personal information by acting in accordance with this policy.

3. When we say ‘we’, ‘us’ or ‘Daphmar Capital Sdn. Bhd’ it’s because that’s who we are and we own and run the Sites and/or Products.

4. If we say ‘policy’ we’re talking about this privacy policy. If we say ‘user terms’ we’re talking about the rules for using each of the Sites and/or Products. The rules vary by product and each product makes them separately available and seeks consent to them separately from this policy.

The type of personal information we collect

5. We collect certain personal information about visitors and users of our Sites and/or Products.

6. The most common types of information we collect include things like: user-names, member names, email addresses, IP addresses, other contact details, survey responses, blogs, photos, payment information such as payment agent details, transactional details, tax information, support queries, forum comments (if applicable), content you direct us to make available on our Sites and/or Products (such as item descriptions and other information you choose to make available on your profile) and, your actions on our Sites and/or Products (including any selections or inputs into items, or text or image prompts) and web and email analytics data. We will also collect personal information from correspondence between you and us when you contact us.

How we collect personal information

7. We collect personal information:

   • Directly when you provide it to us. For example, when you complete forms such as free trials, membership, email list, subscription or competition registrations, when you submit feedback or send us any other type of communication, or when you make transactions such as buying or providing services on our Sites or Products;

   • automatically as you navigate through the Sites and/or Products;

   • Indirectly through other businesses that provide services associated with the Sites and/or Products, when you use those services.

Personal information we collect about you from others

8. Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular, this may include:

   1. financial and/or transaction details from payment providers in order to process a transaction;

   2. third party service providers (like Google and Facebook) who are located in various countries, which may provide information about you when you link, connect, or login to your account with the third party provider and they send us information such as your registration and profile from that service. The information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider; and

   3. Other third party sources/and or partners from various countries, whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you.

   4. The Subscriber of the account, if you’re a member of a team, agency or other organisation that uses our Sites and/or Products.

How we use personal information

9. We will use your personal information:

   1. to perform our contractual obligations towards you as you browse and use the Sites and/or Products in particular, by facilitating and processing transactions that take place on the Sites and/or Products, such as when you purchase a service from our marketplace or subscription service;

   2. when it is necessary for purposes which are in our, or third parties’, legitimate interests. These interests include:

      1. operating the Sites and/or Products;

      2. providing the services described on the Sites and/or Products;

• verifying your identity when you sign in to any of our Sites and/or Products;

1. responding to support tickets, and helping facilitate the resolution of any disputes;

2. updating you with operational news and information about our Sites and/or Products e.g. to notify you about changes to our Sites and/or Products, outages;

3. carrying out technical analysis to determine how to improve the Sites and/or Products we provide and to create new Sites and/or Products;

• monitoring activity on the Sites and/or Products, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Sites and/or Products;

• managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites and/or Products or asking for your feedback or whether you want to participate in a survey;

1. managing our legal and operational affairs (including, managing risks relating to content and fraud matters);

2. training our staff about how to best serve our user community;

3. improving existing and creating new products and services;

• providing general administrative and performance functions and activities;

• verifying your identity including by comparing a selfie taken by you against your Photo ID document using facial recognition technology (subject to your explicit consent if required by applicable law);

• using data analytics to measure the effectiveness of advertising and marketing of the Sites, and improve the optimization of our Sites and/or Products (including by way of data analytics tools);

1. subject to your consent (where required), and unless you have opted out of receiving marketing communications, providing you with marketing information about products and services which we feel may interest you. You can opt out of such communications by following the unsubscribe mechanism on any communication, or by otherwise contacting us as set out at the end of this policy;

2. subject to your consent (where required), customising our services and websites, like advertising that appears on the Sites in order to provide a more personalised experience;

3. for purposes which are required by law, or, where we have a legitimate interest, to respond to and/or defend ourselves against complaints, disputes or legal claims;

4. for the purpose of responding to requests by government, a court of law, or law enforcement authorities; or

5. where we require your personal information to comply with legal or contractual obligations.

10. If we can’t collect and use data for these purposes, then we may not be able to manage our contractual relationship with you, provide you with the Sites and/or Products, or meet legal obligations placed on us. In all other cases, provision of requested personal information is optional.

When we disclose your personal information

11. We will disclose personal information to the following recipients:

    1. companies that are in the Daphmar Capital Sdn. Bhd. Group.

