Tsing – Privacy Statement

This Privacy Statement describes how we collect, use, protect and disclose your information. It also explains your privacy rights, and how you can manage your Personal Information. This Privacy Statement is formulated in compliance with the Malaysian Personal Data Protection Act 2010 (PDPA) and its 2024 Amendments. Together with our Terms and Conditions, it governs your use of our Website. If you do not agree to them, please do not use our Website.

Personal Information

"Personal Information" is data about an individual who can be identified from that data, or by combining it with other data. Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data. The specific definition of Personal Information varies from one jurisdiction to another. "Sensitive Personal Data" means personal data relating to a data subject's race, religion, political opinions, health status, criminal records and other categories as defined under the PDPA. Processing of Sensitive Personal Data shall only be conducted with the explicit written consent of the data subject.

Data Subject Rights

Under the Malaysian Personal Data Protection Act 2010 and its 2024 Amendments, you, as the data subject, are entitled to the following rights:

You may submit rights requests via the contact details stated in the Contact Us section. We shall respond to all valid requests within 21 working days as required by PDPA.

Information Directly Collected

We may require you to provide certain information — including Personal Information — in order to use certain parts of our Website, fulfill your requests with us, communicate with you, or provide you with certain Services. These may include visitors' names, addresses, email addresses, phone numbers, as well as usernames and passwords for Tsing accounts. We keep information related to the Products or Services purchased for as long as those accounts are active. Providing the above personal information is voluntary. If you refuse to provide relevant information, you may not be able to use part or all functions of this Website and related services.

We also collect information that you decide to share with us. When you contact us with questions or concerns, we collect your name, your email address, the subject of your inquiry, and the information you choose to share with us. We may also obtain information about you from our third-party service providers who help us provide our Products and Services to you.

Information Automatically Collected

When you visit our Website, certain non-personal information is collected, such as IP address, device ID, browser setting, operating system, referring domain, language preferences, mobile carrier and website activity through cookies or similar tracking mechanisms. For example, pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action.

A "cookie" is a small file stored on your computer by a website which gives you a numeric user ID and stores certain information about your activity on the website. Some cookies only last for the session you are on the Website. Other cookies persist beyond that session, so, for example, you do not have to reenter contact information or items in your cart. We use cookies to transact with you, gather navigation information, enhance and personalize your experience, analyze usage patterns, and improve our Website, products and services.

Our cookies generally fall into one of four categories: Essential, Functional, Analytics and Target.

All third-party Cookies are only deployed by our partners who have signed formal Data Processing Agreements (DPA) and complied with PDPA requirements. We shall conduct regular compliance reviews on such third parties to ensure their data processing activities do not violate Malaysian laws.

Most browsers are set to accept cookies automatically. You can set your browser to decline all cookies automatically or to prompt you for a response each time a cookie is offered. If you decline cookies, you may find that you cannot access all our Website's features. Opt-outs are device- and browser-specific and may not work in all instances.

In accordance with the PDPA, you may adjust or disable Cookies through your browser settings at any time. Disabling Cookies will not affect your basic access to the Website, but some functional features may be unavailable.

To learn more about the use of Cookies by Google for analytics and to exercise choice regarding those Cookies, please visit the Google Analytics Opt-out Browser Add-on or the Digital Advertising Alliance.

There are "do not track" or similar browser choices available to internet users with respect to online web activity, but given the present lack of consensus of what constitutes an informed election, appropriate trigger or breadth of scope of such choice, our Website will not operate any differently when a "do not track" signal is received.

Use of Information

We gather information from you so we can communicate and transact with you and improve our Products, Services and Website. We also use the information automatically collected about you during your use of the Website to improve the effectiveness of our operations, mobile experience, or marketing efforts, to prevent fraud and theft, and otherwise to protect visitors to our Website and business.

We process (or ask our service providers to process on our behalf) and use your information to notify you about changes to our Products or Services; to monitor the usage of our Services; to detect, prevent and address technical issues; to provide you with Website content and advertisements we think will interest you; to personalize our services and remember you for later use of or visits to the Website; to monitor and analyze our Website metrics and third party marketing activities; to track your entries, submissions, and status of other activities.

