Privacy Policy

Emerging Journey Asia (737126-U), is committed in protecting the privacy of our users and customers in accordance to the Personal Data Protection Act 2010.

This Privacy Policy outlines our practices in relation to the collection, use and protection of Personal Data that you provide through the website, mobile application, software, products and services, such as iremya, which is operated by us (“Platform”). This Privacy Policy also explains your rights and the choices available to you regarding the use of, your access to, and how to update and correct your Personal Data.

In accepting the Terms of Use and by registering to use the Platform, you have hereby consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, you should not agree to the Terms of Use (including this Privacy Policy) and you may not use the Platform or give us any of your Personal Data.

Collection of Personal Data
In the course of your dealings with us, we may request that you provide information about yourself or any other persons (“Personal Data”) for the purposes stated in this Privacy Policy. We collect only personally identifiable information that are specifically and voluntarily provided by you.

“Personal Data” is any information about a living individual who is either identified or reasonably identifiable, or when put together with other information, would directly identify an individual, such as name, gender, date of birth, address, contact number(s), NRIC or passport number, email address, payment and billing information, information in audio and/or video format (including voice and/or video recording), Internet Protocol (IP) address, website or mobile application usage information, information collected through the use of cookies, preferences such as preferred mode of communication, and other information permitted by applicable laws. We also collect and store content that you create, input, submit, post, upload, transmit, store, display or receive in the process of using the Platform.

To access or use the Platform, you may be required to provide your location information for some functions and features that utilise geolocation data for your convenience and to improve your user experience. In cases where we collect or use your geolocation data, or any other Personal Data in the course of providing any additional services, we are not required to provide you with any notices or obtain your prior consent unless the applicable laws provide otherwise.

If you provide have us Personal Data about other individuals, you have hereby confirmed that you have been duly authorized and appointed to act on their behalf and they have agreed that you can:

  • give consent on their behalf to the processing of their Personal Data;
  • receive on their behalf any data protection notices; and
  • warrant that you have obtained their consent for us to store their Personal Data, or have the right to allow us to process their Personal Data.

In the event that you are a minor (i.e. individuals under the age of 18) and intend to provide your personal information to us, you hereby confirm and acknowledge that you have obtained your parent or legal guardian’s agreement and consent to be bound by this Privacy Policy.

Cookies and Other Tracking Technologies
Cookies (small text files placed on your device) and other similar technologies may be used on some pages of the Platform to enable us to streamline your experience of using the Platform, to enable effective provision of the Platform, and to help collect usage and performance data. Cookies allow us to help us recognise when you return, store your preferences and settings, enable you to sign in, combat fraud, and analyse how the Platform is performing.

We may also use small pieces of code known as “web beacons” or “clear gifs” to collect anonymous and aggregate advertising metrics such as counting page views, promotion views, or advertising responses. A web beacon is an electronic image called a single-pixel or clear gif. Web beacons can recognise certain types of information, such as a user’s cookie number, time and date of a page view, and description of the page where the web beacon is placed. These web beacons may be used to deliver cookies that conform to our cookies policy. Such cookies, web beacons and clear gifs may come from third parties.
We may further use cookies for the following purposes:

  • security enhancement of our systems;
  • storage of your preferences and providing customised services to you; and
  • helping us understand how people use these services and improving them.

You may choose to accept or refuse the use of cookies including cookies associated with the Platform, or to indicate when a cookie is being set by us. You may refuse the use of cookies by selecting the appropriate setting on your browser. However, if you select this setting you may be unable to use the full functionality of the Platform. After termination of the visit to the Platform, you can always delete the cookie from your system if you wish.

Cookies and other tracking technologies may also be used to support analytics by other third parties. By continuing to use the Platform, you have hereby consent to our use of cookies and other similar technologies in accordance with this Privacy Policy.

