Privacy Policy and Personal Data Notice

1. Introduction

We, Oodlins, a brand or product of Squincy Sdn. Bhd. (Company No. 1233986T) (hereinafter referred to as the “Oodlins”, “Squincy”, “We”, “Us” or “Our” or “The Company”) are committed to protecting the privacy of personal information and/or data you may provide us on this website (the “Site”) and/or through other modes of communication such as mobile application, social media, emails and telephonic communication.

Pursuant to the requirements of the Personal Data Protection Act 2010 (hereinafter referred to as “PDPA”), this Notice is also issued to all our valued users and/or prospective users. Oodlins is committed to the protection of your personal data and compliance of all applicable personal data protection laws and regulations in Malaysia. The following statements explain the general terms of Oodlins regarding the collection and processing of your personal data by Oodlins.

2. Your Consent

By providing your personal data to Oodlins, you have read and accepted the statements herein; and you have consented to the processing of your personal data by Oodlins in the manner set out herein. If you provide personal data of third parties to Oodlins, you warrant and represent to Oodlins that you have obtained the required consent of the third parties for the processing of the relevant personal data by Oodlins in the manner set out herein. If you do not agree to this, you must not use the Oodlins site or mobile application.

3. Collection of Information or Personal Data

a) The Company will collect your personal information and/or data that you voluntarily provide on online or offline forms: user registration, contact requests, comments, online surveys; and other online / social media and telephonic activities including but not limited to service ordering and general inquiry and customer service activities.

b) Oodlins collects your information when you register on the Oodlins mobile application or Web Site or when you visit Oodlins pages or when you sign up on mobile application.

c) Personal Information: We may collect the following types of personal information in order to provide you with the use and access to the Oodlins site, mobile application, services and tools, and for any additional purposes set out herein:

  • Personal data may include (but not limited to) name as per identity card, and contact information, such as email address, phone number, mobile telephone number, residential address, and (depending on the service used) sometimes financial information, such as bank account numbers; information of your company such as name, registration number, company address, and such other data necessary for the purposes which the personal data is collected.
  • transactional information based on your activities on the sites (such as bidding, buying, selling, item and content you generate or that relates to your account), billing and other information you provide to purchase an item;
  • personal information you provide to us voluntarily through correspondence, chats, dispute resolution, or shared by you from other social applications, services or websites;
  • additional personal information we ask you to submit to authenticate yourself if we believe you are violating site policies (for example, we may ask you to send us an ID to answer additional questions online to help verify your identity);
  • information from your interaction with our sites, services, content and advertising, including, but not limited to, device ID, device type, location, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information.

d) Aggregate Information: Oodlins collects non-identifying, general, generic and aggregate information to better design our Web site and services.

e) Non-Personal Information: Oodlins may collect non-personal information as you use Oodlins. When you use the site, Oodlins, third-party service providers (e.g. Google Analytics), and partners may receive and record non-personal information from cookies, server logs, and similar technology from your browser or mobile device, including your IP address.

f) We may combine some Non-Personal Information with the Personal Information we collect. Where we do so, we will treat the combined information as Personal Information if the resulting combination may be used to readily identify or locate you in the same manner as Personal Information alone.

4. Storing of information

We use hosting provider Amazon Web Services, Google Cloud and Digital Ocean, therefore your information may be transferred to and stored on servers in various locations both in and outside of Malaysia. Oodlins and/or The Company maintains control of your information. We protect your information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorisation controls.

5. Purpose of collecting Personal Information/ Data

a) When you use the Oodlins site or mobile application, we may request certain information. Oodlins does not share any of your personally identifiable or transactional information with any person or entity, other than as set out in this policy. No other third party receives your personally identifiable information or other transactional data except for approximate location / geo-location information when you use the services and those with whom you have transactions and share that information.

b) The information we collect is used to notify consumers about updates to our web site or mobile application and for communications to administer customer relationship management procedures;

c) To communicate with your and/or your company in the use of Oodlins productivity tool for schools;

d) To process your purchase(s) in facilitating payment in connection with the business or contractual dealings between Oodlins and you and/or your company and/or the Parents;

e) Email Communications: We may send you a welcome email to verify your account and other transactional emails for operational purposes, such as billing, account management, or system maintenance. You may only stop those emails by terminating your account. We may also send you promotions, product announcements, surveys, newsletters, developer updates, product evaluations, and event information or other marketing or commercial e-mails. You can opt out of receiving these email communications from Oodlins at any time by unsubscribing using the unsubscribe link within each email, updating your preferences on your Oodlins account or emailing us at [email protected] or contact us at +6012-2020698 to have your contact information removed from our email list or registration database.

f) Text communications: We may send you text messages to your secure phone number for operational purposes, such as notifying you about the status of payment, attendance or any related Oodlins postings. We may also send you information about products, services and/or promotions offered by the Companies and selected third parties that we think may interest you. You can opt out of receiving these text messages from Oodlins at any time by updating your notifications preferences on your Oodlins Settings account in the App.

g) Marketing: You agree that we may use your personal information to tell you about our services and tools, deliver targeted marketing and promotional offers based on your communication preferences, and customise measure and improve our advertising. To provide you with information about the activities, products, services, events and programmes that may be organized, managed, facilitated, provided, sponsored and/or participated by Oodlins; or to provide you information offered by selected third parties that may interest you;

h) To conduct research, study, assessment, survey and/or prepare reports/statistics for purpose of Oodlins’ business activities;

i) We do not rent, sell, or share Personal Information about you with other people or non- affiliated companies for marketing purposes (including direct marketing purposes) without your permission. We may use and share Non-Personal Information for our marketing purposes, including, without limitation, marketing on other websites. For example, we may use the information to control the number of times you have seen an ad, deliver ads tailored to your interests, and measure the effectiveness of ad campaigns. You can prevent us from tailoring our ads to you on other websites by deleting your cookies (see below).

j) To comply with any legal or regulatory requirements applicable to Oodlins and to make disclosure under the requirements of any law, regulation, direction, court order, by-law, guideline, circular or code applicable to Oodlins;

k) To maintain and update internal record keeping.

