1.0 INTRODUCTION

Welcome to Camdy by ROSCELLE(M) SDN BHD ("CAMDY").

This privacy policy (“Privacy Policy”) sets forth the privacy practices of Camdy with respect to all personal data or other non-personal data provided or made accessible on or through our website at www.camdy.com.my (the “Website”) and/or our mobile application (the “App”) (together the “Services”). In this Privacy Policy, “we”, “us”, “our” and other similar references mean Camdy. By subscribing, accessing or using our Services, you have agreed to both our Terms of Use and this Privacy Policy in full and as may be amended from time to time.

Remember that your use of our Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

Camdy is committed to prevent personal data of individuals being used in an inappropriate manner and to ensure compliance with legal and regulatory requirements for data protection and privacy. Your privacy is our priority. Please read this Privacy Policy carefully as it elaborates and describes how Camdy collects, uses, protects and retains your personal data collected through our Services.

By using our Services and providing your Personal Information to us, you are consenting to this Privacy Policy, and the collection, the use, the access, the transfer, the storage, and the processing of your personal information as describe in this Privacy Policy.

2.0 GENERAL

In compliance with the applicable law of Malaysia, the expression of “personal data” stated herein shall bear the same meaning as defined in the Personal Data Protection Act 2010 (“PDPA”).

Processing in relation to personal data means collecting, recording, holding or storing the personal data or carrying out any operation or set of operations on the personal data.

Sensitive personal data means any personal data consisting information including but not limited to the physical or mental health or condition of a Data Subject, his political opinions, his religious beliefs or other beliefs of a similar nature, the commission or alleged commission by him of any offence or any other personal data.

In consideration of your use of our Services, you represent that you are of legal age to form a binding contract and are not a person barred from receiving Services under the laws of Malaysia or other applicable jurisdiction. You also agree to provide true, accurate, current and complete information about yourself. If you provide any information that is untrue, inaccurate, not current or incomplete or we have reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, we reserve the right to suspend or terminate your account.

3.0 COLLECTION OF INFORMATION

Camdy collects information either (1) directly from you through registration or subscription for our Services; or (2) from your use of our Services.

3.1 Information you provide to us directly

3.1.1 Account information

When you access and move around Camdy, register an Account with Camdy or purchase a Product from Camdy, we may collect your personal data including but not limited to:

• contact information such as your full name, date of birth, identification, supporting documents (such as MyKad/NRIC/Passport, bill statement of utility bills or statements which indicates your full name, address, etc), gender, nationality and race, preferred language, current private and/or business address, fixed line telephone (home and office), fax number, email address
• credit card information and bank account details
• the status of the services you have subscribed from us
• your personal interests and preferences to help us to better improve our Products and Services
• how you use the Products and Services
• the equipment you use when accessing our Websites, Products and/or Services (such as your handphone, your computer system and platform) to customize the service for you

Upon the successful registration of an account, you can visit your personal profile at any time to edit the personal data about yourself.

3.2 Information we collect from your use of our Services

3.2.1 We may collect your personal data from you when you:-

• you register/subscribe as a new user 
• you use our Products and/or Services
• participate in any of our surveys
• participate in any of our marketing campaign and/or promotions
• enter and/or participate in any contests, loyalty programmes, competition run/organized by us
• response to any marketing materials we send out (newsletter, etc)
• visit or browse our websites
• lodge a complaint with us
• provide feedback and/or suggestions to us (via our website or in hard copy)

3.2.2 Access device information

When you access our Services from a computer, mobile device or other device(s), we may collect information from that device in respect of your location, IP address, and information about your visit (such as time stamp, date, duration etc)..

3.2.3 Cookie information

“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. We use cookies to help us track your use of the Services and preferences. If you do not wish to have cookies placed on your computer, you should set your browser to refuse cookies, but should be aware that certain features of our Services may not function properly without them or you may not be able to access all or parts of our Website and/or Services. You should refer to the help sections of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling cookies.

4.0 NOTICE AND CHOICE

Purposes of collection and use of personal data

4.1 We use the information we collect from you to try to provide a safe, efficient, and customized experience. You hereby acknowledge, confirm and consent to us collecting, recording, holding, storing, using, dealing with and otherwise processing such personal data, for any of the following purposes:-

• to verify your identity;
• to assess and process your application(s)/request(s) for our Products and/or Services;
• to provide you with the Products and/or Services you have requested;
• to notify you about benefits and changes to the features of our Products and/or Services;
• Assist you to efficiently access your information after you sign in;
• Remember your personal information such as username and password so you will not have to re-enter the same information during the next log-in;
• To send you seasonal new updates messages and/or message informing you of a critical performance error in our Services;
• To assist Camdy in understanding your browsing preferences so that we can offer you tailored content accordingly;
• To conduct research and development and statistical analysis in connection with the Services to identify trends and develop new services that reflect your interests;
• To investigate and resolve any issues of the Services such as billing and fees queries, support, security, technical issues, complaints, report or other enquiries that you submit to us;
• To maintain and develop the Services;
• To improve your user experience and the overall quality of the Services;
• To detect and prevent fraudulent, unauthorized or illegal activity;
• To create personalised Product selected by you;
• If you elect to store a payment method with us, to associate that payment method with you when you place an order;
• To process payment you make for Products;
• To provide customer support;
• To contact you by email and mobile communication and/or provide you with any information you have requested;
• to administer and give effect to the commercial transaction and the management and/or enforcement thereof;
• to contact and provide you information regarding products, services, new launches, upcoming events, promotions, advertising, marketing and commercial materials (including emails, SMS or other means) and such other information as we feel may be of interest to you;
• to use third party service providers to help us operate our business.

