* PRIVACY POLICY**
We, WELNUTS SDN BHD [Company No.:201801034632(1296659-A)] ,respect the privacy of
individuals with regard to personal data and are committed to protecting the privacy of our
users/subscribers/customers (collectively, “ Users ”), and strive to provide a safe and secure user
experience.
You may refer to the group structure of WELNUTS SDN BHD here .
This Privacy Policy is formulated in accordance with the Personal Data Protection Act 2010
(” Act “), which describes how your information (“ Personal Data ”) is collected and used and
your choices with respect to your Personal Data. For absolute clarity, any reference to “we”,
“our” or “us” in this Privacy Policy shall include any member of WELNUTS SDN BHD . The
following discloses our information gathering and dissemination practices for www.welnuts.com
and mobile applications created and/or owned by WELNUTS SDN BHD that are made available
to you for download from the app stores, including but not limited to “Apple App Store”,
“Google Play” and “Huawei App Gallery” (collectively, “Websites”) and if relevant, for the use
of, or subscription to, or purchase of any products and/or services offered by WELNUTS SDN
BHD.
- Information collected by the Websites
Our Websites’ servers do not automatically recognize specific information about individual users
on our Websites. In addition, our servers do not automatically record information regarding a
User’s e- mail address unless the User supplies it.
We collect information about Users during the registration process for certain parts of our sites;
through their participation in certain activities, including contests, forums, and polls; and through
the use of cookies. When you request pages from our server, it automatically collects some
information about your preferences, including your internet protocol (“ IP ”) address. We use this
to help diagnose problems with our server, and to administer our Websites.
The User-supplied information collected through the registration process, surveys, contest entry
forms, polls or other similar vehicles is used to improve the content of our sites, or used for our
marketing purposes. It is not shared with other organizations for commercial purposes unless
specifically stated herein. - Purpose of Personal Data collected
Personal Data that you provide to us voluntarily on our Websites and the other related channels
may be processed and/or disclosed to our Vendors (as hereinafter defined) for the following
purposes (collectively, ” Purposes “):
▪ to manage, verify and complete transactions with you;
▪ to manage and verify your membership for our customer loyalty scheme (where applicable);
▪ to direct market our products and/or services to you;
▪ to understand and analyse our sales, and your needs and preferences;
▪ to develop, enhance, market and provide products and services to meet your needs;
▪ to enable you to participate in promotions and contests;
▪ to process exchanges or product returns;
▪ to improve our services;
▪ to respond to your requests or complaints;
▪ to send you updates on products, news and event updates, rewards and promotions, special
privileges and initiatives offered by WELNUTS SDN BHD and/or its partners and/or advertisers;
▪ to process your payment transactions;
▪ for our credit control service and/or collection of debts due and owing to us; and
▪ to comply with any regulatory, statutory or legal obligation imposed on us by any relevant
authority.
Although the precise details of the Personal Data collected will vary according to the specific
purpose (such as contests, forums, surveys etc.) whether via online or otherwise, we may
typically collect the following Personal Data from or in relation to you:
▪ Name;
▪ Address;
▪ Phone number(s);
▪ Date of birth;
▪ Email address;
▪ Gender;
▪ Identity card number or passport number - Use and Disclosure
We may disclose your Personal Data within WELNUTS SDN BHD and/or to the Vendors (as
hereinafter defined) for the Purposes set forth hereinabove in accordance with the terms and
conditions set out herein.
We are responsible for the Personal Data under our control, including Personal Data disclosed by
us to a Vendor (often referred to as the data processor and third party service providers).
” Vendor ” in this Privacy Policy means in relation to Personal Data, any person or entity (other
than our own employee) who processes the Personal Data on behalf of us and/or who provide
third party services for us. ” Processing “, in relation to Personal Data means for example
obtaining, recording, holding or using the Personal Data in carrying out any operation or set of
operations on the Personal Data and/or providing its respective services to us.
We take every measure to provide a comparable level of protection for Personal Data should the
information be processed by a Vendor.
We use and disclose aggregated non-personally identifying information collected through the
Websites as part of our organization’s process of constantly improving the Websites, and the
products and services offered by ABC SDN BHD. - Impact of Non Provision of Personal Data
Please note that in the event that sufficient Personal Data is not supplied, or is not satisfactory to
us, then your application or request for any of the above Purposes may not be accepted or acted
upon or your request to browse some information on the Websites, or the use of, or subscription
to, or purchase of any products and/or services offered by WELNUTS SDN BHD may be denied
or affected. - Storage and Retention of Personal Data
Your Personal Data shall be stored either in hard copies in our offices or in servers located in
Malaysia. It may be necessary to transfer your Personal Data to third party services providers
based/located outside Malaysia. By continuing to use the Websites, products and/or services of
WELNUTS SDN BHD , you hereby consent to such transfer.
