Privacy Policy
Introduction
1.1 This Privacy Policy applies to this iNtouch™ Website (“Site”), which is managed by Kossan International Sdn Bhd, including its affiliates and associated companies (hereinafter referred to as “KOSSAN Group”, “our”, “us” or “we”). It outlines how we collect, process, use, disclose and/or store your personal data in accordance with the Personal Data Protection Act 2010 and the Personal Data Protection (Amendment) Act 2024 (collectively referred to as “PDPA”), its amendment, subsidiary legislation and any other applicable rules and regulations, guidelines, codes of practice, or related circulars which may be issued from time to time.
1.2 “Personal Data” is defined in the PDPA and means any and all information directly or indirectly relating to you (or any other individual) to the extent that you (or such other individual) are identified or identifiable from that information.
1.3 By accessing or using this Site and/or submitting your Personal Data to us, you are deemed to have:
- Read, understood and accepted the terms of this Privacy Policy;
- Agreed to comply with and be bound by this Privacy Policy;
- Confirmed that all Personal Data provided is accurate, complete, up-to-date and not misleading; and
- Consented to the collection, processing, use, transfer, disclosure, and storage of your Personal Data by the Kossan Group, including third parties processing such data on our behalf, whether located within or outside Malaysia.
1.4 If you do not consent to the processing of your Personal Data as described in this Privacy Policy, please do not use our services or access our platform.
1.5 We reserve the right to amend this Privacy Policy from time to time without prior notice. Any revision to the Privacy Policy shall become effective upon its publication on our Site. If you do not agree with the revised terms, please do not use the Site or submit any Personal Data to us and you may withdraw your consent by notifying us in writing at intouch@kossan.com.my.
- Types and Purpose of Personal Data Collected
2.1 The Personal Data we may collect includes (but is not limited) to the following:
- Full name, National Registration Identity Card numbers (NRIC)/passport numbers, email address and contact details;
- Gender, date of birth, nationality, religion, race, and preferred language;
- Medical information or history, photographs, biometric data, and demographic data;
- Details of parents, legal guardians, family members, or emergency contacts;
- Information from correspondences, feedback, surveys, programmes or activities submitted through the Site; and
- Any other information you may voluntarily provide to us.
2.2 We may collect your Personal Data directly from you through this Site, when you use our products or services, when entering into agreements with us, through correspondences, feedback, surveys, programmes, activities or interactions with us, when you submit your Personal Data to us for any reason, or through third parties such as credit bureaus, credit reference agencies, financial institutions, social networks, fraud prevention agencies, regulatory and government bodies, through service providers or publicly available sources, or other parties lawfully authorized to disclose such data.
2.3 Your Personal Data may be collected, processed, used and/or stored for the following purposes, including but not limited to:
- Verifying your identity and maintaining your account;
- Communicating with you, including responding to enquiries;
- Administering or managing contractual obligations or transactions;
- Facilitating your participation in any of our surveys, programmes or activities;
- Conducting internal research, analytics or development activities;
- Verification of information, internal record keeping, analysis and operation of the site;
- Complying with legal and regulatory requirements; and
- For any other lawful purpose as disclosed at the point of collection.
(All the purposes above are collectively referred to as the “Purposes”.)
- Consent
3.1 By providing your Personal Data to us, you hereby consent and authorise us to the collection, processing, using, disclosing and storing of your Personal Data in accordance with this Privacy Notice, including the disclosure to any third parties such as financial institutions, credit bureaus, credit reference agencies, fraud prevention agencies, regulatory and government bodies, service providers or any other lawful organisations for any of the Purposes or as permitted or required by law.
3.2 If you provide Personal Data relating to another individual, for example but not limited to, your parent or legal guardian, family member, friend, or employee, you confirm that you have obtained their consent and are authorized to:
- Act on their behalf;
- Receive this privacy notice on their behalf; and
- Consent to the processing of their personal data by us.
3.3 We will not disclose your Personal Data to third parties not listed in this Notice without your consent, unless required or permitted by law, or in connection with legal proceedings, fraud prevention, or enforcement of legal rights.
