CONTENT TO ACTION

Scope of this notice

Please read this privacy notice (“Notice”) carefully to understand our policies and practices regarding your Personal Data and how We will treat it. This Notice applies to individuals who interact with Content To Action as consumers (“You”). This Notice explains how your Personal Data are collected, used and disclosed by Content To Action (“Our”, “We”, “Us”) when you visit our mobile application (the “Application”). It also tells you how you can access and update your Personal Data and make certain choices about how your Personal Data are used.

Personal Data refers to information that relates directly or indirectly to you, which can be used to identify you on its own or in combination with other data that We collect or have access to.

By using our Application, giving Us your Personal Data, you are accepting the practices described in this Notice. If you do not agree to this Notice, please do not access Our application or otherwise give Us any of your Personal Data. This Notice may be updated from time to time.

This Notice provides important information in the following areas:

1. Personal data that we collect about you and how we collect it.

Depending on how you interact with Content To Action, We collect various types of information from you, as described below.

Personal data. This includes any information you provide to Us voluntarily when using the Application such as your name, e-mail address, social network url, phone number, or your personal profile. If you choose to share data about yourself via your profile, these data will be made public on the internet.

Derivative data. Information our servers automatically collect when you access the Application, such as your native actions that are integral to the Application, including liking, replies, as well as other interactions with the Application via server log files.

Mobile device access. We may request access or permission to certain features from your mobile device, including your mobile device’s [camera, contacts, reminders, sensors, social media accounts, storage] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Market research & consumer feedback. Any information that you voluntarily share with Us about your experience of using our products and services.

Push Notifications. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Third-party data. Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Application permission to access this information.

Payment and Financial information. We store only very limited, if any, financial information when you subscribe or make a purchase, return, exchange, or request information about our services from the Application. All financial information is stored by our payment processor [In-app apple payment][In-app Google Play Store payment] in a manner compliant with applicable laws, regulation and security standards. You are encouraged to review their privacy policy and contact them directly for responses to any questions.

2. Personal data of children

We do not knowingly solicit or collect personal data from children below the age of 15. If We discover that we have unintentionally collected personal data from a child below 15, We will remove that child’s personal data from our records promptly. However, Content To Action may collect personal data about children below the age of 15 years of age from the parent or guardian directly, and with that person’s explicit consent. In these situations, you confirm that they have appointed you to act for them and to consent on their behalf to processing their personal data in accordance with this privacy notice.

3. Cookies/similar technologies, log files and web beacons

Web analytics cookies
We may also partner with selected third-party vendor, such as Google Analytics, and others, to allow tracking technologies and remarketing services on the Application through the use of first party cookies and third-party cookies, to analyze and track users’ use of the Application. By accessing the Application, you consent to the collection and use of your information by these third-party vendors. 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 install and/or update your settings for one of the following:
[Google Analytics Opt-Out Plugin]
[Google Ads Settings Page]

Third party websites
The Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information.

4. Uses made of your personal data

The following paragraphs describe the various purposes for which We collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.

Contests, marketing and other promotions. With your consent (where required), We use your Personal Data to provide you with information about goods or services (e.g. marketing communications, campaigns or promotions). This can be done via means such as email, ads, SMS, phone calls and postal mailings to the extent permitted by applicable laws. We may also disclose your name, Photographs or Videos in public when you participate in a campaign, event or contest in On Ground Events. Some of our campaigns and promotions are run on third party websites and/or social networks. Use of your Personal Data is voluntary, which means that you can oppose (or withdraw your consent) to the processing of your Personal Data for this purposes.

Consumer service. We use your Personal Data for consumer service purposes, including responding to your enquiries. This typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g. order status, technical issue, product question/complaint, general question, etc.).

Personalisation. With your consent (where required), We use your Personal Data

• i.
  to analyse your preferences and habits,
• ii.
  to anticipate your needs based on our analysis of your profile,
• iii.
  to improve and personalise your experience on our Websites and apps;
• iv.
  to ensure that content from our Websites/apps is optimised for you and for your computer or device;
• vi.
  to allow you to participate in interactive features, when you choose to do so.

Other general purposes (e.g. internal or market research, analytic, security). In accordance with applicable laws, We use your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research and measuring the effectiveness of advertising campaigns. We reserve the right, if you have Content To Action accounts, to reconcile those accounts into one single account. We also use your Personal Data for management and operation of our communications, IT and security systems.

Legal reasons or merger/acquisition. In the event that Content To Action or its assets are acquired by, or merged with, another company including through bankruptcy, We will share your Personal Data with any of our legal successors. We will also disclose your Personal Data to third parties

• i.
  when required by applicable law;
• ii.
  in response to legal proceedings;
• iii.
  in response to a request from a competent law enforcement agency;
• iv.
  to protect our rights, privacy, safety or property, or the public; or
• v.
  to enforce the terms of any agreement or the terms of our Website.

5. Disclosure of your personal data

In addition to the Content To Action entities mentioned in the data controllers & contact section, We share your Personal Data with the following types of third party organisations:

Third party service providers. We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. Service providers, and their selected staff, are only allowed to access and use your Personal Data on Our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure.

By law or to protect rights. If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.

6. Retention of your personal data

In accordance with applicable laws, We will use your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected to comply with applicable legal requirements. Personal data used to provide you with a personalized experience will be kept for a duration permitted by applicable laws.

7. Disclosure, storage and/or transfer of your personal data

We use appropriate measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third party social networks.

People who can access your Personal Data. Your Personal Data will be processed by our authorised staff or agents, on a need to know basis, depending on the specific purposes for which your Personal Data have been collected.

Measures taken in operating environments. We store your Personal Data in operating environments that use reasonable security measures to prevent unauthorised access. We follow reasonable standards to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and although We will do our best to protect your Personal Data, We cannot guarantee the security of the data during transmission through our Websites/apps.

Measures We expect you to take. It is important that you also play a role in keeping your Personal Data safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer. You should also make use of any privacy settings or controls We provide you in our Website/app.

8. Your rights

Access to Personal Data. You have the right to access, review and request a physical or electronic copy of information held about you. You also have the right to request information on the source of your Personal Data. These rights can be exercised by way of contacting us.

If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected. Please note that any identification information provided to Us will only be processed in accordance with, and to the extent permitted by applicable laws.

Additional rights (e.g. modification, deletion of Personal Data). Where provided by law, you can

• i.
  request deletion, the portability, correction or revision of your Personal Data;
• ii.
  limit the use and disclosure of your Personal Data; and
• iii.
  revoke consent to any of our data processing activities.

Please note that, in certain circumstances, We will not be able to delete your Personal Data without also deleting your user account. We may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your Personal Data to satisfy our business needs.

We hope that We can satisfy queries you may have about the way We process your Personal Data. However, if you have unresolved concerns you also have the right to complain to competent data protection authorities.

Emails and Communications. If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

• Noting your preferences at the time you register your account with the Application.
• Logging into your account settings and updating your preferences.
• Contacting us using the contact information provided below.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

OMCONNECT SDN BHD

C-1-05 CENTUM @ OASIS CORPORATE PARK,

No.2, JALAN PJU 1A/2,

ARA DAMANSARA

47301 PETALING JAYA SELANGOR

+603-5612 0601

hello@openmindsresources.com