A. INTRODUCTION & BACKGROUND FACTS THAT YOU SHOULD KNOW
This Personal Data Protection Policy explains the information that LIFE* collects when you use its products, utilities and services via browsing activity to the Website, how that information is used, with whom it may be shared and your privacy choices.
LIFE* provides information, products, utilities and/or services related to telecommunication service via LIFE*’s website at www.getlife.com.my (“Website”) including but not limited to call, short messages service (sms), mobile internet data and other services which would be made available for all LIFE* users from time to time.
In LIFE*, we take your privacy seriously and we will only collect, record, hold, store, use and/or process your personal data or information as outlined below. We appreciate and thank for your precious time in going through our Personal Data Protection Policy (to be referred as “the PDPP”) for a better user engagement with LIFE*.
We strongly believe that data protection is a matter of mutual trust and your privacy is important to us. We shall therefore only process your name and other information which relates to you in the manner set out in the PDPP including but not limited to the existing legislation, sub-regulations, policies and/or regulatory guidelines (whichever is applicable).
We will only collect data or information where it is necessary for us to do so and for you to enjoy a safer data protection experience in using our LIFE*. We will only collect data or information if it is relevant to our dealings or transactions with you. We will only keep your data or information for as long as we are either required to do so by law or as is relevant for the purposes for which it was collected.
We practice compulsory user’s registration inter-alia to ascertain the real and actual identity of every users of LIFE*. As such, in order to use LIFE*, you are unable to choose to remain anonymous and we must be able to identify your personal identity by providing and disclosing your personal data to us during the process of registration with LIFE* including but not limited to procure certain identity verification or factors authentication steps to do so.
We are committed to protecting all personal data or information kept by us and providing you with the highest levels of customer service within our capabilities. We therefore hereby set out a number of personal data protection principles concerning the exercise and/or process of your personal data or information.
For the purpose of this PDPP, the definition of some salient terms including but not limited to the following:
- “Personal Data”
means any personal data or information relating to LIFE*’s mobile based or website registered user that has been provided to LIFE* or made available to LIFE* due to his/her direct user terms and conditions or agreement with LIFE* and/or via any other agreement signed and entered between you and LIFE*, the legal and beneficial owner of the Website which upon the establishment of such contractual relationship, it shall be deemed that LIFE* has been given consent to collect and process the user’s personal data which is in the possession, control and management of the authorised entity governing the operation and management of the premises, e.g. name, identity card or passport number, address, contact number, account number, payment history and/or account activity that relates directly or indirectly to an individual to the extent that the individual can be identified or is identifiable from such information.
- “Sensitive Personal Data”
means and including but not limited to the personal data or information relating to your physical or mental health condition, political opinions, religious beliefs or other beliefs of a similar nature, commission or alleged commission of any offence or any other personal data determined by existing legislation; and
- “3rd Party”
means an individual, incorporated or unincorporated entity who is not a party to a contract or a transaction with LIFE* but excluding LIFE*’s authorised agents, subsidiaries, contractors, sub-contractors and professional advisors or representatives.
By registering for, downloading, or using the Website, you agree to accept this PDPP. LIFE* hereby expressly reserves the right to amend, alter or change any portion of this PDPP. We will announce such amendments, alterations or changes through our dedicated webpage.
B. SCOPE OF THE PERSONAL DATA PROTECTION POLICY
This PDPP applies to all operations and business units of LIFE*. We are responsible for the users’ access and correction of personal data or information, notice and choice process to limit processing of personal data or information. We also responsible for monitoring the administration of this PDPP and its compliance. LIFE* do not knowingly collect information of persons whom are under the age of majority as per the laws governing LIFE*.
This PDPP is effective upon the confirmation and successful registration with LIFE*. For the avoidance of doubt, this PDPP is valid and binding upon every subscribers and users regardless whether you have subscribed the services of LIFE* directly or indirectly.
C. SCOPE OF THE PERSONAL DATA PROTECTION PRINCIPLES IN THE PDPP
8.1. LIFE* will use, process, record, hold, store, share and disclose (“the Process”) the Personal Data with your consent during your course of dealing with us in any manner, among others, for the following purposes:
- to upload, use, share video and/or commence live streaming;
- to purchase or sell permissible products or subscription of services;
- to process and complete transactions with LIFE* and to use and access to LIFE*’s services;
- to process, manage and maintain the all the LIFE* user’s access account and other applications;
- to process any payment or refund due under the access account or to enjoy the online payment features;
- for data processing, updating of any databases and customer service related matters;
- to communicate with the relevant governing entity, including to extend your queries/inquiries, complaints to them and to enable them to generally resolve your concern/disputes; and
- for any other purpose that is incidental or ancillary or in furtherance to the above purposes.
