1.1 Optimum Train Sdn Bhd (“us”, “we”, or “our”) operates the OTfresh website (the “Service”). This Privacy Policy applies to personal information about individuals, be it site visitors, customers, service providers and/or business partners, held by Optimum Train Sdn Bhd, a company incorporated in Malaysia and having its place of business at 138, Persiaran Raja Muda Musa, 41200 Klang, Selangor, Malaysia and/or its affiliates. By providing your personal information to us and/or visiting or using any of the pages available on www.otfresh.my (the “Website”), on which this Privacy Policy or a link to this Privacy Policy appears, you are deemed to have read the following policy and agree to us processing your personal information in accordance with the terms of this Privacy Policy.
We comply with the Personal Data Protection Act 2010 (“PDPA 2010”), which regulates how we collect, use, disclose, store, correct and protect your personal information.
PERSONAL DATA
2.1 Personal data is any personal information from which an individual would be identifiable, it includes information such as name, date of birth, email address, telephone number, NRIC, address, credit card information et cetera (hereinafter referred to as “Personal Data”).
COLLECTION OF PERSONAL DATA
3.1 In accordance with the principles of the PDPA, we will notify you of the purposes and obtain your consent for the collection of your personal data, unless an exception under the law permits us to collect and process your personal data without your consent.
3.2 We collect personal data when:
a. you make purchases online;
b. you set up an account on our Website or subscribe to our membership;
c. you contact our customer relations center, either online or through the phone;
d. you agree to participate in a customer contest, competition, survey, interview or product testing;
e. you conduct certain types of transactions, such as an application for a refund;
f. you provide feedback or complaints in relation to our products or our services either online or through the phone.
USER AND PROCESSING OF PERSONAL DATA
4.1 Personal data collected may be used for various purposes, including but not limited to: a. communicating with you so as to better address your needs;
b. manage your orders and payment online, the subsequent home delivery or self-collection of products as well as exchanges or returns of products, if applicable;
c. identify you as a OTfresh member so as to allow you to benefit from the membership program;
d. management of marketing communication so as to ensure you only receive communication e-mails that are of relevance to you;
e. management of customer reviews on products;
f. facilitate your participation in our organization of customer contests, competitions, surveys, interviews or product tests;
g. conduct market research or surveys, marketing analysis, customer profiling activities, analysis of customer choices, statistical and trend analysis in relation to our products and/or services;
h. management of after sales services, such as enabling us to contact you in the event of any defective components, or to offer workshop services or to contact you in the event of product recalls;
i. contact you about functionality changes to our Website.
4.2 As a general rule, OTfresh processes your personal data and ensures the security and confidentiality of your personal data. OTfresh will not share or disclose your personal data to any individuals or third party operators, the exception being where OTfresh engages service providers to perform specific services on our behalf and for purposes mentioned in clause 4.1 above, including but not limited to the following:
a. delivery of products ordered through our Website;
b. hosting your personal data in data centers through storage facility providers;
c. statistical and analytical studies;
d. monitoring the quality of our service or Website;
e. improving advertising campaigns or promotions, marketing and business efficiencies and prospective sales.
In such situations, the service providers are authorized to use your personal data only to perform the specific services entrusted by OTfresh. As part of our agreement with them, they are required to take all reasonable measures to ensure and maintain a high level of security of your personal data.
PROTECTION AND SECURITY OF PERSONAL DATA
5.1 We take all the necessary precautions to ensure the confidentiality of your personal data. We have the necessary technical and organizational measures in place to safeguard the personal data that you provide and to prevent its disclosure to unauthorized third parties. Such measures include the use of encryption where personal data is entered on our Website as well as limited access to your personal data.
5.2 Transfer of Data outside of Malaysia
As we may outsource some of our data processing, your personal data may be transferred to, accessed in and stored at a destination outside Malaysia. Where such a transfer occurs, we ask that the third parties provide sufficient guarantees to implement appropriate and adequate technical and organizational measures to such a degree that will ensure the security and protection of your personal data.
By using the Website, you hereby expressly consent to the transfer of your personal data outside of Malaysia.
5.3 In the unlikely event that we believe that the security of your personal data has been compromised, we may seek to notify you of that development. If we have your email address, we may notify you by email. By using the Website, you consent to our use of email as a means of such notification.
EXCEPTIONS
6.1 As a general rule, OTfresh processes your Personal Data and ensures the security and confidentiality of your Personal Data. We will take the necessary and appropriate measures to obtain your consent prior to the use or disclosure of your Personal Data.
