PRIVACY POLICY

Your privacy is important to us. The purpose of this Privacy Policy is to inform you of how FirstClasse Asia (Malaysia) Sdn Bhd and/or its related entities, affiliates and subsidiaries (collectively referred to as “FirstClasse”, “us”, “we” or “our”) manages personal data in accordance with the Personal Data Protection Act 2010 (“the Act”) and the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission of Malaysia.

This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to help you to make an informed decision before providing us with your personal data.

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Consent

By interacting with us and/or our websites which include our e-newsletters (collectively, “our websites”), you agree and consent to us - as well as our respective representatives - collecting, using, disclosing and sharing your personal data among ourselves, business partners and other relevant third parties (who may be based outside Malaysia), in the manner set forth in this Privacy Policy.

Information We Collect

There are two broad categories of information that we collect from you – (A) personal data and (B) non-personal data.

1. (A) Personal Data
   1. “Personal Data” means data, whether true or not, about an individual who can be identified (i) from that data or (ii) from that data and other information to which we have or are likely to have access.
   2. We collect certain types of Personal Data, including your name, gender, date of birth, identification numbers, company (if applicable), contact information (e.g. address, phone number, email address), payment information (e.g. credit or debit card information), photographs and video footages taken at events organised by us and/or our business partners and any other information which you may provide in any forms submitted to us or via other forms of interaction with you.
   3. Personal Data is collected in various circumstances, including the following:
      • When you register for or use any of our services on websites owned and/or operated by us (e.g. subscription to our magazine/s, e-newsletter);
      • When you register as a member of websites owned and/or operated by us, or hosted by us on behalf of our business partners or use services on such websites;
      • When you take part in any contest, survey or promotion conducted by us and/or our business partners;
      • When you participate in events, exhibitions or roadshows organised by us and/or our business partners;
      • When we receive references from business partners and third parties, for example, where you have been referred by them; When you submit an application to us for employment or an internship;
      • and When you submit your Personal Data to us for any other reason.
   4. We may also obtain personal data about you from other sources and combine it with information you provide to us. If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
2. (B) Non-Personal Data
   • We also collect certain non-personal data when you visit and use our websites. Such data is entirely anonymous and is aggregated for statistical analysis (“Aggregate Information”).

Cookies

• We use “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you visit our websites. The cookie is used to track information such as the number of users and their frequency of use, profile of users and their preferred websites.
• Like many website operators, we may use an independent company (the “Third Party Market Research Company”) to measure and analyse the Internet usage across our websites. Pages on our websites may be coded with software which enables them to track visitors to our websites. We use the Third Party Market Research Company’s services to collect core information on the usage of our websites, including the following:
  • The number of page views (or page impressions) that occur on our websites;
  • The number of unique visitors to our websites;
  • How long these unique visitors (on average) spend on our websites when they do visit;
  • and Common entry and exit points into our websites.
• This Aggregate Information is collated by the Third Party Market Research Company and provided to us to assist in analysing the usage of our websites. This is so that we can improve the content and navigability of our websites as well as our services and facilities.
• Most browsers automatically accept cookies. You can, however, modify your browser settings to disable cookies. If you choose to do so, some of the functionality of our websites may be impaired.

Web beacons

• In addition to cookies, we may also use web beacons and other similar technologies to deliver or communicate with cookies, in order to better understand how you interact with the content on our websites.
• We also may include web beacons in e-mail messages to determine whether messages have been opened and acted upon, and how.
• The information we obtain in this manner enables us to customise the services we offer, as well as measure the overall effectiveness of our online content, advertising campaigns, and the products and services we offer through our websites.
• Our advertising partners may also place web beacons and other similar ad tracking technologies such as Doubleclick and Eyeblaster on our websites to collect Aggregate Information.
• The Aggregate Information obtained is used by our advertising partners to measure the effectiveness of their advertisements and to personalise the advertisement content that you see.

Purposes for collection, use, disclosure and processing of Personal Data

Depending on your relationship with us, your Personal Data may be collected, used, disclosed and/or processed for various purposes, including the following:

• For editorial purposes;
• To provide goods and services to you (e.g. mailing of magazines, direct mailers and event invitations);
• To verify and process your personal particulars and payments;
• To manage your subscription;
• To communicate with you (e.g. mailing of appeal letters on behalf of charitable causes and follow-up calls to event invitations);
• To send you information, promotions, updates as well as marketing and advertising materials in relation to our goods and services and those of our business partners or third party organisations;
• To send you information about any administrative changes, updates and/or amendments to our policies, terms and conditions;
• To respond to your queries, requests and/or complaints;
• For organising events or other marketing or promotional activities;
• For past, current and potential advertising leads;
• For marketing research, user profile and statistical analysis and other development activities to improve our services and facilities for your benefit.