- 8.2. Your continuance of use of LIFE*’s Website or services shall nevertheless amount to your consent for the processing of the Personal Data by LIFE*;
- 8.3. LIFE* will record and maintain a record or register of consent by your continued use of our Website and/or services as appearing on our active customer database; and
- 8.4. If you are under age of majority, you should ensure that you have obtained the consent of your parent(s) or legal guardian(s) before using any services on LIFE* or browsing the Website.
- 8.5. LIFE* does not sell, share or trade your Personal Data collected or processed with any unauthorised third party(ies), unless consented by you;
8.6. When you register a user account with LIFE*, the Personal Data that we may collect and process would include but not limited to your:
- Email address;
- Residential address;
- Date of birth;
- Contact number;
- Identification number;
- Transaction trail or activity data.
- 8.7. LIFE* does not collect and process any data or information regarding to your credit or debit card details including the payment methodology. The payment gateway offered by LIFE* does not belong to LIFE* but authorised third party, vendor, supplier and/or service provider. LIFE* does not retain such data or information instead of the parties mentioned above or your own respective bank or financial institutions;
- 8.8. Despite the above, LIFE* may also collect your Personal Data from a range of sources including but not limited to any events, activities, contests, promotional activities, surveys, social media tools or pages;
8.9. The Personal Data that we collect from you will be used and share within our group of entities and to authorised third party for one or the following purposes:
- to process, manage and/or verify your actual identity;
- to maintain, upgrade and/or improve LIFE* and/or our services to you from time to time;
- to perform and/or validate your access into any Services or features provided by LIFE*;
- to allow us administer, maintain and/or support your registered account with us;
- to verify and carry out financial transactions in relation to payments you may make online via LIFE* such as the process of the financial information or payment made through LIFE* will be processed by the appointed agent, vendor and/or supplier as such disclosure is necessary for the purpose of conducting the sales transaction(s) that you have opted for;
- to communicate with you and to maintain, upgrade and/or improve our customer relationship with you including to provide customer support to you;
- to conduct market surveys and/or research, customer profiling and its analysis, usage and activity trends pertaining to LIFE*;
- to protect and/or enforce parties’ legal rights including but not limited to initiating or defending any legal proceeding;
- to detect, investigate or prevent any fraudulent or illegal activities or misuse of the LIFE* for illegal purpose and/or purposes or intention that violates the legislation or any governmental policies;
- to transfer, assign and/or validate the parties’ rights, interests and/or obligations under any contractual agreement entered between us;
- for LIFE*’s internal administrative work purposes;
in addition to the Personal Data that mentioned or outlined aforesaid, you may be asked to subscribe to our marketing and/or promotional materials including but not limited to activities below which may come from our group of entities or through affiliation with authorised third party(ies), if any. You are at your liberty and choice to unsubscribe from marketing information at any time by opting for the unsubscribe function within the electronic marketing material or available options:
- announcements on products, services, contests, events, activities, promotions, campaigns, offers or surveys by LIFE*;
- to send seasonal or festive greetings or messages to you;
- events or activities organised or jointly organised by us and our business partners which may be of interest to you;
Your data pertaining to the activities in using LIFE* may be stored with us or authorised third party(ies) but may not be retrieved directly by us, depending on the circumstances from time to time. However, you may access and view such information by logging into your account on the website, if such data is made available by us. You undertake and guarantee to treat the Personal Data that can be accessed by you confidentially and not make it available to unauthorised third party(ies). We cannot and would not assume any liability for any misuse of passwords unless this this misuse is through our own fault.
NOTICE AND CHOICE PRINCIPLE
9.1. Please be informed that LIFE* will process your Personal Data for the following reasons and subject to your choice but possible limitation of services, may disclose the Personal Data to:
- individuals, companies, organisations or entities for the performance of LIFE*’s contract of providing any services to you;
- profiling your service preferences;
- individuals, companies, organisations or entities for compliance with any legal and/or regulatory obligations to which LIFE* is subject, in addition to any obligation imposed under LIFE*’s contract with you;
- other service providers or 3rd Parties nominated by LIFE* either solely or jointly with other service providers for the purposes of establishing and maintaining a common database of customers or processing data as an outsourced entity both within and outside Malaysia (if required) towards the common target to serve you better and accomplished your experience in using LIFE*;
- send you information, promotions, updates and newsletters including marketing and advertising materials or related or similar contents in relation to our services and those of organisations selected or nominated by LIFE*;
- regulatory bodies or other government authorities in compliance with requirements or compulsions under any legislation or orders or towards the detection, assistance, investigation or prevention of any criminal activities;
- any parties involved in or related to a legal proceeding in the courts of law in Malaysia and for the purposes of such proceedings;
- protect LIFE*’s vital interests;
- for the administration of justice and/or facilitating the legal or justice system in Malaysia;
- promote any of the LIFE*’s services, or products, services and special offers of 3rd Party whose products and services we think may be of interest or beneficial to you; and
- for the exercise of any functions, responsibilities or obligations conferred on any person by or under any legislation, law and order of courts of law in Malaysia.
