Effective Date
19th August 2024
Vialing is committed to protecting your privacy. This Privacy Notice (“Notice”) describes how Vialing processes personal data in connection with our business, and our Services.
This Notice explains Vialing’s approach to any Personal Data that we might collect from you, or which we have obtained about you from a third party, and the purposes for which we process your Personal Data in our capacity as a Controller (i.e. when Vialing determines the purposes and means of the processing of personal data). It also describes your rights in respect of our processing of your Personal Data.
We process Personal Data in the countries in which we are established, Malaysia as Vialing Sdn Bhd.
While processing the Personal Data we comply with the principles and rules of the Malaysia PDPA 2010.
This Notice only applies to the use of your Personal Data by us or on our behalf. It does not apply to:
Where this Privacy Notice mentions to “Vialing”, “we”, “us, “our”, this means one or more of the particular Group Companies that provide the particular Website, Application Software, Newsletter or Services to you, recruits you, uses testimonials from you, sends marketing communications to you, hosts an event you visit, or organizes a program in which you participate.
Location: Malaysia
Vialing Sdn Bhd. is a company established under the laws of Malaysia
We collect, process and store Personal Data about the following people:
We may collect, process and store your Personal Data in connection with our provision of those Services to you, our receipt of those Services from you and/or our partnership. This may include Personal Data included in any email, extensive education records, or any document or data provided by administrators or lecturers relating to an order for the Services. University administrators and lecturers are given the access to continuously update the status of the students.
This Notice will apply to our processing of your Personal Data during your use of the Applications when the Applications are provided by us, and the Application shall include a link to this Notice. When Applications are provided by a third party, the privacy statement of the relevant third party will apply.
WHAT PERSONAL DATA VIALING COLLECTS AND HOW THE PERSONAL DATA IS USED | WHAT LEGAL BASIS DOES VIALING RELY ON TO PROCESS YOUR PERSONAL DATA |
A) Personal Data collected from you (“Collected Data”) *Shared with Vialing’s Business Partners/Affiliates for the purpose of Marketing, Product and Business Improvements. | |
Purpose: Providing Customer with Services. Vialing may use, retain and process Customer’s Data for the following purposes when providing Vialing’s Services:
The data processed includes:
| We process Customer’s Personal Data for these purposes based on Vialing’s legitimate interests or a third party’s legitimate interest to ensure Vialing provides the Services in an effective, safe and efficient way. Where Vialing processes Customer’s Personal Data to administer the account, or to the extent necessary to collect the subscription fees, we do so for the purposes of Vialing’s contract with Customer. |
Purpose: Recruitment at Vialing. When Applicant applies for a job through Vialing’s application form, email, or hard copy, whether directly or through a third-party recruitment agency, Vialing will process your data to assess Applicant’s suitability for the specific role Applicant applied for or any other relevant positions. By submitting the resume (“Application”), Applicant acknowledge that Vialing may internally evaluate Applicant’s qualifications based on its contents. If Applicant does not wish to undergo this evaluation, please refrain from providing the information. The processed data includes:
Subject to local regulations, Vialing may also use your data to review the equal opportunity practices in compliance with applicable laws. Vialing does not discriminate based on gender, race, ethnic origin, age, religion, sexual orientation, disability, or any other protected status. Employment decisions are made solely on merit. Vialing retains application data for a limited period for record-keeping and legal (or regulatory, where applicable) purposes. If permitted by local laws, Vialing may also retain Applicant’s data to contact Applicant about future job opportunities that match Applicant’s profile. Further details will be provided during the application process, and we will seek the consent as required by local regulations. | Where Vialing uses Applicant’s Personal Data in connection with recruitment, it will be in connection with Vialing taking steps at Applicant’s request to enter into a contract Vialing may have with Applicant or it is in Vialing’s legitimate interest to use personal data in such a way to ensure that Vialing can make the best recruitment decisions. Vialing will not process any special (or sensitive) categories of Personal Data or Personal Data relating to criminal convictions or offences except where Vialing is able to do so under applicable legislation or with Applicant’s explicit consent. |
Purpose: Vialing’s Hosting or Managing Events and Programs. Periodically, Vialing will organize events to promote the business or for other purposes. The data Vialing processes includes:
