Nurraysa App Privacy Policy

NURRAYSA APP DATA POLICY

INTRODUCTION

1.1 This platform is run by Nurraysa Global Sdn Bhd and its affiliates (individually and collectively referred to as, “Nurraysa”, “we”, “us” or “our”). Nurraysa takes its responsibilities under applicable privacy laws and regulations (“Privacy Laws”) seriously to properly manage, protect and process our Users personal data, privacy rights and concerns on our website and mobile application (the “Platform”) (we refer to the Platform and the services we provide as described on our Platform collectively as the “Services”). Users refers to a user who registers for an account with us for use of the Services, including both buyers and sellers (individually and collectively, “Users”, “you” or “your”. This Privacy Policy shall assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.

1.2 “Personal Data” means any data, whether true or not, about an individual/company who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data may include name, identification number and contact information.

1.3 By using the Services, registering for an account with us, visiting our Platform, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. KINDLY DO NOT USE OUR SERVICES OF ACCESS OUR PLATFORM IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY. You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.

1.4 Any changes to our Privacy Policy shall be notified to you by posting those changes on our Platform. We reserve the right to amend this Privacy Policy from time to time whenever it is required. To the fullest extent permissible under applicable law, your continued use of the Services or Platform, including placing of any orders, shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.

1.5 This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.

1.6 This Policy applies to both buyers and sellers who use the Services except where expressly stated otherwise.

WHEN WILL NURRAYSA COLLECT PERSONAL DATA?

2.1 NURRAYSA may collect personal data about you:

when you register and/or use our Services or Platform, or open an account with us;
when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when you interact with our customer service agents;
when you use our electronic services, or interact with us via our application or use Services on our Platform. This includes, without limitation, through cookies which we may deploy when you interact with our application or website;
when you grant permissions on your device to share information with our application or Platform;
when you link your account with us on your social media or other external account or use other social media features, in accordance with the provider’s policies;
when you carry out transactions through our Services;
when you provide us with feedback or complaints;
when you register for a contest; or
when you submit your personal data to us for any reason

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

WHAT PERSONAL DATA NURRAYSA MAY COLLECT?

3.1 The personal data that we may collect includes but is not limited to:

Account Information. Your Nurraysa ID and related account details, including email address, devices registered, account status, gender and age;
Device Information. Data from which your device could be identified, such as device serial number, or about your device, such as browser type;
Contact Information. Data such as name, email address, physical/billing/delivery address, phone number, or other contact information;
Payment Information. Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information;
Transaction Information. Data about purchases of Nurraysa products and services or transactions facilitated by Nurraysa, including purchases on Nurraysa platforms;
Usage Data. Data about your activity on and use of our offerings, such as app launches within our services, including browsing history; search history; product interaction; crash data, performance and other diagnostic data; and other usage data;
Financial Information. Details including salary, income, and assets information where collected;
Government ID Data. In certain jurisdictions, we may ask for a government-issued ID in limited circumstances, including when setting up a wireless account and activating your device, for the purpose of extending commercial credit, managing reservations, or as required by law for our due diligence;
Other Information You Provide to Us. Details such as the content of your communications with Nurraysa, including interactions with customer support and contacts through social media channels OR information about your network and the people and accounts you interact with;
Permission to Use Camera for app functionality purposes; or
Permission to Collect Device Id for push notification (collected data is secure and will not share to other user)
Information sent by or associated with the device(s) used to access our Services or Platform;
marketing and communications data, such as your preferences in receiving marketing from us and third parties, your communication preferences and history of communications with us, our service providers, and other third parties; and
any other information about the User when the User signs up to use our Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses our Services or Platform.

3.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify the information provided by you.

3.3 If you sign up to be a user of our Platform using your social media account (“Social Media Account”), link your account with us to your Social Media Account or use any of our social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider’s policies, and we will manage and use any such personal data in accordance with this Policy at all times.

3.4 You may opt out at any time or request to correct your data by notifying our Data Protection Officer in writing if you do not want us to collect the aforementioned information/personal data. You may withdraw your consent for the collection, use and/or disclosure and/or request deletion of your personal data in our possession or under our control by sending an email to our Personal Data Protection Officer at admin@nurraysa.com and we will process such requests in accordance with this Privacy Policy and our obligations under the Privacy Laws and other applicable law. However, your withdrawal of consent may mean that we will not be able to continue providing the Services to you and we may need to terminate your existing relationship and/or the contract you have with us. Please also note that by opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services and the Platform.

