Last updated [July 16, 2020]

INTRODUCTION

Your privacy is important to us, and we take our responsibility of caring for it seriously.  We respect your privacy rights and are committed to protecting the personal information that is collected about you. This Privacy Policy describes what information we collect and how we use, disclose, transfer, and store it. If you do not want us to collect, store, use or share your information in the ways described in this Privacy Policy, you may not be able to use our services.

We, including our subsidiary companies, collects, stores, and uses your information as a data controller via this mobile application (herein referred to as the “Application”) in accordance with this privacy policy (“Privacy Policy”).

By using the Application, you hereby consent to this Privacy Policy.

We reserve the right to change this Privacy Policy at any time. In the event that we make material changes to this Privacy Policy, they will be re-posted in the "Privacy" section of our websites and apps with the date the modifications were made indicated at the top of the page. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to it. Your continued use of the Application after such change(s) constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Application or opt out by sending us appropriate notice.

COLLECTION OF YOUR INFORMATION
We collect some information from you in various ways including when you: (a) subscribe to our Application and (c) contact our customer service. The information we may collect includes:

1. Personally identifiable information (such as your name, address, contact number, email address demographic information, network operator, identification card number/passport, payment details (e.g. beneficiary name, bank name, bank account number) etc.) that you voluntarily give to us when choosing to participate in various activities related to the Application, such as chat, posting messages in comment sections or in our forums, liking posts, sending feedback, and responding to surveys (”Activities’). If you choose to share data about yourself via your profile, online chat, or other interactive areas of the Application, please be advised that all data you disclose in these areas is public and your data will be accessible to anyone who accesses the Application;
2. Financial information, such as data related to your payment details (e.g. beneficiary name, bank name, bank account number) that we may collect when you cash out or request for payment, or request information about our services from the Application. We store only very limited, if any, financial information that we collected;
3. User information from social networking sites, such as [Whatsapp, Facebook Messenger, Wechat, Telegram, LINE, Instagram, and other frequently used apps], including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join the Application;
4. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings;
5. Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide;
6. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
7. Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Application permission to access this information especially for sharing of the referral code;
8. Personal and other information you may provide when entering contests or giveaways and/or responding to surveys;
9. Information that you provide when seeking help from our customer service (such as chat logs and customer-support);
10. Other information you provide us

USE OF YOUR INFORMATION
We primarily use the information to provide you with a smooth, efficient, and customized experience, but we also use your information, both individually and combined, as follows:-
i - To operate our business and to enhance your experience, including to :

1. Administer sweepstakes, promotions, and contests.
2. Assist law enforcement and respond to subpoena.
3. Compile anonymous statistical data and analysis for use internally or with third parties.
4. Create and manage your account.
5. Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Application to you.
6. Email you regarding your account or order.
7. Enable user-to-user communications.
8. Fulfill and manage purchases, orders, payments, and other transactions related to the Application.
9. Generate a personal profile about you to make future visits to the Application more personalized.
10. Increase the efficiency and operation of the Application.
11. Monitor and analyze usage and trends to improve your experience with the Application.
12. Notify you of updates to the Application.
13. Offer new products, services, mobile applications, and/or recommendations to you.
14. Perform other business activities as needed.
15. Prevent fraudulent transactions, monitor against theft, cheating and protect against criminal activity.
16. Process payments and refunds.
17. Request feedback and contact you about your use of the Application.
18. Resolve disputes and troubleshoot problems.
19. Send you a newsletter.
20. Solicit support for the Application.
21. Other security reasons
22. identify and fix bugs and service errors
23. comply with all regulatory and legal requirements, and answer any requests from Data Protection Authorities or any law-enforcement agency

ii - To provide you with support, communicate with you and respond to any requests or questions you have submitted through our customer support.

iii - To personalize our communication with you, including to:

1. handle your subscription to, and opting-out of, our newsletters
2. contact you to promote our Application
3. send you, with your prior consent, promotions or marketing materials (we will provide you with the opportunity to opt out of receiving such materials in the future)
4. provide you with advertising that better suits your interests and profile and is age-/gender-appropriate and targeted to your general location
5. serve and measure the effectiveness of advertising
6. personalize your content and offers
7. send you push notifications (if you choose to allow that function)—only for users 18 years old or older

For some purposes described above, Elfo Sdn Bhd may use and perform analytics. Analytics information supports business analysis and operations, allows product development, improves products and Application, personalizes content, provides advertising, and makes recommendations.

Our legal basis for collecting and processing your personal information is described above. 