| It is necessary for Vialing to use Attendee’s Personal Data in this way to perform Vialing’s obligations in accordance with any contract that Vialing may have with Attendee where Attendee have signed up to attend an event, or it is in Vialing’s legitimate interest or a third party’s legitimate interest to use Personal Data in such a way to ensure that the event is operated in a secure and effective way. Vialing may specifically ask Attendee’s permission to use Attendee’s photographs, quotes, testimonials, or other content that is made available or publish at the event. Where this is the case, Vialing’s processing of such Personal Data will be based on consent (or, if Vialing enters into a contract with Attendee for this purpose, on the performance of said contract) |
Purpose: Participation in Public forums, Community platform, Forms and use of Customer’s statements for testimonials. When Customer visits or registers for Vialing’s publicly accessible community forums and blogs or submit any forms on Vialing’s Site, Customer should be aware that any information provided in these areas may be read, collected and used by others who access them. Vialing may post Customer’s testimonials/comments/reviews on Vialing’s Websites which may contain Customer’s Personal Data. The data processed includes:
| Vialing may post Customer’s testimonials/comments/reviews on the Websites which may contain Personal Data. Where Vialing uses Customer’s content in connection with Services that Vialing provides via Website, it is in Vialing’s legitimate interest to use any Personal Data that Customer provides to ensure that Vialing provides the relevant Services in an effective way. Prior to posting the testimonial, Vialing will obtain Customer’s consent to post Customer’s name along with the testimonial. If Customer does not consent, Vialing is only allowed to use the testimonial in a fully anonymized way. If Customer wants to revoke the consent and for the testimonial to be removed, please contact Vialing at [email protected]. If Vialing enters into a contract with Customer for this purpose, Vialing’s legal basis may be the performance of said contract. |
Purpose: Newsletters. When Customer actively subscribes to Vialing’s newsletters, Vialing collects and stores Customer’s e-mail address to share the newsletters. | If Customer has requested content from Vialing, i.e. a newsletter, it is in Vialing’s legitimate interest to use Customer’s Personal Data in such a way to ensure that Vialing processes the request in an effective way. |
Purpose: Advertising and Marketing to Our Customers and Prospective Leads – Sending Marketing Communications by Post and/or Email. The data Vialing processes includes:
| In Malaysia, we will rely on your consent when sending marketing communications. Otherwise, it is in our legitimate interest to use your Personal Data for marketing purposes, for example to decide what marketing content we think may appeal to you or for postal or email marketing (except where we are required by applicable law to obtain your consent). |
Purpose: Advertising and Marketing to Customers and Prospective Leads: Online Personalized Marketing. The data Vialing processes includes:
| Please see the “Cookies and Similar technologies” section to learn about the legal basis that Vialing relies on to collect data via the use of cookies. Where Vialing uses Customer’s personal data to display online personal advertising to Customer, Vialing relies on the consent that Customer has provided in respect of the collection of such data, or, subject to local law, it is otherwise in our legitimate interests to promote the Website and Services to Customer. |
Purpose: Advertising and Marketing to Vialing’s Customers and Prospective Leads – Advertising to Customer on Social Media and Other Platforms. Vialing shares Customer email addresses and other identifiers, like phone numbers or device IDs (usually encrypted or ‘hashed’), with third-party social media platforms and services such as Facebook, LinkedIn, and similar platforms (“Social Platforms”). These third-party providers attempt to match Customer data with their registered users. If a match is found, Vialing displays advertisements to Customers when they use the relevant Social Platform (e.g., on their Facebook newsfeed). This method, known as “custom audience” advertising, allows Vialing to tailor the audience it wants to reach on these platforms. Some of the ads Customers see may be personalized, using data such as:
This data is used to personalize Vialing’s advertising but is not shared with the third-party providers of the Social Platforms for this purpose. For more details on data sharing, please refer to the “Cookies and Similar Technologies” section. This activity is also subject to the privacy choices Customers have made on such Social Platforms. | Vialing will only share Customer Personal Data with third-party providers of Social Platforms to advertise Vialing’s Services to Customers when they use those Social Platforms, either with Customer consent or when it is in Vialing’s legitimate interest to promote its Services. For details on the legal basis for activities involving Cookies, please refer to the “Cookies and Similar Technologies” section. Customers can opt out of Vialing sharing their personal information with third-party providers by exercising their data subject rights as outlined below. |