6.2 The exceptions are where OTfresh engages service providers to perform specific services on our behalf and for purposes mentioned in clause 4.1 above, including but not limited to the following:
a. delivery of products ordered through our Website;
b. hosting your Personal Data in data centers through storage facility providers;
c. statistical and analytical studies;
d. monitoring the quality of our service or Website;
e. improving advertising campaigns or promotions, marketing and business efficiencies and prospective sales.
In such situations, the service providers are authorized to use your Personal Data only to perform the specific services entrusted by OTfresh. As part of our agreement with them, they are required to take all reasonable measures to ensure and maintain a high level of security of your Personal Data.
6.3 Your Personal Data may also be shared or disclosed to third parties such as regulatory and government authorities where we are under a duty to do so.
COMMUNICATION AND MARKETING
When it comes to marketing, respect for your peace and tranquility and the relevance of our messages are two rules on which we never compromise. You have the option to opt-out of receiving marketing communication from us and/or selected third parties. You can opt-out by clicking on the “unsubscribe” link in any email communications which we might send you.
COOKIES
8.1 The Website integrates the use of cookies. Cookies are files that are saved on your computer or smartphone. Cookies enable us to collect and store information concerning your browsing activity on our websites and/or apps. These cookies have several purposes, including but not limited to:
a. enabling you to use the main functions of the website, such as managing your shopping cart or remaining logged in while you browse the website;
b. enabling you to visit the website in a personalized way based on your previous visits and purchases;
c. enabling you to receive offers from us on external partner websites.
Cookies do not contain your personal data.
8.2 Management of cookies
Most browsers, smartphones and other web-enabled devices are typically set up to accept cookies. There are different options available to manage the cookies. You can change your browser settings to prevent cookies from being accepted or, depending on which browser you are using, you might be able to receive an alert when a website is trying to place one on your browser. With most browsers you can allow first party cookies to be set but refuse third party cookies.
You can delete cookies stored in your browser by using a function in your browser. Whilst this does not mean you won’t collect cookies in the future, it gives you freedom to delete your cookies after you have been online. This function is known as “clearing cookies”. Clearing your cookies on one browser of one device does not automatically clear them on another. You need to clear all browsers on all channels independently.
Please note that by blocking or deleting cookies used on the Website, you may not be able to take full advantage of the Website.
8.3 To make full use of the Website, cookies need to be enabled on your browser as certain features will not work if you reject cookies. Your experience online will be severely restricted should you disable cookies as you will not be able to set up an account, log in to an existing one and purchase online.
8.4 By using the Website, you consent to the use of cookies and the collection of information by us through these cookies.
YOUR RIGHTS
9.1 Providing us with your personal data does not mean you lose control of them. You have rights over your data, which you may exercise dependent on the purpose of the collection of the personal data.
9.2 Your rights include:
Right of access
The right of access allows you to request access to personal data that we hold about you.
Right of rectification
The right of rectification allows you to update your data.
Right to object
The right to object allows you to limit or to stop the processing of your data. It also allows you to opt-out of marketing communication.
Right of erasure
OTfresh does not store data longer than necessary. All your data is automatically erased, if it is no longer necessary in relation to the purpose of collection. The right of erasure allows you to have your data erased earlier.
Right to portability
The right to portability enables you to request that we transmit your data in format technically usable to yourself or another entity.
Right to prevent processing for purposes of direct marketing
This right allows you to opt-out of receiving direct marketing communication.
9.3 You may exercise your rights by contacting our Data Protection Officer through the following methods:
a. Writing to following address:
OTfresh.my
Address: 138, Persiaran Raja Muda Musa,
41200 Klang, Selangor,
Attn: Data Protection Officer
b. Sending an email to cs@otfresh.my.
To ensure your request is processed as efficiently as possible, please indicate the right(s) that you wish to exercise and what it is in relation to. Our security procedures mean that we may request proof of identity before we take the action requested for.
RIGHTS TO AMEND THIS PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time. If material changes are made to this Privacy Policy, they will be posted on this page and date stamped. We encourage you to review this page periodically in order for you to stay notified of any changes.
Your continuous use of this Website and acceptance of our services after any changes to this Privacy Policy constitutes your consent to any such changes.
CONTACT US
If you have any questions, feedback or concerns in relation to your personal data or this Privacy Policy, please do not hesitate to contact our Data Protection Officer at cs@otfresh.my, who will be delighted to answer any questions that you may have.
