This Privacy Policy (“Policy”) sets out how spacproperty.com.my (“SPAC Property Sdn. Bhd.”,“SPAC Property”, “The platform”, “The portal”, “We”, “Our” or “Us”) collect, use and protect your Personal Data which you have provided to us. By engaging us to provide our services or by accessing our portal such as spacproperty.com.my or using our mobile application (collectively referred as “Portal”), you hereby consent to the processing of your Personal Data by us in the provision of our services (“our Services”).
PERSONAL DATA
The personal data that you provide or have provided to us includes your name, contact details, address, email address, scanned copy of your NRIC, bank account information, video and voice recording, photographs, messages etc. (“Personal Data”). Such Personal Data includes the content that you uploaded on the Portal for the publication of the same to your permitted person(s) upon your passing (“Contents”).
In addition to the Personal Data that you provide to us directly (whether when engaging us to provide our services or during any communication with us), we may also collect your Personal Data from various other sources, including without limitation, from social media, online search tools, external service providers, information obtained from third parties through lawful sources including but not limited to National Registration Department of Malaysia, or at events we have organised or participated by.
If you provide us Personal Data about another person, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:-
give consent on his/her behalf to the processing of his/her Personal Data;
receive on his/her behalf any data protection notices; and
warrant that you have obtained his/her consent for us to store his/her Personal Data or have the right to allow us to process his/her Personal Data.
PURPOSE OF PROCESSING OF PERSONAL DATA
By using our Services, you hereby agree and consent to us using and processing your Personal Data provided to us, in the manner and for the purposes as described below:-
for the purpose of provision of our Services;
for us to communicate with you;
to manage and administer your account, including to process and fulfill your instructions with respect to your nominated person(s);
to identify you on our system;
to be used in, to provide and/or to improve our services, market surveys, processing invoices and payment and client profiling activities regarding our services;
for enforcement against your obligation, including but not limited to the collection of amounts outstanding;
for our internal record keeping;
for internal functions such as evaluating the effectiveness of marketing, market research, statistical analysis and modeling, reporting, audit and risk management;
for prevention and detection of crime (including but not limited to fraud and money laundering);
to conduct client due diligence, to verify your identity, to monitor, detect and deter unauthorised or fraudulent use or abuse of our services;
to meet any legal or regulatory requirements relating to all the commercial transactions, our conduct of the business or activities or our provision of services, and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by laws, guideline, circular, code applicable to us or any member of our group of companies from time to time;
to enable us to send you information by email, regular postal mail, telecommunication means about our services, upcoming events, promotions, advertising, marketing and commercial materials offered by us that we think may interest you;
to maintain our operations or client relationship management systems;
to respond to your enquiries and complaints and to resolve disputes; and
for general operation and maintenance of our Services and/or Portal.
It is voluntary for you to supply your Personal Data to us. However, if you do not wish to provide your Personal Data, we may not be able to:
provide you the services that you require; or
communicate effectively with you.
We may also use and process your Personal Data for other purposes such as:-
to send you materials such as special offers, promotions and marketing information, newsletters, articles, write-ups and other updates; and
to analyse traffic and click stream patterns, demographics of our users base, interests and use of the Services, for general business analytics and in order to constantly improve and maintain our Services and for developing new features and services, if any, by way of email or mail.
THE PERSONAL INFORMATION WE COLLECT ABOUT YOU
We may collect personal information about you including, but not limited to your name, address, phone number, email, gender, occupation, personal interests, information regarding your search activities and behaviour such as the duration of active spacproperty.com.my membership/registration, and any other information provided. For some services and products, we may also collect your personal information to enable verification of your identity, including information from your passport, driver’s licence, and health care and concession cards. If you access any of our services through a social network site or login to the Website using your social network credentials such as Facebook, Google and Apple, we will collect limited information provided to us by that social network site, such as user name, site ID, profile photo and email address.
It is mandatory for you to provide us with your name, contact information and other details marked as mandatory as requested by us. If you choose not to furnish any mandatory personal data requested or wish to withdraw your consent or significantly limit the processing of your personal data, you agree that (notwithstanding any agreement between you and us) we may not be able to provide you with our services and products.
If you submit personal information to us in relation to an employment opportunity, we may also collect information about your employment and academic history.
We may also collect non-personal information about you including, but not limited to, data relating to your activities on the Website (including IP addresses) via tracking technologies such as cookies, web beacons and measurement software or data relating to survey responses.
You acknowledge that the personal information you provide us and which we collect from you, is your own information or information which you have been authorised to provide to us.
DISCLOSURE OF PERSONAL DATA
HOW WE USE YOUR PERSONAL INFORMATION
We use the personal information we have collected largely for the purpose of providing you with products and services that you have requested, responding to your inquiries, creating and maintaining your account and ensuring you comply and adhere to our website terms of use.