    2. if applicable, authors of any items or services made available to you, so they can facilitate support and license validation, who may be located in any of the countries our products are available in;

    3. the Subscriber of the account, if you’re a member of a team, agency or other organisation that uses our Sites and/or Products;

    4. If applicable, anyone who uses assets that you have made available through our Sites and/or Products;

    5. subcontractors and service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers; technical and customer support services; marketing and analytics services; security and fraud prevention services; subscription management services; payment processing services; and operational tooling services. Noting that our subcontractors and services providers may also transfer and access such information from other countries in which they have operations;

    6. our professional advisers (lawyers, accountants, financial advisers etc.);

    7. regulators and government authorities in connection with our compliance procedures and obligations;

    8. a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;

    9. a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;

    10. a third party, in order to enforce or defend our rights, or to address financial or reputational risks;

    11. a rights holder in relation to an allegation of intellectual property infringement or any other infringement; and

    12. other recipients where we are authorised or required by law, or requests by government, a court of law, or law enforcement authorities, to do so.

Where we transfer and/or store your personal information

12. We are based in Malaysia so when your data is transferred to us it will be processed in the country. Some of the recipients we have described in the section 11 above, and to whom we disclose your personal information, are based around the world. When we transfer data to these recipients, we do this on the basis of this policy and we will ensure that relevant safeguards are in place to afford adequate protection for your personal information and we will comply with applicable data protection laws. We also take care to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

How we keep your personal information secure

13. We store personal information on secure servers that are managed by our service providers. We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of the personal information we process, including username and password authentication, two-factor authentication, and data encryption where appropriate. Unfortunately, data transmission over the internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee its security.

Your rights relating to your personal information

14. Depending on the jurisdiction you are located in, you may have the following rights, as provided under applicable law and subject to any limitations in such law:

    1. To accessthe personal information we hold about you;

    2. To request we correctany inaccurate personal information we hold about you;

    3. To request we deleteany personal information we hold about you;

    4. To restrictthe processing of personal information we hold about you;

    5. To objectto the processing of personal information we hold about you; and/or;

    6. To receiveany personal information we hold about you in a structured and commonly used machine readable format or have such personal information transmitted to another company.

15. Please note that, prior to any response to the exercise of such rights, we may require you to verify your identity or confirm the specific right that you’re seeking to exercise, by providing any or all of the following information, in accordance with the provisions of the applicable law in each country: (i) name and address or other means to communicate the response to your request; (ii) documents proving your identity or, of your legal representative, if applicable; (iii) a clear and precise description of the personal information in respect of which the applicable right applies; (iv) the express manifestation to revoke your consent to the processing of your personal information and, therefore, not to use it; and (v) any other element that facilitates the location of the personal information.

16. If you seek to exercise any of the rights described in section 15, we may need to pass on costs that are strictly necessary for the reproduction, modification or sending of personal information to you. Otherwise, your exercise of these rights will be free of charge.

17. You can access or correct some of the personal information that we collect about you by logging in to your account. You can also close the account you have with us for any of our Sites at any time. To make a request to exercise any other rights you have, contact us using the contact details at the end of this policy.

Marketing choices regarding your personal information

18. We may send you marketing communications by email about products and services that we feel may be of interest to you and will obtain your consent, where it is required by law. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

19. You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Sites may not work properly in your case.

Information you make public or give to others

20. If you make your personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data. There are lots of ways that you can find yourself providing information to other people, like when you post a public message on a forum thread, share information via social media, or make contact with another user (such as a third party Author) whether via our Sites and/or Products or directly via email. Before making your information publicly available or giving your information to anyone else, think carefully. If giving information to another user via our Sites and/or Products, ask them how they will handle your information. If you’re sharing information via another website, check the privacy policy for that site to understand its information management practices as this policy will not apply.

How long we keep your personal information and how you can manage or delete your personal information

21. We retain your personal information for as long as is necessary for the purposes outlined in this policy. To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and other applicable legal requirements.

22. If you no longer want us to provide you with the services, or if you would like to exercise any of the rights set out in paragraph 14, please contact us at info@corporatetrainer.com.my

23. Please note that if you request the erasure of your personal information we may retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations or requests by government, a court of law, or law enforcement authorities, enforce the terms of service and take other actions permitted by law. Any information we retain will be handled in accordance with this policy.

When we need to update this policy

24. We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.

25. When we do change the policy, we take steps to notify you about such changes, where required by applicable law. A copy of the latest version of this policy will be available on this page or other websites.

How you can contact our Data Protection Officer

26. If you wish to exercise any of your rights under this policy, or have any inquiries or complaints about our privacy practices or the way in which we have been managing your personal information, in the first instance please contact our Data Protection Officer at info@corporatetrainer.com.my. We ask that when you provide any information to us, (a) you provide sufficient information that allows us to reasonably verify you or are an authorised representative of that person; and (b) provide sufficient detail such that we understand and can evaluate your request. We will deal with the matter within a reasonable time, and within any timeframe prescribed by applicable law, and keep you informed of the progress of our investigation.

Complaints

1. If you contact us with a complaint about our handling of your information, we will acknowledge receipt of the complaint, attend to all complaints promptly and seek to resolve any complaint as soon as reasonably practicable.

2. If you have unresolved concerns after contacting us, you may also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country.