Privacy Policy

PRIVACY POLICY

31 January, 2021

 

  1. INTRODUCTION

 

Asia Assistance Network (M) Sdn Bhd (“Asia Assistance”, “we”, “us”, “our”) is committed to maintain the privacy of Personal Data obtained in the course of our business activities and comply with the applicable laws regarding the processing of personal and sensitive personal data. Our privacy policy regarding the collection and use of your information via the AWAKEN platform (either website or mobile app) is set forth below.

AWAKEN is a digital solution that allows you to measure your health and wellbeing. AWAKEN consists of several tailored plan that carries various range of services including but not limited to health assessment, health coaching, reward program and other personalized health recommendations (“Services”). Use of the AWAKEN (either through website of mobile app) including use of any products or services available in AWAKEN will be governed by this Privacy Policy.

  1. AGREEMENT TO PRIVACY POLICY & CONSENT

By accessing or using the AWAKEN platform (either website or mobile app), you expressly agree to the terms and conditions stated herein and you shall be deemed to have consented to the collection and use of your Personal Data by the Asia Assistance. In the event you do not agree with the terms and conditions of this Privacy Policy, please do not proceed to access and use the AWAKEN platform (either website or mobile app) for any purposes.

  1. PROCESSING OF YOUR PERSONAL DATA

 

For the purpose of this Privacy Policy, “Personal Data” means any data relating to a person who can be identified either from the data, or from the data together with other information that is available, or from the data together with other information that is likely to be available. Personal Data covers any information that can identify an individual such as identification numbers or characteristics such as physical, physiological, mental, economic, cultural, or social identity.  Examples include: name, pseudonyms, address, telephone number, identity card number, occupation, salary/compensation, health or personnel records, birth date, financial/bank account information, physical characteristics, etc. Personal Data is each piece of information related to the individual, regardless of the form in which it is expressed and the format in which it is kept in or on the information holder (storage media, paper, tape, film, electronic media, etc).

When you access or use the Services, we will collect and process your Personal Data such as your email address and other relevant information in order to provide the Services to you.

We also reserve the right to share your information with third parties to the extent permitted by applicable laws including but not limited to the requirements under Personal Data Protection Act 2010. Asia Assistance maintains full rights to any information collected, and may freely collect, use and disclose such information unless prohibited by this Privacy Policy or applicable law as stated above.

 

 

 

  1. PURPOSE OF PROCESSING YOUR PERSONAL DATA

Your personal data will be processed for the following purposes:

 

  • Management of registration in order for you to access AWAKEN platform (either website or mobile app);
  • To provide you the Services to ensure you can enjoy the Services, its advantages and benefits;
  • Delivery of commercial correspondence or newsletters, whether or not personalised, on health, healthcare, wellbeing, physical exercise, nutrition, healthy lifestyles;
  • Personal profiling based on your browsing behaviour, sociocultural factors and the use of big data processing techniques, for market analysis purposes and to inform users on health services, wellbeing, healthcare, physical exercise, nutrition and healthy lifestyles, which may be of interest;
  • Profiling and completion of surveys and check-ups in order to provide you with personalised recommendations on health and lifestyles. This profiling will only be carried out if, after your registration as a user, the relevant sections are completed on the AWAKEN platform (either website or mobile app) for surveys and medical check-ups (to be filled in voluntarily).

In any case, all Personal Data will be treated confidentially and will be adequate, pertinent and not excessive for each one of the purposes indicated.

  1. SHARING AND DISCLOSURE OF YOUR PERSONAL DATA

 

You are hereby informed that your Personal Data will be processed by Asia Assistance and/or its affiliates, sub-contractors, third-party service provider in and or outside of Malaysia which is operating the AWAKEN platform (either website or mobile app) including third-parties provider(s) or supplier(s), or any person under a duty of confidentiality to which has undertaken to keep your personal data confidential which we have engaged to discharge the Services to you.

We will only use your Personal Data to the extent appropriate and necessary. We shall not sell, share or disclose your Personal Data to third party in ways that differ from what is discussed in this Privacy Policy.

However, we may share your Personal Data to the following third parties and or purposes:

  • Our affiliates or related companies either in Malaysia or outside of Malaysia;
  • Any person or third-party provider(s) or supplier(s) service provider engaged to provide the Services who are under a duty of confidentiality to keep your Personal Data confidential;
  • To third parties for the purpose of statistical purposes to understand trends or traffic patterns. In doing so, we shall not include any Personal Data that identifies individuals;
  • Professionals working on behalf Asia Assistance e.g. auditors, accountant or financial adviser, lawyers and/or other third parties as required or permitted by law or as we may determine to be necessary or appropriate;
  • Data centres, servers including cloud storage located within or outside of Malaysia for data storage purposes;
  • Government agencies, law enforcement agencies, regulatory bodies, statutory agencies or bodies if required to do so, to satisfy any applicable law or order of a court or attending queries from the relevant authorities.