3.4 As the purposes for which we may collect, process, use, disclose, or store your Personal Data depend on the specific circumstances, some purposes may not be expressly stated above. However, we will inform you of any such additional purposes at the time your consent is sought, unless the processing of your Personal Data without consent is allowed under applicable data protection laws.
- Personal Data of Children
We do not knowingly collect or request personal data from individuals under the age of 18 without verifiable parental or guardian consent. If you provide such data, you confirm that you are legally authorized to act on behalf of the minor and to consent to the collection and processing of their personal data in accordance with this Privacy Notice.
- Use of Cookies
We may use cookies and/or similar technologies from time to time to collect information about how you interact with our website. Cookies are small data files stored on your device that help enhance your browsing experience by personalizing content to better suit your preferences. These cookies do not identify you personally, but rather recognize the device you use. You are not required to accept cookies, and you can adjust your browser settings to accept all cookies, alert you when a cookie is being sent, or block cookies altogether. Disabling cookies may impact your use of certain functions or features of our Site.
- Retention of Personal Data
Your Personal Data will be retained only for as long as necessary to fulfil the Purposes or as required to comply with legal, regulatory or internal policy requirements. Data no longer required will be securely destroyed and/or deleted or anonymized.
- Access and Correction of Personal Data
7.1 It is not mandatory for you to provide us with your Personal Data, however, failure to do so may affect our ability to provide you with services or respond to your requests.
7.2 You are responsible for ensuring that the Personal Data provided is accurate, complete and up-to-date. In the event of changes, please notify us at intouch@kossan.com.my.
7.3 You have the right to access to, or correction of, or withdrawal of your consent to our processing of your Personal Data or object to or limit the processing of your Personal Data held by us subject to legal requirements. We may impose a reasonable administrative fee to cover the administrative costs of processing your request to access your personal data. We reserve the right to refuse requests that are unreasonable, frivolous, or would compromise the privacy of others.
7.4 Subject to applicable laws, you may also request that we transmit a copy of your Personal Data that you have provided to us in a structured, commonly used and machine-readable format to another data user, where technically feasible and permissible under the PDPA or other applicable laws. All requests must be submitted in writing to intouch@kossan.com.my We may charge a reasonable administrative fee and require proof of your identity before responding to your request.
- Data Protection
We endeavour, wherever practicable, to implement appropriate administrative, technical, and physical security safeguards to protect your Personal Data against loss, misuse, or from unauthorized access, disclosure, alteration, or modification, in line with applicable laws, industry best practices and PDPA obligations.
- Third-Party Websites and Disclaimer
This Site may contain links to third-party websites or content. This Privacy Notice does not apply to those websites, and we are not responsible for the privacy practices or content of such third parties. We encourage you to review their respective privacy policies. We reserve the right to remove any unauthorised links to this Site that are posted without our prior written consent.
- Marketing and Promotional Materials
If you wish to opt out from receiving any marketing communications and promotional materials from us or any company within the Kossan Group, you may do so by notifying us in writing at intouch@kossan.com.my.
- Exclusion of Liability
You acknowledge and agree that we shall not in any event be liable for any claim, loss, damage (financial and otherwise), injuries, embarrassments or liability howsoever arising whether in contract, tort, negligence, strict liability or any basis (including direct or indirect, special, incidental, consequential or punitive damages or loss of profits or savings) arising from any inaccuracy or loss, deletion or modification of data or for any other reasons whatsoever relating to any information forwarded to us or to such other party or third party, as the case may be, or in relation to any access or use, or the inability to access or use by such other party or third party or reliance on the information contained therein, whether caused by any technical, hardware or software failure of any kind, the interruption, error, omission, delay, viruses or otherwise howsoever. Further, you shall indemnify and keep us indemnified from any loss, damage, expense, injuries, embarrassments or liability that may be suffered by us arising from your provision of false or inaccurate Personal Data.
- Contact Us
If you have any questions or comments or complaints on this Privacy Notice or our privacy practices or how we process your Personal Data, please contact:
Kossan International Sdn Bhd
Email: intouch@kossan.com.my