4.2 You are not able to limit the processing of mandatory fields (marked as *) in respect of your personal information when you register for an account with us, in order for us to provide our Services to you. If you do not consent to Camdy processing your personal information for any of the purposes set out in this Privacy Policy, you must terminate your relevant account with Camdy and stop using the Services.

4.3 Where sensitive personal data is provided and disclosed by you to Camdy, by such disclosure, you have consented Camdy to collect and process the data.

5.0 DISCLOSURE OF PERSONAL DATA

Personal data shall not without your consent be disclosed for any purpose other than the purpose for which the personal data was to be disclosed at the time of collection of the personal data or a purpose directly related to it, or be disclosed to a third party, organisations, companies and individuals outside of our Services other than that specified in the “Notice and Choice” section above. To the extent that you disclose to us any personal data of another individual, we shall assume, without independent verification, that you have obtained such individual's consent for the disclosure of such personal data as well as the processing of the same in accordance with the terms of this notification.

As part of providing you with our Products and/or Services, we may be required or need to disclose information about you to the following third parties:-

• law enforcement agencies;
• government agencies;
• companies and/or organization that acts as our agents, service providers and/or professional advisers;
• other parties in respect of whom you have given your express or implied consent;
• customer inquiry and other customer related services;
• data processing services;
• information technology services;
• media and marketing services (including advertising);
• market research and website usage analysis services.

6.0 SECURITY

All information and records containing personal data are considered to be our property and are afforded confidential treatment at all times. Camdy will take appropriate measures to protect the personal data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction when processing personal data. All such electronic information is stored on restricted database servers.

Unfortunately, no data transmission over the internet can be guaranteed as completely secure. So while we strive to protect such personal data, we cannot ensure or warrant the security of any personal data transmitted to us and individuals do so at their own risk.

The Services contain links to other sites. Camdy is not responsible for the privacy practices or the content of such sites.

7.0 DATA RETENTION AND TRANSFER

Camdy retains personal data for as long as necessary for its legitimate business purposes, and as otherwise permitted by applicable law.

Your personal data may from time to time be transferred to, stored, used and processed by us in places other than Malaysia. This is because some of our digital storage facilities and servers may be located in such other places.

In addition to the above, your personal data may also be transferred out of Malaysia to third parties and you hereby consent to the transfer of your personal data out of Malaysia.

8.0 DATA INTEGRITY

Where indicated (for example in registration/application forms), it is obligatory you provide your personal information to us to enable us to process your application for our Products and/or Services. Should you decline to provide such obligatory personal information, we may not be able to process your application/request or provide you with our products or services.

9.0 ACCESS

We can assist you to access and correct your personal information held by us.

If you wish to have access to your personal information in our possession, or where you are of the opinion that such personal information held by us is inaccurate, incomplete, misleading or where relevant, not up-to-date, you may make a request to us by email. You should quote your User ID, full name, email address, mailing/billing address and handphone/ fixed phone number and provide brief details of the information you want a copy of in any such request. We shall charge a processing fee for searching for and providing you with access to your personal information to cover administration costs.
We will use reasonable efforts to comply with your request to access or correct your personal information within 21 days of receiving your request and the relevant processing fee.
Please note that we may have to withhold access to your personal information in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.

10.0 CHANGE OF CONTROL

If we sell or otherwise transfer, either in part or the whole of Camdy and/or our assets to another organization (including but not limited to disposition, merger, acquisition and/or liquidation), your information such as name and email address, Content and any other information collected through the Services may be among the items sold or transferred. You acknowledge and agree Camdy to disclose, release and transfer the personal data to the other party.

11.0 CHANGES TO THE PRIVACY POLICY

We may be required to revise and/or modify this Privacy Statement from time to time and the updated version shall apply and supersede any and all previous versions, including but not limited to, booklets, leaflets or hard copy versions. By continuing to use our Services after such revision and/or modification, you are accepting and consenting to such revision and/or modification. Please check our website for information on our most up-to-date practices.

12.0 LANGUAGE

In the event of any inconsistency between the English version and the Bahasa Malaysia version of this Privacy Policy, the English version shall prevail.

13.0 GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by the laws of Malaysia and you and Camdy agree to submit to the exclusive jurisdiction of the Malaysian courts should conflict arises.

14.0 ENQUIRIES

If you have any questions about this policy or our Website or Services in general, please write in to us here or email us at support@camdy.com.my.

Last Updated: 22.5.2023