3.5 We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

3.6 We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances.

COLLECTION OF OTHER DATA

4.1 As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you browse our Platform. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a “cookie” (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our site.

4.2 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device’s location services, please contact your mobile device service provider or the device manufacturer. Do note that by disabling your mobile device’s location services, our location based services may be affected.

4.3 As when you view pages on our website or mobile application, when you watch content and advertising and access other software on our Platform or through the Services, most of the same information is sent to us (including, without limitation, IP Address, operating system, etc.); but, instead of page views, your device sends us information on the content, advertisement viewed and/or software installed by the Services and the Platform and time.

COOKIES

5.1 We or our authorized service providers and advertising partners may from at any time use “cookies” or other features to allow us or third parties to collect or share information in connection with your use of our Services or Platform. These features help us improve our Platform and the Services that we offer, as well as helps us to offer new services and features, and/or enable us and our advertising partners to serve more relevant content to you, including through remarketing. “Cookies” are identifiers that are stored on your computer or mobile device that record data about the computer or mobile device, how and when the Services or Platform are used or visited, by how many people and other activity within our Platform. We may link cookie information to personal data. Cookies also link to information regarding what items you have selected for purchase and web pages you have viewed. This information is used to keep track of your shopping cart, to deliver content specific to your interests, to enable our third-party advertising partners to serve advertisements on sites across the internet, and to conduct data analysis and to monitor usage of the Services.

5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this you may not be able to use the full functionality of our Platform or the Services.

HOW DO WE USE THE INFORMATION YOU PROVIDE US?

6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes (collectively referred to as ‘Purposes’):

to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
to manage, operate, provide and/or administer your use of and/or access to our Services and our Platform (including, without limitation, remembering your preference), as well as your relationship and user account with us;
to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
to enforce our Terms of Service or any applicable end user license agreements;
to protect personal safety and the rights, property or safety of others;
to prevent risks and fraud;
for identification, verification, due diligence, or know your customer purposes;
to evaluate and make decisions relating to your credit and risk profile and eligibility for credit products;
to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
to allow other users to interact, connect with you or see some of your activities on the Platform, including to inform you when another User has sent you a private message, posted a comment for you on the Platform or connected with you using the social features on the Platform;
to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to recommend products and/or services relevant to your interests, to improve our Services or products and/or to enhance your customer experience;
to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with our Services;
for marketing and advertising, and in this regard, to send you by various mediums and modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties that we may collaborate with) that we (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing materials. We may use your contact information to send newsletters or marketing materials from us and from our related companies;
to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or where we have a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on our Platform or on its related corporations or affiliates (including, where applicable, the display of your name, contact details and company details);
to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
to audit our Services and business;
to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
to respond to any threatened or actual claims asserted against us or other claim that any Content violates the rights of third parties;
to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves Nurraysa as a participant or involves only a related corporation or affiliate of Nurraysa as a participant or involves Nurraysa and/or any one or more of Nurraysa’s related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation; and/or
any other purposes which we notify you of at the time of obtaining your consent.

6.2 You acknowledge, consent and agree that Nurraysa may access, preserve and disclose your Account information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over Nurraysa or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over Nurraysa; (c) enforce the Nurraysa Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against Nurraysa or other claim that any Content violates the rights of third parties; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of Nurraysa, its users and/or the public.

6.3 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.

HOW DOES NURRAYSA PROTECT AND RETAIN CUSTOMER INFORMATION?

7.1 We implement a variety of security measures to ensure the security of your personal data on our Platform by containing our User’s personal data behind secured networks, only accessible by a limited number of our employees. However, there is no guarantee of absolute security as there may be inevitable events through no fault of ours.

7.2 We shall retain our User’s personal data in accordance with the Privacy Laws and/or other applicable laws by destroying or anonymize any personal data when we have reasonably determined that (i) personal data is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such personal data. If you cease using the Platform, or your permission to use the Platform and/or the Services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

DOES NURRAYSA DISCLOSE THE INFORMATION IT COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES?