More specifically, we may use personal information which it has collected to:
(a) ensure that content from the Websites s presented in the most effective manner for you and for your computer;
(b) provide a better or more relevant service or product to you, for instance by automatically populating forms on the Website when you make enquiries of selected estate agents;
(c) combine your personal information with information that we have collected from its service providers, third parties, cookies or web beacons in order to provide you with a better or more relevant and personalised experience and to improve the quality of its products and services and the services of third parties. This includes using the information to report statistics, analyse trends, administer our services and diagnose problems. For example, we may combine behavioural data we have collected about you through the use of cookies or web beacons and combine it with your personal information from requests you send to us or third parties through the Website;
(d) personalise and customise your services, experience, advertising and content that you view and engage with on the Website or the websites of our service providers and business partners;
(e) respond to or provide you with service, products, information and assistance that you request from us;
(f) contact you to conduct surveys, research and feedback about our products, services or the Website;
(g) verify your identity when you register or log into the Website via your SNS account and remind you of your password and username;
(h) allow you to participate in interactive features of our service, when you choose to do so;
(i) help carry out our obligations arising from any contracts entered into between you and us;
(j) notify you about changes to our products and services; and
(k) use your personal information in direct marketing and/or provide your personal information to another person for gain and/or for use by that person in direct marketing as set out in the USING AND DISCLOSING YOUR PERSONAL INFORMATION FOR MARKETING PURPOSES section below.
If all or part of this information is not provided, we may not be able to provide these services.
If you submit personal information to us in relation to an employment opportunity with us, we may also use your personal information to:
(a) consider you for the position for which you have submitted your personal information to us or any other positions that are or become available in the future;
(b) respond to you in relation to any future application you make for an employment opportunity with us; and
(c) contact your referees in order to collect the information you have consented to us collecting about you in order to consider you for employment opportunities with us.
USING AND DISCLOSING YOUR PERSONAL INFORMATION FOR MARKETING PURPOSES
We may:
(a) use your personal information (ie. your name, residential address, mobile phone number, residential phone number and email address) to provide you with information about offers, promotions, goods or services and for direct marketing real estate, investment and/or financial products/ services (and we may not so use your personal information unless we have received your consent), which we believe may be of interest to you; and
(b) provide your personal information (including your name, residential address, mobile phone number, residential phone number, email address and information regarding your search activities and behaviour such as the duration of active spacproperty.com.my membership/registration) to (i) real estate agents or agencies, property developers, builders, retirement community operators, landlords, financial and investment providers that have listings or advertising on the Website and which you have requested information from by submitting an enquiry; and (ii) our service providers (so that they can provide you with products or services on our behalf or products or services that you have requested directly from them, or to help us to provide you with our products or services) for gain and/or for use by that person in direct marketing real estate, investment and/or financial products/services (and we may not so provide the data unless we have received your written consent to the intended provision); and
(c) share your information (ie. your name, residential address, mobile phone number, residential phone number and email address) with the Company’s related companies, our service providers and other third parties (who are our clients or financial services companies, investment service providers and telecommunications services providers) so that they can provide you with products or services on our behalf or help us to provide you with the requested products or services including contacting you in relation to the products or services.
We may not so use your personal information for direct marketing or share your information with others for direct marketing unless we have received your consent. Further, we will give you the opportunity to request that your information not be used for further direct marketing in the future in our communications with you.
MAIL AND PORTAL
Any Personal Data contained in the emails and “Contact” messages sent via the Portal to us shall be used and processed in the manner set out in the Policy. The content of the messages shall be strictly monitored by us.
If you do not wish for your Personal Data to be collected via cookies on the Portal, please configure your internet browser to delete or deactivate cookies.
The Portal may contain links to other sites and pages. We shall not be responsible for any Personal Data or information that you may provide to other entity via the links.
REQUEST FOR ACCESS AND INQUIRIES
You may at any time hereafter request for access to, or request for rectification or correction of your Personal Data, or limit the processing of your Personal Data by us, as the case may be subject, however to the exceptions and restrictions as may be contained under the applicable law. If you wish to do so, please contact:-
Data Protection Officer
Please note that we have the right to refuse your request to access and/or make any correction to your Personal Data to the extent permitted under the applicable law. In the event of any change in your Personal Data, you are obliged to promptly contact and notify us via the contact details set out in paragraph 5.1 above.
You may also contact us via the above contact details if you have any inquiries or complaints in respect of your Personal Data provided to us.
MINORS
The Portal and/or Services covered by this Policy are not designed for or intentionally targeted at those below 18 years old.
GENERAL
We reserve the right to amend or modify the Policy from time to time.
Any modification or change shall be effective upon posting by SPAC Property Sdn. Bhd. or spacproperty.com.my on the Portal, and you agree to be bound to any such changes or modifications when you use the Portal after any such change is posted.