Source of Personal Data
The Personal Data collected, used and processed by us are sourced from wholly legitimate and transparent means, including but not limited to:

  • your access or use of the Platform;
  • any emails or correspondences that we received from you;
  • during conversations between you and our representatives;
  • any applications or forms that you submitted on the Platform;
  • customer surveys or promotional events;
  • referral programmes;
  • our business partners;
  • authorised third parties, including but not limited to, credit reporting agencies, regulatory and enforcement agencies, and other government entities;
  • when our users add you as their reference;
  • when our users add you as an emergency contact; and
  • marketing services providers or partners.

Purpose of Collection of Personal Data
We may collect, use and process the Personal Data which shall include, but not limited, to the following purposes:

  • to provide you with our products and services;
  • to administer your user account on the Platform (“Account”);
  • to verify and carry out financial transactions in relation to payments you may make on the Platform;
  • to process exchanges or product returns;
  • to enable us to provide, facilitate, perform, personalise and improve the Platform to meet your current and future needs;
  • to help us understand and develop a customised user experience based on your preferences, behaviour and activities;
  • to reward you through our customer loyalty programmes;
  • to contact and communicate with you;
  • to respond to your enquiries, and to provide customer support;
  • to resolve disputes or to investigate any complaints you made or made against you;
  • to prevent, detect or investigate any potential breaches, illegal activities or prohibited content on the Platform;
  • to monitor and analyse your use of the Platform;
  • to research, evaluate and develop the Platform;
  • for general operation and maintenance of the Platform;
  • to promote or communicate information, updates, and news about the Platform or new products and services of ours and our subsidiaries and such communications are only initiated from us;
  • to be used in, to provide and/or to improve the Platform, market surveys, processing invoices and payment, and client profiling activities regarding the Platform;
  • for internal functions such as evaluating the effectiveness of marketing, market research, statistical analysis and modelling, reporting, audit, and risk management;
  • to develop, show, measure and track advertising (including but not limited to, content, survey and promotions of the Platform or new products and services of ours)
  • to be used in third party analytics tools and advertising networks, and to collect information about you and on how you interact with it while you use the Platform;
  • to maintain our operations or client relationship management systems;
  • to enforce and exercise rights stated in this Privacy Policy or the Terms of Use;
  • to maintain and upkeep customer or company records and development in the ordinary course of business;
  • for our internal record keeping;
  • for prevention and detection of crime;
  • to conduct client due diligence, to verify your identity, to monitor, detect and deter unauthorised or fraudulent use or abuse of the Platform;
  • for the preparation and execution of all necessary documents, agreements and/or contracts for the Platform;
  • those purposes specifically provided for in any particular product or service offered by us; and
  • to meet any legal or regulatory requirements relating to all the commercial transactions, our conduct of the business or activities or our provision of services, and to make disclosure under the requirements of any applicable laws, regulations, directions, court orders, by laws, guidelines, circulars, codes applicable to us or any member of our group of companies from time to time.

Consequences of Refusal or Failure to Provide Personal Data
Unless stated otherwise, the Personal Data provided to us are wholly voluntary in nature and you are not under any obligations or duress to do so. However, in some circumstances if you do not provide us with your Personal Data described in this Privacy Policy, we shall not be held liable for any of the consequences arising there from:

  • the inability for us to provide you with the products and/or services you requested, either to the same standard, or at all;
  • the inability for us to provide you with the information about products and/or services that you may want, including information about discounts or special promotions, or our new products and/or services;
  • the inability for us to tailor the content of the Platform to your preferences and your experience of the Platform may not be as enjoyable or useful;
  • the inability to complete commercial transactions in relation to the Platform; and
  • the inability to comply with any applicable laws, regulations, directions, court orders, by laws, guidelines and/or codes applicable to us.