 

 

 

  1. RETENTION OF YOUR PERSONAL DATA

 

  1. SECURITY

We are committed to ensuring that your Personal Data is stored securely. We endeavour, where practicable, to implement appropriate physical, administrative, electronic, technical and procedural security measures to safeguard your Personal Data as required by applicable law. We use industry standards, such as Secure Socket Layers (“SSL”) technology, to help safeguard against such occurrences. In certain cases, the information passed between your browser and our system is encrypted with SSL technology to create a protected connection between you and the AWAKEN platform (either website or mobile app) to ensure confidentiality.

Our data centre is both physically and electronically secured. Our servers are protected from open access to the internet by using firewall and we conduct penetration test. We limit access to Personal Data to our employees and third parties including the third-parties provider(s) or supplier(s), who we reasonably believe need to have access to your Personal Data.

  1. TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF MALAYSIA

For the purpose of the Services, our storage facilities, servers and or cloud storage may be located in other jurisdictions outside of Malaysia, where your Personal Data will be stored. In addition, your Personal Data may be disclosed or transferred to our affiliates located outside Malaysia or where you access the AWAKEN platform (either website or mobile app) from countries outside Malaysia.

You hereby expressly consent to us transferring your Personal Data outside of Malaysia for the purpose of the Services and your access on the AWAKEN platform (either website or mobile app). We endeavour to ensure the appropriate measures are taken to procure that all such third parties outside of Malaysia shall protect the confidentiality and privacy of your Personal Data.

  1. COOKIES

We may use “cookie” technology on and off the AWAKEN platform (either website or mobile app). “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. They enhance your online experience by saving your preferences while you are visiting a particular website. When you use the AWAKEN platform (either website or mobile app), we may place a cookie on your computer, which may be either temporary or permanent.

Temporary cookies are used to complete transactions with AWAKEN platform (either website or mobile app) and for other purposes such as counting the number of visits to certain web pages. These temporary cookies are eliminated when you exit your browser. A permanent cookie may also be stored on your computer by your browser. When you log in, this type of cookie tells us whether you’ve visited us before or if you are a new visitor. The cookie does not obtain any information about you or provide us with any way to contact you, and the cookie does not extract any information from your computer.

In addition, if you visit the AWAKEN platform (either website or mobile app) again after deleting a cookie, a new cookie may be activated. Since third parties may use their own cookies when you click on a hypertext link to their site or service, you should carefully review the privacy policy of other sites you link to, if any, from the AWAKEN platform (either website or mobile app).

  1. IP ADDRESSES

We may also log and track IP addresses for systems administration purposes and for reporting usage trends. Your IP address is usually associated with the physical place from which you enter the internet, the name of the domain and host from which you access the internet, the browser software you use and your operating system, and the date and time you access the AWAKEN platform (either website or mobile app). IP addresses are not used to track an individual user’s session. This information only helps us determine how often different areas of the AWAKEN platform (either website or mobile app) are visited.

We may combine non-identifiable information collected automatically (such as through IP addresses, cookies or click-stream monitoring) with any previously submitted Personal Data that we may have received.

  1. GEOGRAPHICAL LOCATION

We may collect your geographic location based on your IP address and other location-based data.

  1. YOUR DATA PRIVACY RIGHTS

 

11.1     Right of access to your personal data

Subject to the exception provided under the Personal Data Protection Act 2010, you are entitled to request for access to, request for a copy of, a request to update or correct, your personal data held by us. Nevertheless, we have the right to refuse your request to access or correct your personal data if providing such access is perceived to be harmful to the risks of your privacy or the rights of other may also be violated.

 

  • Withdrawal of consent and total or partial objection to the processing.

You are entitled to revoke your consent and to challenge the processing at any time, for reasons related to your individual situation, should the processing be based on our legitimate interest or that of a third party (including any processing aimed at direct marketing and profiling). In this case, we will cease its processing and your relationship with us will have to be terminated.

11.3     Data Privacy inquiries

If you have any questions about this Privacy Policy or the use of your information by, please call us at +603-7628 3888 from 9am to 5pm, Monday to Friday or email us at legal@asia-assistance.com. Please enter Data Protection Enquiry as the email subject.

 

 

  1. MODIFICATION

Asia Assistance reserves the right, at its own discretion to revise this Privacy Policy at any time without prior notice to you. If you continue using the Services after we made any changes or modification to this Privacy Policy, it shall be deemed that you agree and accept of such changes. This Privacy Policy is not a contract, nor does it create any legal or suggest any obligation on our part with another party or on behalf of another party.