Purpose: Advertising and Marketing to Vialing’s Customers and Prospective Leads – Advertising to Individuals Similar to Customers. Vialing shares Customer Personal Data with third-party providers of Social Platforms as outlined in the “advertising to you on social media and other platforms” and “Cookies and Similar Technologies” sections. When Customers use these Social Platforms, Vialing may request these providers to identify other registered users who share similar interests and characteristics with Customers, using information available to the providers about both Customers and their user base. This approach, known as “lookalike” audience advertising, is intended to present Vialing’s ads to individuals who resemble its Customers. If you have encountered such advertising on a Social Platform, please be aware that it is based on data you provided to the Social Platform (which Vialing does not receive) and is governed by your privacy settings on those third-party services. | Please see the “advertising to you on social media and other platforms” section for details of the lawful basis that Vialing relies on to share Customer personal data with the Social Platforms. It is in Vialing’s legitimate interests to further use Customer’s Personal Data to advertise Vialing’s Services to other individuals who use those Social Platforms and share similar interests and characteristics with Customer. If you are someone who has seen this advertising on a Social Platform, it is in Vialing’s legitimate interests that the Social Platform uses the data you provided to it to advertise Vialing’s Services. Please note that Vialing does not receive this data, and you should exercise your rights regarding such data in accordance with the privacy notice of the relevant Social Platform. |
Purpose: Cookies and Similar Technologies, Application Software, Usage Data, Single Sign-On, and Social Media. Vialing employs commonly used tools to automatically gather information that may include Personal Data from Customer computers or mobile devices when they visit Vialing’s Websites, use Vialing’s applications, or engage with Vialing’s Services. a) Cookies and similar Technologies. Vialing and its third-party advertising partners utilize cookies, web beacons, pixel tags, and similar technologies (collectively referred to as ‘cookies’) to collect data from the devices Customers use to access Vialing’s Website. The data collected through these cookies serves several purposes:
Vialing may receive reports from third-party companies regarding the use of these technologies, both on an individual and aggregated basis. Most web browsers support cookie management at the individual browser level. It’s important to note that disabling cookies may restrict access to certain features or functions on Vialing’s Websites and Services. Similar to other websites, Vialing automatically collects and stores certain information in log files. This information may include internet protocol (IP) addresses, browser types, internet service providers (ISPs), referring/exit pages, files viewed on the Websites (e.g., HTML pages, graphics), operating systems, date/time stamps, and clickstream data. Vialing links this automatically collected data with other data collected about Customers. | Cookies and Similar Technologies: Where data is collected using non-essential cookies, Vialing relies on consent to collect Customer’s personal data and for the onward processing purpose. |
b) Application Software: When Customers download, install, and use Vialing’s Application Software, Vialing automatically collects information about the type of device Customer uses, the version of the operating system, and the device identifier (or “UDID”). Vialing utilizes analytics software to gain insights into how its Application Software functions on Customer’s device. This software may record various details such as usage frequency, events that occur within the application, aggregated usage statistics, performance data, and the source from which the application was downloaded. The information stored within the analytics software is not linked to any personal data Customers submit within the Application Software. Upon opening Vialing’s Application Software for the first time, Customers may be prompted to grant permission for receiving push notifications. If Customers opt in, Vialing’s Application Software will send push notifications, including reminders, alerts, updates, and other relevant information. Customers have the option to configure and disable push notifications through their device settings. | Application Software: Functionality: Vialing considers it in the legitimate interest to utilize the data collected to send error messages (if applicable) and to safeguard the Application Software by detecting and resolving errors and cyberattacks. Analytics: When Vialing employs analytics software to assess the performance of our Application Software on Customer phones, Vialing relies on the legitimate interests to secure and ensure the proper functioning of Vialing’s Application Software, as well as to deliver the Services effectively. Push Notifications: In Malaysia, Vialing seeks Customer consent before sending push notifications about events, promotions, or updates to the Services. Otherwise, Vialing relies on the legitimate interests to do so. |
c) Usage Data: Alongside the information detailed in the Cookies and Similar Technologies section [link to cookies policy] where Vialing automatically gathers data, Vialing also captures clicks, scrolls, conversions, and drop-offs on our Websites and Service(s) to monitor real-time user journeys (referred to as “Usage Data”). Under this Notice, Vialing will utilize such Usage Data and Customer data, including but not limited to: (i) evaluating the business needs of Customers to suggest or determine appropriate Services; (ii) delivering requested information about the Services; (iii) addressing customer service inquiries, questions, and issues; (iv) for analytical purposes; and (v) to enhance and provide the Services. | Usage Data: Vialing relies on the legitimate interests to process Usage Data for the stated purposes, except for call recording, which exclusively relies on consent. |