We will normally collect personal information from you only:

1. when we have your consent to do so
2. when we need the personal information to fulfill a contract with you and provide you with the Application, such as customer services, bug and service-error detection, and fraud prevention
3. when the processing is in our legitimate interests (when we serve and measure the effectiveness of advertising or marketing campaigns, protect and improve our products and services) and not overridden by your rights, or
4. when we have a legal obligation to collect personal information from you.

RETENTION OF YOUR INFORMATION
We retains, uses and stores your information as long as you are using our Application, and also for the period necessary to fulfill all the purposes described in this Privacy Policy, in compliance with the applicable laws of your country of residence. We want to inform you that a longer retention period could be required to resolve disputes, or answer regulatory or police requests. In such cases, the collected information will be used and stored until the request is closed.

DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

1. By Law or to Protect Rights
   If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect our or others’ rights, property, and safety, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
2. Third-Party Service Providers
   We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
3. Marketing Communications
   With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.
4. Third-Party Advertisers
   We may use third-party advertising companies to serve ads when you use the Application. These companies may use information about your use on the Application and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.
5. Affiliates 
   We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
6. Business Partners
   We may share your information with our business partners to offer you certain products, services or promotions.
7. Other Third Parties
   We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.
8. Offer Wall
   The Application may display a third-party-hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer. Such an offer wall may appear in the Application and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will leave the Application. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.
9. Social Media Contacts
   If you connect to the Application through a social network, your contacts on the social network will see your name, profile photo, and descriptions of your activity.
10. Sale or Liquidation
    If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter into liquidation, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

INTERNATIONAL OPERATIONS AND TRANSFERS OF YOUR INFORMATION
As part of our international operations, we may transfer personal information to our affiliates (which means subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership of Elfo Sdn Bhd from time to time for our legitimate business purposes.

We have taken measures to ensure that your personal information is treated securely and lawfully, and that it receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the European Economic Area (“EEA”) or Switzerland, we provide adequate protection for the transfer of personal information to countries outside of the EEA or Switzerland based on the standard contractual clauses authorized by the European Commission or other appropriate safeguards defined in Article 46, General Data Protection Regulation (GDPR) (EU) 2016/679.

INTERNET-BASED ADVERTISING
Additionally, we may use third-party software to serve ads on the Application, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us. For more information about opting-out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

WEBSITE ANALYTICS
We may also partner with selected third-party vendors such as Google Analytics, Fire Base and Adjust to allow tracking technologies and remarketing services on the Application through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Application, determine the popularity of certain content, and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can install and/or update your settings for opting-out.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

THIRD-PARTY WEBSITES
The Application may link to external sites that are beyond our control. This Privacy Policy only covers the way we treat personal information and non-personal information we collect on the Application. By accessing any external sites, you agree to the privacy policies of those sites. Please understand that external sites may have different policies with respect to the collection, use and disclosure of your personal information. We have no control over, and are not responsible for, the privacy practices of such third parties.
Therefore, you are encouraged to review the privacy policies of all third parties' services. Without limiting anything in the following section, we are not liable in any way for the actions, inactions or policies of any external services.

SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

POLICY FOR CHILDREN
We encourage parents to instruct their children about privacy and the way they use their information on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission.

We consider a user to be a child if they are under the age of 18, unless more stringent regulation applies in their country of residence. No personal information should be submitted to us by users under the minimum legal age. If you become aware of any data we have collected from children under age 18, please contact us using the contact information provided below.

LEGAL DISCLAIMER
Our Application operate “AS IS”, and we do not represent or warrant that our Application will be available at all times, or that your use of the Application will be uninterrupted or error-free. We are not responsible for your ability to access the Application or for matters beyond our control. This Privacy Policy is governed by the laws of Malaysia. Any dispute arising from the use of the Application shall be submitted to the competent courts of Malaysia age. If you become aware of any data we have collected from children under age 18, please contact us using the contact information provided below.

EMAILS AND COMMUNICATIONS
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

1. Noting your preferences at the time you register your account with the Application
2. Logging into your account settings and updating your preferences.
3. Contacting us using the contact information provided below

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

CONTACT US
If you have questions or comments about this Privacy Policy, please contact us at:

1. by sending an email to: [email protected]
2. by writing to:
   Elfo Sdn Bhd
   Unit C-5-1 Megan Avenue, 2,
   Jalan Yap Kwan Seng,
   50450 Kuala Lumpur
   MALAYSIA
3. Contact number: +603-2162 2728
4. Fax Number: +603-2162 2729