9.2. LIFE* collects personal data from the user account registration in order to assess your needs and provide you better service. LIFE* may transfer your personal data to third parties both in Malaysia and overseas providing outsourced data storage or data processing services for LIFE*.
9.3. Any customers who have provided your personal data prior to this PDPP may inform LIFE* using the contact details set out below to know what types of Personal Data have been processed and the purpose of the processing.
9.4. Save in accordance with this PDPP and except as permitted or required under any enactment, law, regulations, statute or code, LIFE* will not use or disclose the Personal Data without prior written consent.
9.5. You will be given the opportunity to ‘opt-out’ of having your Personal Data used for purposes not directly related to the services of LIFE* at the point where we ask for information. If you do not wish to receive our promotional updates you may opt-out of receiving these communications by contacting LIFE* at the methods listed below. Please take note that should you decide to ‘opt-out’, we may not be able to provide you with certain services and your subscription.
- 10.1. LIFE* will only disclose the Personal Data to comply with any government agency notification requirements and/or for the purpose for which the Personal Data is processed where you have consented to disclosure;
- 10.2. LIFE* may from time to time contact you on behalf of external business partners about particular goods, offers or services that may be of interest to you. In those cases, the Personal Data that may identify you will not be transferred to the third party. All communication whether from LIFE* or LIFE*’s business partners will be sent to you by LIFE*;
10.3. Despite the above, LIFE* may still disclose some of your Personal Data to the following third parties for legitimate purposes, such as:
- your immediate family members and/or emergency contact person as may be notified to us or requested by us from time to time, if any;
- any individual or entity that under a duty of maintaining confidentiality to whom has undertaken such duty to keep your Personal Data in confidential engaged by us;
- professional advisers appointed or engaged by us including but not limited to lawyers, auditors, accountants and others;
- data centres or servers situated outside Malaysia to process or store the Personal Data where you hereby expressly consent to us to transfer your Personal Data out of the country(ies) other than Malaysia which might not provide or offer the same or better level of data protection measures;
- insurance company(ies) to apply and obtain insurance policy(ies), if any;
- to the public at large when you become the winner in any contests or activities;
- any other or relevant party pertaining to any proposed or actual corporate restructure activities, merger or acquisitions, sale, consolidation, joint venture, assignment, transfer, funding or realisation of assets, share sale relating to any portion of LIFE*’s business or in the highly unlikely event of insolvency, bankruptcy, winding up or receivership whichever is applicable.
10.4. The failure to provide your Personal Data may lead to the consequences that we are unable to enable the functions, features and operation of the LIFE* to you and you will not be able to enjoy the LIFE*.
- 11.1. LIFE* is responsible for taking prudent steps to safeguard the confidentiality and security of all Personal Data, including appropriate procedural, organisational and technical steps to protect Personal Data from accidental or unlawful destruction or accidental loss, alteration or disclosure. These steps include entering into written agreements with subcontractors who process Personal Data in accordance with LIFE*’s instructions and incorporating LIFE*’s own data protection standards as a minimum;
- 11.2. We will place or procure various reasonable security measures to safeguard all Personal Data that has been collected or processed by us within our reasonable and commercial capacity as the internet / online or cloud-based transmission is not a 100% secured medium of communication;
11.3. LIFE* ensures that all information collected and processed will be safely and securely stored. We protect your Personal Data by:
- allowing access to Personal Data via passwords;
- securely destroying your Personal Data when it is no longer needed for our record retention purposes.
11.4. LIFE* does not accept responsibility or liability for any unauthorised access, loss, unlawful interceptions, hacking activities, installation or download of prohibited or unwanted software including but not limited to spyware, malware or virus which caused the loss of the Personal Data transmitted to or from LIFE* after performance or procurement of such reasonable security procedures that are within the commercial capacity of LIFE*.
LIFE* in executing its responsibilities with respect to the confidentiality of Personal Data, LIFE* will employ a number of safeguards, appropriate to the sensitivity of the information, to protect Personal Data against loss or theft, as well as unauthorised access, disclosure, copying, use or modification. Such safeguards will include physical measures, organisational measures and technological measures, for example locked filing cabinets, restricted access to offices, security clearances and limiting access on a “need to know” basis and use of passwords and encryption. Procedures for implementing these measures will be communicated to all LIFE*’s employees and third parties to ensure compliance with this principle.