Purpose: Business Administration and Legal Compliance Vialing may utilize Customer’s Personal Data for the following purposes: a) Responding to lawful requests from public authorities, which may include meeting national security or law enforcement requirements; b) Disclosing Personal Data when Vialing believes it is necessary to protect our rights, or to comply with a judicial proceeding, court order, police request, or other legal process directed towards us; c) Safeguarding the rights of third parties; and d) Utilizing Personal Data in connection with business transitions such as mergers, reorganizations, acquisitions by another company, or the sale of any of Vialing’s assets. | Where Vialing utilizes Customer’s Personal Data during a business transition, to assert legal rights, or to safeguard the rights of third parties, Vialing does so based on Vialing’s legitimate interests. For all other purposes outlined in this section, Vialing is legally obligated to use Customer’s Personal Data to fulfill any legal obligations imposed on Vialing, such as complying with court orders. In certain jurisdictions, this may involve exercising legal rights in judicial, administrative, or arbitration proceedings. Vialing will not process any special (or sensitive) categories of Personal Data or Personal Data concerning criminal convictions or offenses, unless permitted by applicable laws and/or with Customer’s explicit consent. |
Purpose: Receipt of Products and Services from Our Suppliers If Vialing has engaged Customer or the organization Customer represents to provide products or services (such as IT support or financial advice), we will collect and process Customer’s Personal Data to effectively manage our relationship, receive products and services, and when applicable, provide our Services to others. The Personal Data collected may include Customer’s name, email address, telephone number, designation, billing address, and any other voluntarily provided personal data pertinent to our relationship with Customer or the organization Customer represents. | Vialing needs to use Customer’s Personal Data to fulfill Vialing’s obligations under any contract with Customer or the organization Customer represents. Additionally, it is in Vialing’s legitimate interest to utilize Personal Data to maintain a productive working relationship with Customer or the organization Customer represents. This ensures that we can receive the products and services provided by Customer or their organization effectively and deliver Vialing’s Services to others efficiently. |
Purpose: Security Vialing may process Customer’s Personal Data as part of Vialing’s security administration procedures. Vialing implements various security measures at Vialing’s premises, including CCTV surveillance and building access controls. Signs indicating CCTV surveillance are prominently displayed. The captured images are securely stored and accessed only when necessary (for instance, to investigate an incident). CCTV recordings are typically overwritten automatically after a brief period unless there is a specific reason to retain them, such as an ongoing investigation into an incident like theft. For visitors to Vialing’s premises, Vialing may require signing in upon arrival, and maintain visitor records for a limited time, typically for as long as necessary for legitimate security reasons. These records are securely stored and accessed only by authorized personnel as needed, such as to address any incidents that may arise. | It is in Vialing’s legitimate interests to process Customer’s Personal Data so that Vialing can keep Vialing’s premises secure and provide a safe environment for Vialing’s personnel and visitors. |
B) Information that we collect from third-parties | |
Vialing may receive Customer’s Personal Data from third-party sources such as databases and social media platforms. Before receiving this information, Vialing ensures that these third parties have obtained Customer’s consent or are legally permitted or required to disclose Customer’s personal information to Vialing. The types of information Vialing obtains from these third parties may include Customer’s name, email address, postal address, location, designation, and telephone number. Vialing utilizes this information to enhance the customer support experience, maintain accurate records about Customer, and support Vialing’s sales and marketing efforts. | When Vialing processes Customer’s Personal Data obtained from third parties for these purposes, Vialing will rely on the consent given by Customer to such third parties for sharing data with Vialing. In cases where consent from Customer to the third party is not obtained, and in accordance with local laws, our processing activities will be based on Vialing’s legitimate interests. This ensures Vialing enhances customer service and maintain accurate marketing databases. |
Personal Data is processed by Vialing in countries Vialing is established in, including Malaysia, and in countries where the third-party are based that Vialing uses.