6. Sharing your Information

a) We disclose personal information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations. As stated above, we do not disclose your personal information to third parties for their marketing purposes without your explicit consent.

b) We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

c) We may disclose your personal information upon a business transition; At the sale or transfer of Oodlins and/or all or part of its assets, your personal information may be among the items sold or transferred.

d) We may disclose your personal information to entities located outside of Malaysia, including our related bodies corporate, shareholders, subsidiaries within or outside Malaysia, government agencies, agents, contractors, auditors, consultants, accountants, insurers, lawyers or other financial or professional advisers of Oodlins regulatory bodies, government bodies or other authorities if required or authorized to do so to discharge any regulatory function under any law or in relation to any order or judgment of a court, financial institutions for purposes of facilitating payments and/or maintaining financial records in connection with the business or contract relationship between Oodlins and you and/or your company, any person to whom Oodlins is compelled or required to do so under the law.

e) We may share aggregate data with advertisers and other third parties. Oodlins uses industry-standard encryption technologies when transferring and receiving consumer and transaction data exchanged with our site.

f) Please note that your personal data is necessary for Oodlins to carry out the aforesaid purposes. The failure to supply such personal data will or may: result in Oodlins being unable to administer the business or contractual relationship between Oodlins and you and/or your company; result in Oodlins being unable to provide you with information about the activities, products, services, events and programmes organized, managed, facilitated, provided, sponsored and/or participated by Oodlins ; and/or result in Oodlins being unable to provide you with information about the products, services, events and programmes offered by selected third parties which may interest you.

g) If you have any inquiries or complaints in respect of the personal data, kindly communicate to Oodlins in writing at the postal address: A-05-02, Empire Office, Empire Subang, 47500 Selangor. Malaysia. or email address [email protected].

7. Cookies

a) Cookies are pieces of data assigned by a web server that uniquely identify the browser on your PC. Oodlins uses cookies called “persistent” cookies to enable the site to remember you on subsequent visits, speeding up or enhancing your experience of services or functions offered. Cookies also enable our systems to gather information about your navigational patterns through the site. You have the option to disable cookies at any time through your browsers. We may also store your website activity in cookies which may be used by third party vendors, including Google, to serve ads based on your behaviour on our website.

b) The third party vendors (e.g. Google Analytics) may receive and record non-personal information from cookies, server logs, and similar technology from your browser or mobile device, including your IP address. You may opt out of Google’s use of cookies by visiting the Google advertising opt-out page

c) If you access our Services with your login credentials from a social networking site (e.g., Facebook or Twitter) or if you otherwise agree to associate your Oodlins account with a social networking account, we may receive personal information about you from such social networking site, in accordance with the terms of use and privacy policy of the social networking site. For example, Facebook may share with us your friend list, birthday, information about the interests of you or your friends or other personal information, in order to help us establish your account, tailor services to you and find other current or potential site users that you know. We may add this information to the information we have already collected from you via other aspects of the Site. You are also subject to the social networking site’s terms of use and privacy policy. We use the OAuth (open authorisation) protocol to enable us to access this information without collecting your password when you agree allow another application to access your account information.

8. Rights for access and correction or modification of information

a) You can update your information through your account profile settings. If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it (in writing and/or via email).

b) You can correct or modify your personal information and/or data which is inaccurate, incomplete, misleading and/or not up-to-date at any time through any channels provided by the Company.

c) Additionally, you may request access to any personal information we hold about you at any time by contacting us at [email protected] Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

d) There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

e) If you have any request in relation to the abovementioned rights and/or for any inquiry in respect of your personal Information and/or Data, please write to and/or contact the following: –

Company         : SQUINCY SDN BHD

Contact No       : +603-5633 6080

Email                : [email protected]

Company Address: A-05-02 EMPIRE OFFICE, EMPIRE SUBANG, 47500 SELANGOR. MALAYSIA

9. Security of Your Personal Data

Oodlins has implemented security policies and technical measures to protect your personal data in accordance with such requirements of the applicable personal data protection laws and regulations. Where we consider it necessary or appropriate for the purpose of data storage or processing, we may transfer the personal data to a third-party service or product providers within or outside Malaysia, under similar level of security measures.

Nevertheless, the Company will not be responsible for any event arising from unauthorised access to or theft of your Personal Information or Data. The Company will not be held responsible for events arising from third parties gaining unauthorised access to or third parties’ theft of your personal information and/or data.

10. Changes to our privacy policy and PDPA

We may change this privacy policy and PDPA from time to time. Any updated versions of this privacy policy and PDPA will be posted on our website. We recommend to review the most updated version of this statement each time you provide your personal data to Oodlins and/or Squincy.

This privacy policy was last updated on 7th August 2019.