Privacy Notice – PERSONAL DATA PROTECTION ACT (PDPA)
RealRewards Loyalty Sdn. Bhd. (“RealRewards”) respects the privacy of its customers with regards to personal data. This Privacy Notice is issued in accordance with the Personal Data Protection Act 2010 (“Act”). We believe this Notice enables you to understand the following :
- What kind of Personal Information* RealRewards collects and the ways of collecting it.
- How RealRewards uses your Personal Information.
- The parties that RealRewards discloses your Personal Information to.
- The choices that RealRewards offers, including how to access and update the Personal Information.
*Note: “Personal Information” in this Privacy Notice refers to any information which relates directly or indirectly to you and/or your transactions with us. This information includes your name, address, occupation, contact details, the details of your account(s), the type of products and/or services subscribed to and such other necessary information regarding yourself and your transaction(s) with us. Also, please note that this Privacy Notice is applicable only if you are an individual.
When you apply for our products and services and/or purchase third party products and services distributed by us, you may be required to provide RealRewards with your Personal Information. In doing so, you consent to use of the Personal Information by RealRewards in accordance with this Privacy Notice.
1. Types of Personal Information which we collect and source of information
The types of information which we collect includes but is not limited to data and information pertaining to yourself such as your name, address, e-mail address (or other contact information), age, gender, race, National Registration Identification Card (NRIC) number, financial information such as your bank balance, bank transactions, assets, liabilities and income as well as credit facilities and records with other financial service providers. The information serves to establish your identity, background, financial standing and credit worthiness as well as suitability of the products and services offered by RealRewards and our business partners, if applicable. We may obtain this information from yourself and from a variety of sources, including but not limited to:
- Through your relationship with us, for example information provided by you in application forms, when using our products or services, when taking part in customer surveys, competitions and promotions, and during financial reviews;
- Tthrough your verbal, written and e-mail communications with us and/or our authorised agents;
- From an analysis of the way you use and manage your account(s)/facility(ies) with us, from the transactions you make and from the payments which are made to your account(s)/facility(ies);
- From third parties such as employers, credit reference information providers, government/statutory agencies, and/or
- From such other sources in respect of which you have given your consent to disclose information relating to you and/or where not otherwise restricted.
2. How we use your Personal Information
RealRewards collects, uses, and/or processes your personal data for the following purposes:
- To process application for products offered by RealRewards and/or its business partners and/or services which you had subscribed for;
- To notify you about important changes/developments to the product/service features;
- To assess/verify your credit worthiness;
- To communicate with you including responding to your enquiries and/or complaints and resolving disputes;
- For the purposes of strategic alliances, cross selling, marketing, and promotions; by other units/department/ entities within RealRewards, our agents and third parties;
- To comply with regulatory requirements and provide assistance to law enforcement agencies;
- To research and develop products and/or services;
- To administer and/or manage products and services to you including collecting debts and enforcement of our rights and obligations;
- To improve and develop our services and quality assurance to you;
- To prevent, detect or prosecute cases of fraud/crime and comply with legal and regulatory obligations;
3. Disclosure of your Personal Information
While RealRewards treats your Personal Information as private and confidential, the Personal Information may be disclosed, disseminated and/or transferred to the following :-
- Entities and business units within RealRewards in and outside Malaysia, for the purposes of providing customers with latest marketing and promotional offers which may be of interest to customers;
- Licensees, business partners and third party service providers;
- Professional advisors including consultants, lawyers, accountants, auditors, bankers, rating agencies, trustees, insurers, auctioneers and brokers on a need to know basis for the purposes of providing their services/advices to us;
- Agent or contractors acting on our behalf or appointed by us to act on our behalf;
- Regulatory, government bodies or other authorities if required or authorised to do so to discharge any regulatory function under any law or in relation to any order or judgment of a court;
- Any parties authorised by you;
- Any person or corporation to whom RealRewards may transfer or propose to transfer any part of its interests, obligations, business and/or operations. subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to RealRewards and further subject to your rights as stated in this notice.
You may inform us at any time if you do not wish to receive marketing communications from us, from individual entities within the RealRewards Group and/or from our merchants and business partners by notifying us through the channels stated below in Clause 10 of this notice.
4. Security measures adopted to protect Personal Information
The security of your information is our priority. RealRewards keeps, protects and processes your Personal Information in a secure manner by maintaining physical, electronic and procedural safeguards, in compliance with applicable regulations.
We ensure that access of RealRewards employees to the Personal information which you have provided to us is limited to authorised employees who are trained in handling your information. These authorised personnel are required to ensure the confidentiality of your information and to respect your privacy at all times.
5. Retention of your Personal Information
RealRewards will retain your personal information in compliance with this Privacy Notice and/or the terms and conditions of your agreement(s) with RealRewards for the duration of your relationship with us, for such period as may be necessary to protect the interests of RealRewards and/or its customers as may be deemed necessary, where otherwise required by the law and where required based on RealRewards’s relevant policies.
6. Your obligation to supply Personal Information
To enable us to process your application for products or services offered by RealRewards, you are required to provide Personal Information deemed necessary by RealRewards as indicated in application or service request forms. Should you decline to provide such obligatory personal information, we may not be able to process your application/request or provide you with our products or services.
7. Your rights to access and correct your Personal Information
Keeping your data and information accurate and updated is very important to us. You are responsible to ensure that the Personal Information which you provide to us is accurate, complete and not misleading and that such Personal Information is kept up to date.
You have the right to request for access to your Personal Information and to request for amendment/correction of your Personal Information by contacting us through the channels stated below in Clause 10 of this notice, if you have reason(s) to believe that your records with us are inaccurate, incomplete or not updated.
We will use reasonable efforts to comply with your request to access or correct your personal
information subject to due verification and further communication with you. Please note that RealRewards may have to withhold access to your personal information in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.
Please also note that RealRewards may use its discretion in allowing the corrections requested and/or may require further documentary evidence of the new information to avoid fraud and inaccuracy.
8. Choices over the disclosure, retention and use of your Personal Information
Subject to Clause 6 above and the contractual rights and obligations of RealRewards under relevant laws and regulations, you may exercise your choice in respect of the disclosure, retention and use of your Personal Information. Should you wish to do so, kindly contact us through any of the channels stated below in Clause 10 of this notice.
9. Revisions to Privacy Notice
RealRewards reserves the right to amend this Privacy Notice from time to time.
10. Contacting RealRewards on your Personal Information and this notice
Should you wish to request for access to your Personal Information, request for amendment/correction of such Personal Information or provide any feedback to RealRewards on this Privacy Notice, you may contact us at the following address, phone no. and/or e-mail :-