Disclosure of Personal Data
In order for us to fulfil the purposes listed above, the Personal Data may be disclosed to the following, but not limited to, sessions of parties:

  • other users of the Platform;
  • our employees, partnerships, joint venture entities, contractors or third party service providers, third party management companies, subcontractors or other parties as may be deemed necessary by us to facilitate your dealings with us;
  • our vendors, consultants, marketing partners, research firms, and other service providers or business partners;
  • our holding, subsidiary or related companies, including those incorporated in the future, and/or any member of our group of companies;
  • our auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our business;
  • any persons, government agencies, statutory authorities and/or industry regulators whom we are compelled or required to do so pursuant to any laws, or if we have good faith belief that such disclosure is necessary to protect and/or defend our rights and interests or in connection with an investigation of fraud, infringement, piracy, tax avoidance and evasion or other unlawful activity;
  • any persons who is under a duty of confidentiality to which he/she has undertaken to keep such data confidential which we have engaged to fulfil our obligations to you.

Third parties are legally tasked with processing the Personal Data in line with the principles maintained and specified by us. Third parties are also held legally responsible for securing the Personal Data at an appropriate level of security in relation to applicable data protection laws and widely accepted industry standards.

The Personal Data may also be disclosed to third parties with the consent of the record subject. If we or our business is acquired by or merged with another entity, or there is a proposed acquisition or merger, the Personal Data may be transferred to such entity as part of the proposed or actual merger or acquisition. We ensure the protection of Personal Data that all appropriate confidentiality obligations and technical and organisational security measures are in place to protect the confidentiality and security of your Personal Data collected through the various methods described in this Privacy Policy to prevent any unauthorised access, unauthorised or unlawful alteration, disclosure or processing of such information and data, and the accidental loss or destruction of or damage to such information and data. These efforts include but are not limited to:

  • storing your Personal Data in systems that are protected by secure networks and operating environments that are not available to the public and are only accessible by our employees for the purpose of performing their official duties, and authorised third parties who are contractually bound to take reasonable measures to keep your Personal Data secure;
  • regularly monitoring our systems for possible vulnerabilities and attacks, and regularly review our information collection, storage and processing practices to update our physical, technical and organisational security measures; and
  • verifying the identities of users before they can access the Personal Data we maintain about them.

Compliance with these provisions will be required by all authorised third parties who may access the Personal Data as described above.

Choices to Limit Processing of Personal Data
You have the right to limit in part, or wholly, any of the processes by which your Personal Data is subjected to in terms of the operations allowed to be performed upon it, the period of time allowed, or alternatively, the deadline of the consent given. The responsibility for compliance rests with us, who determines the purposes and means of processing of your Personal Data.

You shall notify us in writing to request your Personal Data to be retained by us so long as it is necessary for the fulfilment of the purposes for which it was collected only or inform us your objection to the use of your Personal Data for marketing purposes whereupon we will not use your Personal Data for such purpose. You may withdraw, in full or in part, your consent given to us. Your withdrawal in each case is subject to any applicable legal restrictions, contractual conditions, and a reasonable time period. Your withdrawal may also be subject to whether it would affect the operation of our business. Your Rights in respect of the Personal Data which you have submitted to us, you have the right at any time to:

  • request for access to your Personal Data in our records;
  • request to make correction of your Personal Data in our records in the event the information is inaccurate, misleading, out-of-date or incomplete upon validation and verification of the new information provided;
  • request to cease processing your Personal Data for the purposes of marketing;
  • object to the processing of your Personal Data, ask us to restrict or limit processing of your Personal Data, or request portability of your Personal Data;
  • withdraw your consent for us to continue processing your Personal Data; and
  • complain to a data protection authority about our collection and use of your Personal Data.

Editing or Deleting Personal Data
In respect of requests for access to or to make correction of your Personal Data in our records, or to cease processing your Personal Data for the purposes of marketing, such requests must be made in writing and supported with submission of the relevant documents as required by us in person from time to time to the addresses set out in the Contact Us section below. We will only make appropriate corrections based on the updated information provided by you. When requested and if it is practical, we will delete identifying information from our current operation systems. Your request may also be subject to payment of a fee in accordance with applicable legal requirements.

You may request for deletion of your Personal Data by us, and we will use commercially reasonable efforts to honour your request. However, kindly note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case, we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database but may remain in our archives. We may also retain your information for fraud prevention and detection or similar purposes.