DATA INTEGRITY PRINCIPLE
- 13.1. LIFE* strives to maintain complete, current and accurate information about its customers. Any inaccurate information that is brought to LIFE*’s attention will be corrected as quickly as possible after notification. Procedures will be maintained to ensure that any reported inaccuracies are promptly and effectively handled and that customers’ information remains as accurate, current and complete as possible;
- 13.2. You are obliged to provide your Personal Data to LIFE*. Failure to provide a complete and correct information to LIFE* as required in the LIFE*’s Website may result in your registration with LIFE* be declined and the offers and services to be provided in consequential.
- 13.3. We may take reasonable steps to ensure that the information or the Personal Data provided by you is accurate, complete and not misleading and that such Personal Data is kept up-to-date and meanwhile, you are also responsible to do the same.
- 14.1. Any person dealing with LIFE* can have access to his or her Personal Data that LIFE* has in its possession or control and may request that his or her Personal Data be amended for purposes of accuracy and completeness subject to such written request or notification be provided to LIFE*;
- 14.2. Under such circumstances, you may request to access or request for a copy of your Personal Data that held by us or to request to update or rectify the accuracy of your Personal Data which may subject to a minimal administrative fee to cover the costs involved in processing your request to access to your Personal Data;
- 14.3. You may also opt to rectify or update your previous Personal Data that has been registered and/or collected by LIFE* by editing your profile on the “Settings” page on the website or to inform our officer in-charge of personal data protection. However please take note that you may not delete information that has been associated with any past transactions.
SENSITIVE PERSONAL DATA
- 15.1. LIFE* does not collect and process any Sensitive Personal Data in its ordinary course of business;
- 15.2. If need arises, LIFE* will obtain explicit consent from you before it collects and processes any Sensitive Personal Data;
- 15.3. LIFE* may process Sensitive Personal Data without your consent only in limited circumstances as permitted by law, if any.
OUR WEBSITE (TO BE READ WITH OUR TERMS AND CONDITIONS)
- 16.1. Subject to development and circumstances from time to time, LIFE* may provide products, utilities and services via our dedicated website(s). When you visit our website the web servers will generally record anonymous information such as the time, date and URL of the request. This information assists LIFE* to improve the structure of its website(s) and monitor the performance. From time to time LIFE* may also use third parties to analyse this anonymous information;
- 16.2. As mandatory in the usage of the LIFE*’s websites, LIFE* may require standard information such as login ID, password, Personal Data for verification purposes, contact details and/or identification information. This information is necessary for LIFE* to provide the products and services you are subscribing for. You are required to maintain your secrecy of own login ID and password enabling the access to the LIFE*’s website(s) or app. It is strongly stressed that LIFE* will not be able to secure the Personal Data if you choose to reveal your own login ID and password to anyone and as such, is not liable for any breach or leakage of Personal Data.
YOUR IP ADDRESS(ES), COOKIES AND OTHER CAPTURES
- 17.1. LIFE* may collect your Internet Protocol (IP) addresses if you choose to browse or login into your account via LIFE*’s website or app. IP addresses are assigned to computers or mobile devices on the internet to uniquely identify them within the network. LIFE* also collects and manages IP addresses as part of the service of providing internet session management, if any and for security purposes;
- 17.2. LIFE*’s website(s) may transmit to your computer a feature known as ‘cookies’. It is a package of data that allows LIFE*’s server to identify and interact more effectively with your computer instead of having to spend more time on identifying each user and/or visitor, thereby also providing additional login convenience. However, you are at your liberty or choice to configure, personalise the app or web browser to refuse, reject or even delete such cookies;
- 17.3. LIFE* may also collect and/or record the information that your browser sends whenever you visit our website including but not limited to browser type, webpage that you were visiting before you came to our website, the pages that within LIFE* you visit, time spent on these pages, items and information searched for on our website, access times and dates and other statistics which are not specifically mentioned herein;
- 17.4. The computer data and/or information other than Personal Data as mentioned aforesaid may be collected for analysis and evaluation in order to assist to improve the website, services and products we provide and will not be used in association with any other Personal Data.
INTEREST BASED ADVERTISING (IBD)
LIFE* or LIFE*’s Website may collect and process your Personal Data and/or anonymous information about the web browsing activity of a customer internet-enabled device and use that information to associate your browser with one or more pre-defined interest categories. This enables LIFE* to provide advertisements to you that are tailored to your interests. IBA is a way of making the advertisements on the websites you visit more relevant to you. It makes the advertising more relevant to you for your convenience and interest.
We are committed to protect the Personal Data of all customers and/or users. If you have any questions in relation to this PDP Policy and/or wish to withdraw your consent, access or modify the Personal Data that we have collected or processed or complaints pertaining to this PDP Policy, please contact us with the following method and we will respond to such request promptly or within three (3) working days:
19.1 Customer Service Call Centre at 011-33777777
In the event of any inconsistencies, errors, mistakes or discrepancies between the English version and other translated versions of this PDPP whether done by LIFE* or other unknown third party(ies), the English version shall prevail.