Any Personal Data supplied by you will be retained by us as long as necessary for the fulfilment
of the Purposes stated in paragraph (2) above or as required to satisfy legal regulatory,
accounting requirements or to protect our interests.
Save and except as provided in paragraph (15) hereof, we do not offer any online facilities for
you to delete your Personal Data held by us. - How Email and ‘Contact Us’ messages are being handled
We may preserve the content of any email or “Contact Us” or other electronic message that we
receive.
Any Personal Data contained in those messages will only be used or disclosed in ways set out in
this Privacy Policy.
The message content may be monitored by our service providers or employees for purposes
including but not limited to compliance, auditing and maintenance or where email abuse is
suspected. - Communication or Utilisation Data
Through your use of telecommunications services to access the Websites and/or any other sites
operated and/or managed by WELNUTS SDN BHD, your communications data (e.g. IP address)
or utilization data (e.g. information on the beginning, end and extent of each access, and
information on the telecommunications services you accessed) are technically generated and
could conceivably relate to Personal Data.
To the extent that there is a compelling necessity, the collection, processing and use of your
communications or utilization data will occur and will be performed in accordance with the
applicable data privacy protection legal framework. - Automatic Collection of Non-Personally Identifiable Data
When you access the Websites and/or use of any product/services offered by WELNUTS SDN
BHD, we may automatically (i.e., not by registration) collect, use and disclose non-personally
identifiable data, including but not limited to information about your Internet browser and
operating system, domain name of the website from which you came, number of visits, average
time spent on the site and pages viewed.
We may use and disclose these non-personally identifiable data and share it within ABC SDN
BHD and/or third parties to inter alia; monitor the attractiveness of the Websites and improve our
performance/product/services/content on an aggregate, anonymize and non-personally
identifiable basis. However, please be assured that this information is not intended to be used to
personally identify you.
For example, we may collect:
▪ Device information— such as your hardware model, IP address, other unique device identifiers,
operating system version, browser type and settings, such as language and available font settings,
and settings of the device you use to access our Websites.
▪ Usage information— such as information about your usage of the Websites, products and/or
services offered by WELNUTS SDN BHD, the time and duration of your usage and other
information about your interaction with content offered by WELNUTS SDN BHD , and any
information stored using cookies, mobile ad identifiers, and similar technologies that we have set
on your device. For detailed information about our use of cookies, web beacons, and other
technologies, see Online Tracking and Advertising in paragraph (9) below.
▪ Location information— such as your computer’s IP address, your mobile device’s global
positioning system (GPS) signal or information about nearby WiFi access points and cell towers
that may be transmitted to us when you use certain services. - Online Tracking and Advertising
How We Use Cookies, Web Beacons, and Similar Technologies and How to Disable These
Technologies
We and any third parties duly appointed/authorized by us to provide content, advertising, or
functionality or measure and analyze advertisement performance on our Websites (collectively,
“ Authorized Third Parties ”), may use cookies, web beacons, mobile advertising identifiers,
and similar technologies to facilitate administration and navigation, to better understand and
improve our Websites, to determine and/or improve the advertising shown to you here or within
the online sites operated and/or managed by ABC SDN BHD, and to provide you with a
customized online experience.
Cookies . Cookies are small files that are placed on your computer when you visit the Websites.
Cookies may be used to store a unique identification number tied to your computer or device so
that you can be recognized as the same user across one or more browsing sessions, and across
one or more sites. Cookies serve many useful purposes. For example:
▪ Cookies can remember your sign-in credentials so you do not have to enter those credentials
each time you visit a Website.
▪ Cookies can help us and the Authorized Third Parties understand which parts of our Websites are
the most popular because they help us see which pages and features users access and how much
time they spend on the pages. By studying this kind of information, we are better able to adapt
our Websites and provide you with a better experience.
▪ Cookies help us and the Authorized Third Parties understand which advertisements you have
seen so that you don’t receive the same advertisement each time you visit our Websites.
Most browsers accept cookies automatically, but can be configured not to do so or to notify the
user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu
to learn how to disable cookies. If you disable browser cookies or flash cookies, it may interfere
with the proper functioning of our Websites.