We may retain the Personal Data while your Account remains active and for a period necessary to fulfil any of the applicable purposes of use described in this Privacy Policy, or to comply with any applicable laws and regulations.
Further, we may retain the Personal Data following the closure or termination of your Account if retention is reasonable and necessary to:

  • comply with applicable laws, regulations or legal obligations;
  • provide and complete customer support service;
  • resolve disputes between or with our users; or
  • detect and deter unauthorised or fraudulent use of or abuse of the Platform.

Retention of Personal Data
The Personal Data you submit to us will only be retained for as long as is required for the purposes for which it was collected or as permitted by applicable laws.

In practice, we delete or anonymise the Personal Data upon deletion of your Account, unless:

  • we must keep it to comply with applicable laws, regulations or legal obligations;
  • we must keep it to evidence our compliance with applicable laws, regulations or legal obligations;
  • there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
  • the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security.

Even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

International Transfers of Personal Data
To provide our services, we may process and store your information on servers located in Malaysia or other jurisdictions where we deem it appropriate or desirable unless the applicable laws provide otherwise. There may be a possibility that the data protection level in other jurisdictions do not completely meet the requirements of data protection laws in Malaysia, but all such transfers are performed in accordance with the requirements of applicable laws.

Links to Other Websites or Mobile Applications
If you click on a link to a third party website or mobile application, you will leave the Platform and be redirected to the website or mobile application you selected. As we cannot control the activities of third parties, we cannot accept responsibility for any use of your personally identifiable information by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as us. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website or mobile application that is linked to the Platform, you should read that website or mobile application’s privacy statement before providing any personally identifiable information.

Browsing History
We do not obtain, capture or store your browsing activities outside or that is not part of our Platform.

Diagnostics
We may use your data to identify errors, to execute troubleshooting and/or to measure technical diagnostics related to the Platform performance.

Marketing and Promotions
We may use your Personal Data to market products, services, events or promotions of ours, our partners, sponsors and advertisers. We may communicate such marketing to you by post, telephone call, short messaging service (SMS), in-app engagement, online messaging service as well as push notification, by hand and by email. If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, you may click on the “Unsubscribe” link in the relevant email or message you receive from us. Alternatively, you may also update your preferences in your Account or contact us directly at the email address set out in the Contact Us section below. Please be aware that once we have received your request to unsubscribe, it may take up to fourteen (14) working days for us to process your request and to be reflected in our systems. Therefore, you may still receive marketing communications during this period of time.

Financial Info
We will never have access to the collection of information pertaining to any payment or transaction you make on the Platform such as in the form of payment, payment card number, or bank account number. We will not access, collect, and store any of your financial information in our Platform. We will never acquire, access, collect and/or store your personal financial information such as salary, income, assets, debts or any other financial information on our Platform.

Language
In the event of any conflicts between the English and Bahasa Malaysia versions of this Privacy Policy, the English version shall prevail.

Changes to Privacy Policy
We shall have the right to amend this Privacy Policy at any time. We will take reasonable steps to ensure changes to this Privacy Policy are communicated by posting all changes prominently on the Platform and other places we deem appropriate for a reasonable period of time. Changes to this Privacy Policy will be effective immediately once published on the Platform unless otherwise noted. Your continued access or usage of the Platform following any amendments indicates your consent to the practices described in the revised Privacy Policy. If you do not agree, you should immediately discontinue your use of the Platform. If we make any material changes, we will notify you by email (sent to the email address specified in your Account) or by any means of a notice on the Platform prior to the change becoming effective. We invite you to periodically review this Privacy Policy to be informed of any relevant changes, especially before providing any information to us.

Contact Us
If you have any feedbacks, comments or questions about this Privacy Policy, or would like to access, correct, amend or delete the Personal Data that we hold about you, or the way we handle the Personal Data, our contact details are set out as follows:

Emerging Journey Asia (737126-U)
Suite 2, Level 3A, Wisma YPR,
Lorong Kapar Off Jalan Syed Putra,
58000 Kuala Lumpur
www.iremya.com
Email : service@iremya.com
Tel : +603 2276 6411