Dasar Perlindungan Data

Effective Date: [*]
This Personal Data Protection Policy (“Personal Data Protection Policy”)
explains how Think City Sdn. Bhd., its affiliates, and its subsidiaries (“Think City,” “us,”
“our,” and “we”) use your personal data and this Personal Data Protection Policy applies
to anyone who uses the Bakul K2K Website, creates an Account, makes a transaction
through the Bakul K2K Website, uses a Promotion, redeems an eCoupon, applies for a
refund, interacts with our Social Media Accounts, is onboarded as a Merchant, uses the
review, complaint or report functionalities, or other online services or any of our
described activities that we own or control (collectively, the “Services”). For terms that
govern the use of the Services, please review the Terms and Conditions.

By using the Services, you acknowledge that you have read and agreed to the terms of
this Personal Data Protection Policy. If you do not want your personal data handled as
described in this Personal Data Protection Policy, please do not provide us with your
personal data or interact with the Services. If you choose not to provide the necessary
personal data to us, we may not be able to provide you with the Services or allow you
to set up an Account.

We may modify this Personal Data Protection Policy at any time. You are deemed to
agree and consent to any changes in this Personal Data Protection Policy by way of
your continued use of the Services.

If we make any material changes, we will notify you by email (sent to the email address
specified in your Account) or by means of notice on the Services prior to the change
becoming effective. You can determine when this Personal Data Protection Policy was
last revised by referring to the “Effective Date” above.

Personal data, as used in this Personal Data Protection Policy, shall have the definition
ascribed to it under the Personal Data Protection Act 2010. Defined terms shall have the
meaning ascribed to them in the Terms and Conditions unless the context otherwise
admits. To the extent that this Personal Data Protection Policy varies or modifies any
provision of the Terms and Conditions, the term in the Personal Data Protection Policy
prevails.

TYPES OF INFORMATION WE COLLECT

We may collect, and you hereby consent to such collection of, the following categories
of personal data from and about you:

• Identifiers: such as your name, postal addresses, email addresses, Account
information, social media account handle(s), telephone numbers.

• Demographic information: such as your nationality or ethnic origin, age, birthdate,
and gender.

• Commercial information: such as information that enables us to determine lifestyle,
interests, and activities (including order history), areas of interest, and information
collected through your interactions with the Social Media Accounts or the review,
complaint or report functionalities on the Bakul K2K Site.

• Location information: such as information related to your state, district, city, or
neighbourhood, and, from time to time, more specific location information that is
provided through the GPS functionality on mobile devices used to access the Services.

• Financial information: such as information collected from you as needed to process
payments for Bakuls, process any applicable Promotions or eCoupons, process any
refunds, Account creation or Merchant onboarding, or as provided by you to
administer your participation in any Services, such as your bank account details,
payment card number, expiration date, and card verification value (“CVV”). We do not
retain your bank account details, payment card number, expiration date, and CVV.

• Internet and network activity information: such as information about your browsing
behaviour, search history, and interactions with websites and advertisements,
including data from cookies, pixel tags, and web beacons.

• Inferences regarding preferences and other characteristics: such as our assessment
of the types of Services you may have an interest in. 

HOW THINK CITY COLLECTS INFORMATION

We may collect personal information about you from a variety of sources, including:

• From you: We collect information that you submit to us. For example, when you
create an Account, use the Services, make any transaction through the Bakul K2K
Website, participate in any Promotion, redeem any eCoupon, apply for or receive any refund,
register to receive information available through the Services, or interact with
us in other ways. We will collect any information you voluntarily provide, and we may
also request optional information to support your use of the Services. We also collect
any information that you voluntarily enter into the chat, review, complaint or report
functionalities within the Services. If you send an e-mail to us, we will collect your
email address and the full content of your e-mail, including attached files and other
information you choose to provide to us.

• From your device: When you use the Services, we may collect information about the
devices you use to access the Services, including hardware model, operating system
and version, Internet Protocol (“IP”) address, and other unique device identifiers, mobile
network information, and information about the device’s interaction with our Services.
We also collect information about how you use our Services, including your access
times, browser types, and language. This type of data enables us to understand how
often individuals use parts of the Services so we can analyse and improve it. To collect
this information, we use cookies and web beacons, and other similar technologies.
Note that this Personal Data Protection Policy does not cover the use of such information
by third parties.

• Location information: We may collect different types of information about your
location, including general information, such as the city, state, district and/or post code
associated with your IP address, and, if you agree, more specific location information
that is provided through the GPS functionality on mobile devices used to access the
Services. We may use such location information to customise the Services, including
advertising that is presented to you. In order to do this, your location information may
be passed along to our affiliates, agents, vendors or advertisers. You may be able to
disallow our use of certain location data through your device or browser settings.

• Social media networks and other third parties: We may obtain information about you
or your use of the Services from third party sources, such as our vendors, web-hosting
providers, analytics providers, or advertisers. You may give us permission to access
your information from services offered by third parties, including social media
networks. The information we obtain from third party services depends on your
account/privacy settings with those third parties and the third parties’ privacy policies.
When you access the Services through social media networks and other third-party
platforms, you are authorising Think City to collect, store, and use such information
and content in accordance with this Personal Data Protection Policy. Please keep in
mind that any information provided to us by a third party may also be subject to that
third party’s privacy policy.