When Vialing processes your Personal Data, it may need to be shared with third-parties (including entities within Vialing’s Business Partners or Affiliates), as laid down below. The list is non-exhaustive and there may be circumstances where Vialing needs to share Personal Data with other third parties.
Customer’s Personal Data may be collected, transferred to and stored by Vialing in Malaysia and our affiliates and third-parties disclosed in Section 4 above, that may be based in other countries.
Customer’s Personal Data may be processed outside Customer’s country or jurisdiction, including in places that may not be subject to an adequacy decision by Customer’s local legislature or regulator, and may not provide the same level of data protection. Vialing ensures that the recipient of Customer’s Personal Data offers an adequate level of protection and security. Where required by applicable law, Vialing will only share, transfer or store Customer’s Personal Data outside of Customer’s jurisdiction with Customer’s prior consent.
Vialing employs suitable technical and organizational measures to safeguard the Personal Data collected and processed. Vialing has established information security policies, rules, and technical measures to protect the Personal Data under its control from unauthorized access, misuse, disclosure, unauthorized alteration, and unlawful destruction or accidental loss. Additionally, all Vialing employees and data processors (i.e., those who process Customer Personal Data on Vialing’s behalf) are required to maintain the confidentiality of the Personal Data of all users of Vialing’s Website and those who purchase Vialing’s Services. The measures used are designed to provide a level of security appropriate to the risk of processing Customer Personal Data.
Information security risks are continuously evolving, and so are the controls. These controls are periodically reviewed as part of internal and external audits. If a Customer has questions about the security of their Personal Data, they can contact Vialing using the details in section 16.
As explained above, some of Vialing’s Services involve processing data on behalf of Customers in relation to the Applications, tools, or software that Vialing provides. Except for the limited circumstances outlined in this Notice, Vialing is not the Data Controller of this Hosted Data, as Vialing does not determine the purposes or the means of the processing.
If a Customer wishes to access, correct, update, modify, or delete Hosted Data, or no longer wants to be contacted by one of Vialing’s Customers, they should direct their query to the Customer, who is the Data Controller of their data. If a Customer requests Vialing to action a Request, Vialing will respond within a reasonable timeframe.
If a Customer of Vialing’s Services wishes to raise a Request on behalf of data subjects in connection with Hosted Data, Customer may raise a ticket on the support portal of the relevant Service. Please note that if Customer has subscribed to more than one Service, a Request on a particular Service support portal is specific to that Service only, and separate Requests need to be raised across other relevant Service support portals.
Customers have the right to receive notice of specific details about Vialing’s data collection, use, and disclosure practices. Vialing does not sell personal information as defined by the PDPA 2010. The following table summarizes the categories of personal information Vialing may collect and disclose to service providers. While Vialing does share personal information (as defined by the PDPA 2010), this is explained further below the following table. The categories used to describe personal information align with those enumerated in the PDPA 2010.