8.1 In conducting our businesses, we may need to use, process, disclose and/or transfer your personal data to our third-party service providers, agents and/or our affiliates or related corporations, and/or other third parties, located in or outside of Malaysia. Such third parties may include:

our subsidiaries, affiliates and related corporations;
buyers or sellers you have transacted with or interacted with on the Platform or in connection with your use of the Services for the above-stated Purposes;
other users of our Platform for one or more of the above-stated Purposes;
contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those parties which provide administrative or other services to us such as mailing houses, logistics service providers, financial services providers, advertising and marketing partners, telecommunication companies, information technology companies, and data centres;
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 Nurraysa’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Nurraysa about our Service Users is among the assets transferred; or to a counterparty in a business asset transaction that Nurraysa or any of its affiliates or related corporations is involved in;
governmental or regulatory authorities having jurisdiction over Nurraysa or as otherwise permitted under Section 6.2; and
third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

8.2 Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties may process your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. We strive to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing, or similar risks and retain your personal data only for as long as your personal data is needed for the above-mentioned Purposes.

8.3 We may share user information, including statistical and demographic information, about our Users and information about their use of the Services with advertising partners and third-party suppliers of advertisements, remarketing, and/or other programming.

8.4 For the avoidance of doubt, if the Privacy Laws or other applicable laws permits us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply. Consistent with the foregoing and subject to applicable law, we may use your personal data for recognized legal grounds including to comply with our legal obligations, to perform our contract with you, to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights, or where necessary in connection with a legal claim.

8.5 Third parties may unlawfully intercept, or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We shall make security arrangements to protect your personal data as required by the Privacy Laws; however, there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.

8.6 As set forth in Nurraysa’s Terms of Service, Users (including any employees, agents, representatives, or any other person acting for such User or on such User’s behalf) in possession of another User’s personal data through the use of the Services (the “Receiving Party”) hereby agree that, they will (i) comply with all applicable Privacy Laws with respect to any such data, including any collection, processing, storage or transfer of such data; (ii) allow Nurraysa or the User whose personal data the Receiving Party has collected (the “Disclosing Party”) to remove his or her data so collected from the Receiving Party’s database; and (iii) allow Nurraysa or the Disclosing Party to review what information has been collected about them by the Receiving Party, in each case of (ii) and (iii) above, in compliance with and where required by applicable laws.

8.7 Notwithstanding anything set forth herein, Sellers (including any employees, agents, representatives, or any other person acting for such Seller or on such Seller’s behalf) shall comply with all applicable Privacy Laws and, in respect of any buyer’s personal data received from Nurraysa, (i) are not permitted to use such buyer’s personal data except as reasonably necessary to respond to buyers’ enquiries and to carry out, respond to, process, deal with or complete a transaction without the buyers’ and Nurraysa’s prior written consent; (ii) should refrain from contacting buyers using such information outside of the Nurraysa platform; (iii) are not permitted to disclose such buyer’s personal data to any unauthorized third parties without the buyer’s and Nurraysa’s prior written consent; (iv) shall employ sufficient security measures to protect each Nurraysa user’s personal data in their possession, retain such data only for as long as necessary for the purposes above and in accordance with the Privacy Laws, and to delete or return such data to Nurraysa upon any request from Nurraysa or as soon as reasonably possible upon completion of the transaction; and (v) to inform Nurraysa’s Personal Data Protection Officer at admin@nurraysa.com in the event of any potential data breach or other loss of such user’s data.

INFORMATION COLLECTED BY THIRD PARTIES

9.1 Our Platform uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyse how Users use the Platform. The information generated by the cookie about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Platform, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

9.2 We, and third parties, may from time to time make software applications downloads available for your use via the Platform or through the Services. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your device’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third-party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third-party products or services provided through these applications are not owned or controlled by Nurraysa. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.

DISCLAIMER REGARDING SECURITY AND THIRD-PARTY SITES

10.1 In an attempt to provide you with increased value, we may choose various third-party websites to link to, and frame within the Platform. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites may have separate and independent privacy policies as well as security arrangements. Even if the third-party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third-party web sites (even if offered on or through our Platform) may not be received by us.

10.2 Although we implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control, we are not responsible and do not guarantee the security of the personal data and/or other information that you provide on third-party sites. Third-party linked sites are only for your convenience, and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

WILL YOUR PERSONAL DATA TRANSFERRED OVERSEAS?

11.1 Your personal data and/or information may be transferred to, stored or processed outside of your country for one or more of the Purposes. In most cases, your personal data will be processed by us in Singapore, where our servers are located. Nurraysa will only transfer your information overseas in accordance with Privacy Laws.

HOW CAN YOU REACH US?

12.1 If you have any questions or concerns about our privacy practices, we welcome you to contact us by e-mail at admin@nurraysa.com.