We also process and use your information as you have given us your consent and permission to do so. We may process and use your personal data for our legitimate business interests or the legitimate interests of a third party, provided that such interests do not override your fundamental rights under the PDPA. You have the right to opt out of such processing at any time. For instance, we may use your information to assist with fraud prevention, improve the security of our networks, assist with enhancing the physical security of our customers, and reporting suspected criminal activity to law enforcement. We may also use your information in relation to certain direct marketing events.

Finally, we process and use your information to comply with applicable laws, respond to lawful and enforceable requests from law enforcement, judicial or other public authorities, meet professional obligations, prevent fraud, collect fees owed, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms and Conditions and take other actions permitted or required by applicable law.

Sharing of Information

Our employees and agents may view your Personal Information to perform their jobs and service your needs. We authorize their access to your Personal Information on a need-to-know basis to provide you with our products or services, or for one of the other reasons listed in this Privacy Statement.

We may share your personal data with our Affiliates, authorised vendors and agents only with your consent or for the performance of our services to you, in compliance with the PDPA and this Privacy Statement. "Affiliates" are those persons or entities directly or indirectly controlling, controlled by, or under common control with the Company.

We will not share Personal Information with third party service providers for purposes of marketing. We may share Personal Information on an as-needed basis with third party service providers who help us operate our business, for example by hosting or operating our Site, storing data in the cloud, managing databases, performing analyses, sending out communications for us such as newsletters or surveys, processing payments and orders and responding to customer service requests. We require those providers not to disclose Personal Information and to use it only for the limited purposes we provided it.

We will not sell, transfer, or disclose your Personal Information for purposes of marketing. However, we may sell, transfer and/or disclose your Personal Information as part of a business divestiture, sale, merger, or acquisition of all or a part of our business. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Statement. In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset.

We may release your Personal Information to others (including law enforcement) if we believe such release is reasonably necessary (i) to comply with a government or law enforcement request or judicial process; (ii) to operate this Website; (iii) to process any orders or registrations; (iv) to conduct any promotions in which you participate; or (v) to protect our rights or property or those of our Affiliates, users or customers.

In addition, we may share aggregate, non-individual information, incapable of identifying a particular person, with third parties for lawful purposes.

Data Movement

All personal data collected from users in Malaysia is primarily processed and stored within Malaysia in compliance with the PDPA. Any cross-border transfer of personal data to overseas jurisdictions shall strictly comply with Section 129 of the Malaysian PDPA:

Links

When you click on links and/or ad banners that take you to third-party websites, you will be subject to the privacy policies and terms and conditions of those third-party websites, not ours. We are not responsible for those websites or the actions of third parties. We encourage you to read their privacy policies and user terms and conditions.

Children

Our Website is not intended for children under 18 years of age. Processing of personal data of minors under 18 shall strictly comply with PDPA provisions, and we will not collect such data without the consent of their legal guardians. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us.

Retention and Security

We will not keep your Personal Information for any longer than is necessary for the purposes we collected it. To protect your Personal Information, we maintain a variety of security measures, including physical, electronic and administrative safeguards. No system can be completely secure, so we do not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure.

Any password for our website or app shall be the exclusive property and confidential information of the Company and may be used by you solely for your personal use of this website. You are responsible for maintaining the confidentiality of any password. All activities conducted using your password shall be your responsibility, whether you authorized them or not. You agree to immediately notify us of any unauthorized use of your password or account.

In the event of any personal data breach that may compromise your personal data security, we shall notify the Malaysian Personal Data Protection Commissioner within 72 hours as required by the PDPA 2024 Amendments. If the breach is likely to cause substantial harm to you, we will also inform you of the incident, impacts and remedial measures promptly. We shall maintain a complete register of all personal data breaches for no less than two years from the date of notification to the Malaysian Personal Data Protection Commissioner, including incident description, root cause, affected data categories, mitigation measures and notification records.

Changes to this Privacy Statement

We may change our Privacy Statement from time to time. We will post those changes here and reflect the date they were updated above.

Contact Us

If you have questions about our use of your Personal Information or this Privacy Statement, please contact:

Tsing Digital Technology SDN. BHD.
Address: LEVEL 8, JKG TOWER, 282, JALAN RAJA LAUT, CHOW KIT, 50350 WILAYAH PERSEKUTUAN KUALA LUMPUR
E-mail: ccrcir@ccrc.com