Vialing may collect this personal information for the purposes described in the section above titled ‘WHAT PERSONAL DATA DOES VIALING COLLECT, HOW DOES VIALING USE CUSTOMER PERSONAL DATA, AND WHAT LEGAL BASIS DOES VIALING RELY ON.’
CATEGORY | SOURCE |
Identifiers (such as contact information or personal characteristics like name, email address, postal address, or social media handles) | You, Vialing’s social media pages |
Health Information (such as protected health information or physical or mental health status) | You |
Financial Information (such as payment data, bank account information, or credit information) | You |
Protected Classifications and Other Sensitive Data (such as date of birth or gender) | You |
Student Data (such as education records, or behavioural data) | You |
Commercial Information (such as transaction information, billing and payment records, or order history) | You |
Biometric Information (such as fingerprint, voiceprint, facial recognition, or eye recognition) | You |
Geolocation Information (such as approximate location based on the Customer’s IP address) | You |
Internet or Electronic Network Activity Information (such as IP address, device identifier (e.g., MAC), cookie or tracking pixel information, browsing or search history, or diagnostic information) | You |
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information (such as call recordings, photographs, or video) | You |
Professional or Employment-Related Information (such as current employer or job title) | You |
Education Information (such as education history and level of education) | You |
Inferences Drawn About the Customer (such as user profile reflecting preferences, characteristics, psychological trends, or predispositions) | You |
Content of Communications (such as contents of phone calls, emails, text messages, or photos) | You |
Contacts (such as a list of contacts provided by the Customer or collected from the Customer’s device with permission) | You |
Vialing may share the categories of Identifiers, Geolocation Information (coarse location only), and Internet or Electronic Network Activity Information with advertising partners as described above.
The retention period for each category of personal information listed above is determined based on the following factors: (1) the duration needed to retain the information to fulfil the business or commercial purpose for which it was collected, (2) any applicable legal or regulatory requirements, (3) internal operational needs, and (4) any requirements for the information based on actual or anticipated investigation or litigation.
Entities to whom Vialing discloses information for business purposes are service providers, which are companies engaged to perform activities on Vialing’s behalf. Vialing restricts service providers from using personal information for any purpose that is not related to their engagement.
Vialing may disclose personal information collected from Customers as described in this privacy notice:
Vialing may also disclose personal information to other external parties when required by law or to protect Vialing or other persons, as described in this privacy notice.
Additionally, Vialing may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Vialing’s assets or capital stock, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding, in which personal information held by Vialing about Customers is among the assets transferred. If this happens, the recipient of the personal information will continue to honor the promises made in this privacy notice or provide Customers with notice of
If you no longer wish to receive marketing communications from Vialing, you can click on the “unsubscribe” link found at the bottom of our marketing emails or contact us at [email protected]. Additionally, when using our Mobile Applications, you have the choice to disable push notifications.
If you would like to object to the use of your Personal Data for analytics, you can contact us at [email protected]
To opt out of the use of cookies, please see update your preferences.
10.OTHER COMMUNICATIONS
If you are our customer, we will send you important announcements related to our services via email or in-product notifications when necessary. For example, if our services are temporarily suspended for maintenance, you may receive an email from us. These communications are essential for effectively delivering our services, and generally, you cannot opt-out of them. If you prefer not to receive such communications, you may deactivate your account.
11.RETENTION OF PERSONAL DATA
We will retain your personal data only for as long as it is necessary for the purposes outlined in this notice. This includes complying with our legal obligations, maintaining accurate financial records, handling complaints, and enforcing our agreements.
For personal data processed in connection with our services, we may retain it for up to six seven years from the date the services were provided, in accordance with our data protection obligations. After this period, we may securely destroy the data without further notice.
For other personal data, we generally retain it for up to three years from our last interaction with you, in compliance with our data protection obligations. After this period, we may securely destroy the data.
If personal data is only needed for a short period (e.g., for a specific promotion or marketing campaign), we will not retain it longer than necessary. If you opt-out of marketing communications, we will maintain certain personal data indefinitely on a suppression list to ensure we do not send you further marketing communications, unless you opt back in.