HOW THINK CITY USES INFORMATION

We may use information collected as described in this Personal Data Protection Policy to:

• Operate, maintain, and improve the Services and other features and functionalities
related to the Services;

• Provide you with interest-based advertisements, push notifications, communications,
and offers for Services, and other goods and services related to the Services, including
based on your precise geolocation;

• Modify, use and publish any still or moving images of the Services for any promotional,
marketing, commercial, or other related purpose, without any payment or compensation;

• Facilitate any third-party logistics operator to locate and deliver any Bakul(s) to your
address;

• Evaluate any still or moving images of the Services to evaluate the delivery status of a
Bakul, including any still or moving images of you accepting receipt of a Bakul, without
any payment or compensation;

• Process payments from Users, including the payment for any Bakul, the participation in
any Promotion or the redemption of any eCoupon;

• Evaluate your eligibility for certain types of Promotions or eCoupons that may be of
interest to you, including identifying your lodgings;

• Analyse advertising effectiveness;

• Evaluate your reviews and respond to any complaints or reports;

• Evaluate any request for a refund;

• Perform analytics and conduct customer research, including through any review
functionality;

• Communicate and provide additional information that may be of interest to you about
Think City and our business partners, sometimes by combining your information with
information we obtain from other sources;

• Send you reminders, technical notices, updates, security alerts, support and
administrative messages, service bulletins, marketing messages, and requested
information, including on behalf of our business partners;

• Administer rewards, surveys, contests, or other promotional activities, including any
Promotions or eCoupons, or events sponsored by us or our business partners;

• Manage our everyday business needs, such as administration of the Services, dispute
management, fulfilment, analytics, fraud prevention, and enforcement of our corporate
reporting obligations or our Terms and Conditions, or to comply with the law;

• Allow you to apply for a job, make a complaint, make a report, or sign up for special
offers from our business partners, or other companies;

• Verify your requests made pursuant to this Personal Data Protection Policy; and

• Enhance other information we have about you to help us better understand you and
determine your interests.

We also may use information collected as described in this Personal Data Protection
Policy with your consent or as otherwise required or permitted by law.

If you use any features on the Services to send information about the Services to another
person, we will also collect the personal information of that other person to the extent
disclosed by you and may contact them using the information you provided us.

WHEN AND WHY THINK CITY DISCLOSES INFORMATION

Generally, Think City does not publicly disclose any personal data related to financial or
payment activities or any information related to your government-issued identification
card or your passport. However, we may share your personal data as follows：

• as required to comply with the law or legal obligations, such as to comply with legal
orders and government requests, or as needed to support auditing, compliance, and
corporate governance functions;

• in response to a subpoena, or similar legal process, including to law enforcement
agencies, regulators, and courts in Malaysia and other countries where we operate;

• with our professional advisers, such as our lawyers and accountants, with a view to obtain
professional advice;

• with our vendors who perform a variety of services and functions for us, such as Bakul
delivery, data storage, order fulfilment, transmitting emails, and managing digital
content. We may share your information with such vendors subject to confidentiality
obligations consistent with this Personal Data Protection Policy and on the condition that
the service providers use your information only on our behalf and pursuant to our
instructions;

• in the event we go through a business transition such as a merger, acquisition by
another company, bankruptcy, reorganisation, or sale of all or a portion of our assets;

• to combat fraud or criminal activity, and to protect our rights, Users, Merchants and
business partners, or as part of legal proceedings affecting Think City or its related
corporations;

• with our affiliates and subsidiaries who may only use the personal information for the
purposes described in this Personal Data Protection Policy;

• if the information has been aggregated, de-identified, anonymised or otherwise does
not identify you personally; or

• otherwise with your consent.

Notwithstanding the above, Think City shall in no event sell, assign or take any secured
interest over your personal data.

SECURITY OF PERSONAL DATA

Think City has implemented an information security program that contains
administrative, technical, and physical controls that are designed to reasonably
safeguard personal data that is compliant with the Personal Data Protection Standard
2015. However, no method of transmission over the Internet, or method of electronic
storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

Furthermore, you hereby consent to your personal data being stored in secure facilities
on the Cloud and acknowledge that your personal data may be processed, stored and
analysed outside of Malaysia.

YOUR RIGHTS REGARDING PERSONAL DATA

You have certain rights with regard to your personal data: 

• You have the right to know and request information about the categories and specific
personal data we have collected about you within the last twelve (12) months, as well as
the categories of sources from which such information is collected, the purpose for
collecting such information, and the categories of third parties with whom we share such
information. You also have the right to know if we have sold or disclosed your personal
data for business purposes;

• You have the right to correct or update your personal data;

• You have the right to request a copy of your personal data;

• You have the right to withdraw consent for further processing of your personal data;

• You have the right to request for us to cease processing your personal data if such
processing is likely to cause damage or distress; and

• You have the right to request for us to cease processing your personal data for the
purposes of direct marketing.

CONTACT US

Please contact us if you have any questions or comments about our privacy practices or
this Personal Data Protection Policy.

We may be contacted by emailing at k2k.publichousing@thinkcity.com.my or by writing to:

Think City Sdn. Bhd.
Level 1, No 21-35,
UAB Building, Gat Lebuh China,
10300 George Town,
Pulau Pinang,
Malaysia.

Re: Bakul K2K