Last updated 10th September 2021.
INTRODUCTION
Think City (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website Think City, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”) in accordance with the Malaysian Personal Data Protection Act 2010 (“PDPA”). Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.
You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.
RETENTION OF PERSONAL DATA
We may retain your personal data for as long as necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
The information we may collect on the Site includes:
Personal Data
Personally identifiable information, such as your name, email address, and telephone number that you voluntarily give to us when you fill out a contact form or register for a course. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.
Derivative Data
Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.
Mobile Device Data
Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.
USE OF YOUR INFORMATION
We may collect, retain and process your Personal Data (including Sensitive Personal Data) for several purposes including the following:-
- to respond to your queries including queries relating to Think City;
- to provide technical support to you, where required, and to ensure the security of the Site;
- to monitor and improve Think City’s services;
- for direct marketing services;
- to update and provide information on promotions and upcoming events or functions or product launches to you;
- to conduct research, surveys and statistical analysis;
- to send emails on updates or on any event that may be of interest to you;
- for the performance of a contract to which you are a party;
- for compliance with any legal obligation to which Think City is subject.
DISCLOSURE OF PERSONAL DATA
Think City has the sole and absolute discretion in sharing any Personal Data with the following third parties for certain limited purposes as it deems necessary, as follows:-
- Think City’s partners, trusted affiliates, promoters, event organizers, researches, and advertisers as part of the efforts to conduct statistical analysis of current or future global trends as well for marketing, advertising and promotional purposes of future products, and/or events;
- third party service providers which helps operate Think City and its website; as well as all other social media websites operated for and on behalf of Think City and/or administer activities on Think City ’s behalf, such as to send out newsletters and/or emails, to conduct text messaging blasting and/or surveys; and
- Think City ’s legal representatives, accountants, auditors, consultants, promoters, event organizers and such other service providers in the conduct and administration of its affairs.
Your consent pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to the with regard to processing of your personal data.
Data that has been anonymized does not personally identify you and is not covered by this Privacy Policy.
We hold our employees, agents, and suppliers accountable for maintaining the trust that you place in us with your personal data. Your personal data will not be used or shared except as in accordance with applicable law relating to personal data.
Your personal data may be shared with third party service providers as set out above.
As a result of the scope of the Site’s operation, the sharing of your personal data with our other group entities, service providers, and customers may result in your personal data being sent to countries outside of your country of residence, which may have data protection laws that differ from those in your country of residence. Regardless of the source or destination location of your information, we will at all times protect your personal data as described in this Privacy Policy, and in accordance with applicable data protection laws when transferring your personal data.
TRACKING TECHNOLOGIES
Cookies and Web Beacons
We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. When you access the Site, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.
We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. For more information on how we use cookies, please refer to our Cookie Policy posted on the Site, which is incorporated into this Privacy Policy. By using the Site, you agree to be bound by our Cookie Policy.
Website Analytics
We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
POLICY FOR CHILDREN
We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. If you set the DNT signal on your browser, we will respond to such DNT browser signals.
CONTACTING US
If you have any questions, grievances or complaints, or comments about this Privacy Policy and/or the handling of your personal data by us, please contact us at:
Address:
Bangunan UOB by Think City,
Level 1, No 21-35,
UAB Building, Gat Lebuh China,
10300 George Town, Pulau Pinang.
GOVERNING LAW
This Privacy Policy shall be governed by and construed in accordance with the laws of Malaysia.