If you apply for a job with us, we will retain your application data for record-keeping and legal purposes for a limited period. We may also retain it to contact you about future job opportunities if we believe you are suitable, subject to applicable laws.
These retention periods may vary due to local laws, liability periods, and mandatory retention requirements. For instance, if specific information must be retained longer under local laws or regulations, or due to different legal limitation periods, we will adhere to those requirements.
12.LINKS TO THIRD-PARTY SITES
Our websites include links to third-party websites that are not owned or managed by Vialing. We do not control the privacy practices of these websites or third parties. When you leave our websites, we recommend reading the privacy policies of each website that collects your personal data.
13.AMENDMENTS
Changes to this Notice will be published on this URL and will become effective immediately upon posting. In the event of significant changes, we will notify you through a prominent notice on this Website, via email, or through an in-product notification. However, we recommend checking this Notice regularly to stay informed about how we handle your Personal Data. It is important to visit this Notice frequently to remain fully aware. Your continued use of our Websites or the Service(s) after any amendment, modification, or change to this Notice is posted signifies your acceptance of the updated terms. If you do not agree with the terms of this Notice or any revised version, you have the option to discontinue using the Websites or Service(s).
14.EFFECT OF MERGER OR ACQUISITION
If Vialing undergoes a business transition like a merger, acquisition by another company, or sale of its assets, Customers’ Accounts, Collected Data, and Customer data may be transferred as part of the transaction. We will prominently notify you of any change in ownership or control through our Websites, and Customers will receive notification via email.
15.CONTACTING VIALING
If you have any questions about this Privacy Notice or our privacy practices, you can contact us at [email protected] or via postal mail at Vialing Sdn Bhd., 9-3 Galleria Cyberjaya, Jalan Teknokrat 6, Cyber 5, 63000 Cyberjaya, Selangor, MALAYSIA attention: Data Protection Officer, with a copy to [email protected].
DEFINITIONS
“Controller”, “Data Subject”, “Personal Data Breach”, “Processor” and “Process” shall have the meaning given to them in the PDPA 2010 or other applicable law.
“Account”: means any accounts or instances created by or on behalf of Customer for access to and use of any of the Service(s).
“Affiliate”: means, with respect to Vialing’s entity, any entity that directly or indirectly controls, is controlled by, or is under common control with such Vialing entity, whereby “control” (including, with correlative meaning, the terms “controlled by” and “under common control”) means the possession, directly or indirectly, of the power to direct, or cause the direction of the management and policies of such person, whether through the ownership of voting securities, by contract, or otherwise.
“API”: means the application programming interfaces developed, enabled by, or licensed to Provider that permits a User to access certain functionality provided by the Service(s).
“Documentation”: means, the then-current, generally available user documentation provided by Vialing detailing the functionalities of the Software and the Services.
“PDPA”: means the Personal Data Protection Act 2010 to regulate the processing of personal data in the commercial transactions and to provide matters connected therewith and incidental thereto, effective in Malaysia.
Application Software”: mean the software applications created, developed, and owned by Vialing to enable access and use of the Service(s).
“Personal Data” means, data relating to an individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller (as defined under applicable data protection laws).
“Processing”/ “To Process”: means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
“Customer Data”: means all electronic data, text, messages or other materials, including, without limitation, Personal Data of Users and End Users, submitted to the Services by Customer or its Users through Customer’s Account in connection with Customer’ use of the Services.
“Service(s)”: means, the Vialing software-based service offerings identified on the SOF and any Updates, including any Software, API or Documentation made available by Vialing with such offering, but excludes any applications or APIs separately provided by third parties.
“Software”: means the generally available software provided by Vialing in connection with Customer’s use of the Services but excludes any applications or APIs that are provided by third parties. “User”: means, any individual who is authorized by Customer to use the Services, including an Account administrator, employees, consultants, contractors, and agents of Customer or its Affiliates, and third parties with which Customer or its Affiliates transact business.