Beacons . We, along with the Authorized Third Parties, also may use technologies called beacons
(or “pixels”) that communicate information from your device to a server. Beacons can be
embedded in online content, videos, and emails, and can allow a server to read certain types of
information from your device, know when you have viewed particular content or a particular
email message, determine the time and date on which you viewed the beacon, and the IP address
of your device. We and third parties use beacons for a variety of purposes, including to analyze
the use of the Websites and products and/or services offered by WELNUTS SDN BHD and (in
conjunction with cookies) to provide content and advertisements that are more relevant to you.
Local Storage & Other Tracking Technologies . We, along with third parties, may use other
kinds of technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and
Hypertext Markup Language revision 5 (HTML5) local storage, in connection with our
Websites. We also may use unique identifiers associated with your device, such as mobile
advertising identifiers. These technologies are similar to the cookies discussed above in that they
are stored on your device and can be used to store certain information about your activities and
preferences. However, these technologies may make use of different parts of your device from
standard cookies, and so you might not be able to control them using standard browser tools and
settings. For HTML5 local storage, the method for disabling HTML5 will vary depending on
your browser. For Flash cookies, information about disabling or deleting information contained
in Flash cookies can be found here .
Additional Choices With Respect To Targeted Advertising
As described above, we and the Authorized Third Parties may use cookies and other tracking
technologies to facilitate serving relevant advertisements to you. For example, these technologies
help us determine whether you have seen a particular advertisement before, tailor advertisements
to you if you have visited our Websites before, and avoid sending you duplicate advertisements.
Due to differences between using apps and websites on mobile devices, you may need to take
additional steps to disable tracking technologies in mobile applications. Many mobile devices
allow you to opt-out of targeted advertising for mobile applications using the settings within the
mobile application or your mobile device. For more information, please check your mobile
settings. You also may uninstall our applications using the standard uninstall process available
on your mobile device or app marketplace. - Public Forums
Our Websites make information sharing, feedback, forums, and/or message boards available to
Users. Please remember that any information that is disclosed in these areas becomes public
information and you should exercise caution when deciding to disclose your Personal Data. We
request that users treat each other with courtesy and mutual respect. - Confidentiality
Personal Data held by us will be kept confidential in accordance with this Privacy Policy
pursuant to any applicable law that may from time to time be in force.
Any questions, comments, suggestions or information other than Personal Data sent or posted to
the Websites, or any part thereof by Users will be deemed voluntarily provided to us on a
non-confidential and non-proprietary basis.
We reserve the right to use, reproduce, disclose, transmit, publish, broadcast and/or post
elsewhere such information freely without further reference to you. - Security
Our Websites have security measures in place to protect the loss, misuse and alteration of the
information under our control. When a User is asked to provide his/her credit card information,
we provide a secure environment through our partners’ systems (using industry standard SSL or
SET protocols) for this purpose.
For the internet, unfortunately, no data transmission over the internet can be guaranteed as
completely secure. So while we strive to protect such Personal Data, we cannot ensure or warrant
the security of any Personal Data transmitted to us and individuals do so at their own risk. Once
any Personal Data comes into our possession, we will take reasonable steps to protect that
information from misuse and loss and from unauthorised access, modification or disclosure.
A username and password may be essential for you to use some sections of the Websites. For
your own protection, we require you to keep these confidential and to change your password
regularly (if required). - Links
Our Websites contain links to other sites. We are not responsible for the privacy practices or the
content of such sites. We have established relationships with advertisers and/or business partners
but such relationships are generally technical in nature, or content collaborations. If any
advertisers and/or business partners access to any information entered by Users in our database,
this fact shall be disclosed to the Users upon initiating the registration process. Users who feel
they do not wish their information to be shared by anyone other than the Websites may then opt
out of completing the registration. - Right of Access to Personal Data
Under the Act, you have the right of access to your Personal Data held by us on payment of a
prescribed fee and to request correction of the Personal Data that is inaccurate, incomplete,
misleading or not up-to-date. If you have any questions regarding this Privacy Policy or if you
wish to request access to your Personal Data or if you wish to correct your Personal Data or if
you wish to withdraw your consent for future marketing communication, you may send your
request in writing to:
WELNUTS SDN BHD
14 & 16, Laluan Perusahaan Kledang 3,
Taman Perindustrian Chandan Raya,
Menglembu, 31450 Ipoh Perak - Changes to Privacy Policy
We reserve the right to amend this Privacy Policy from time to time without prior notice. Any
changes to the Privacy Policy will be uploaded onto our Websites and therefore, we encourage
you to check/visit the Websites from time to time for any changes on a regular basis.
In the event of conflict between the English and Bahasa Melayu versions of the Privacy Policy,
the English version of the Privacy Policy shall prevail.
(Last updat ed 21 January 2021)
