PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CLICKING OR CHECKING “SIGN UP”, “I AGREE TO ZCITY’S PRIVACY POLICY”, “I AGREE AND CONSENT TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND/OR PROCESSING OF MY PERSONAL DATA FOR THE PURPOSE STATED IN, AND UNDER THE TERMS OF, ZCITY’S PRIVACY POLICY” OR SIMILAR STATEMENTS AVAILABLE AT THE ZCITY REGISTRATION PAGE OR IN THE COURSE OF PROVIDING YOU WITH THE SERVICES OR ACCESS TO THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THE TERMS OF THIS PRIVACY POLICY AND THAT YOU HAVE AGREED AND CONSENTED TO THE COLLECTION, USE, DISCLOSURE, STORAGE, TRANSFER AND/OR PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED AND UNDER THE TERMS HEREIN.
1.0 Introduction
1.1 Welcome to the ZCITY platform run by ZCITY Sdn Bhd and its affiliates and affiliates (individually and collectively 'ZCITY', 'we', 'us' or 'our'). ZCITY takes its responsibilities under applicable privacy laws and regulations ('Privacy Laws') seriously and is committed to respecting the privacy rights and concerns of all Users of our ZCITY website (the 'Site') (we refer to the Site and the services we provide as described in our Site collectively as the 'Services'). This Privacy Policy ('Privacy Policy' or 'Policy') is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. Please read this Privacy Policy carefully.
1.2 'Personal Data' or 'personal data' means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information.
1.3 By using the Services, registering for an account with us, visiting our website, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. 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 WEBSITE. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on our website. We reserve the right to amend this Privacy Policy at any time.
1.4 This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.
1.5 This Policy applies to both users, agents and merchants who use the Services except where expressly stated otherwise.
2.0 Personal data collection
2.1 We will/may collect personal data about you:
(a) when you register and/or use our Services or Site, or open an account with us;
(b) when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
(c) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
(d) when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when you interact with our customer service or agents;
(e) when you use our electronic services, or interact with us via our application or use services on our website. This includes, without limitation, through cookies which we may deploy when you interact with our application or website;
(f) when you grant permissions on your device to share information with our application or Platform;
(g) when you link your ZCITY account with your social media or other external account or use other social media features, in accordance with the provider’s policies.
(h) when you carry out transactions through our Services
(i) when you provide us with feedback or complaints;
(j) when you register for a contest or campaign; or
(k) when you submit your personal data to us for any reason.
The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.
2.2 During the course of your use of the Platform and the provision of the Services, we may collect personal data about you, as follows:
(i) Identity data, such as your name, gender, profile picture, and date of birth;
(ii) Contact data, such as billing address, delivery address, email address and phone numbers;
(iii) Biometric data, such as voice files when you use our voice search function, and facial and other bodily features and voice of yourself and/or another person featured in your video when you upload videos onto the Platform;
(iv) Account data, such as bank account details, bank statements, credit card details and payment details (such account data may also be collected directly by our affiliates and/or third party payment service providers);
(v) Transaction data, such as details about orders and payments, and other details of products and Services related to you;
(vi) Technical data, such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, international mobile equipment identity, device identifier, IMEI, MAC address, cookies (where applicable) and other information and technology on the devices you use to access the Platform;
(vii) Profile data, such as your username and password, orders related to you, your interests, preferences, feedback and survey responses;
(viii) Usage data, such as information on how you use the Platform, products and Services or view any content on the Platform, including the time spent on the Platform, items and data searched for on the Platform, access times and dates, as well as websites you were visiting before you came to the Platform and other similar statistics;
(ix) Location data, such as when you capture and share your location with us in the form of photographs or videos and upload such content to the Platform;
(x) Marketing and communications data, such as your preferences in receiving marketing from us and our third parties, your communication preferences and your chat, email or call history on the Platform or with third party customer service providers; and
(xi) Additional information we may request you to submit for due diligence checks as required for identity verification (such as copies of government issued identification, e.g. passport, ID cards, etc.) or if we believe you are violating our Privacy Policy or our Terms of Use.
2.3 We may collect personal data from you, third parties (including but not limited to agents, vendors, contractors, partners and any others who provide services to us, who collect your personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial providers, credit bureaus, delivery, marketing and other service partners), our affiliates, or such data may be collected automatically when you use the Platform or the Services, as set out in this section. See also section 8 below on the collection of computer data.
2.4 Where we collect personal data from third parties and/or our affiliates, we will only collect your personal data, where permitted by law, for or in connection with the purposes for which those third parties or our affiliates are engaged, for the purposes of our collaboration with the third parties or affiliates, or for the requirement to carry out verification or due diligence checks. During the course of your use of the Platform and our provision of the Services, you agree that you have provided your consent (whether to us, the third party or our affiliates) to the transfer of your personal data from third parties and/or our affiliates to ZCITY for the purposes set out in this Privacy Policy or any other terms.
2.5 You must only submit personal data which is accurate and not misleading and you must keep it up to date and inform us of any changes to the personal data you have provided to us. We shall have the right to request for documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law.
2.6 We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to us or as otherwise provided for under this Privacy Policy. If you choose not to provide your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with certain features or functionality on the Services or access to the Platform.
2.7 If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent, license and permissions from that third party to share and transfer his/her personal data to us, and for us to collect, store, use and disclose that data in accordance with this Privacy Policy.
2.8 If you sign up to be a user on our Platform using your social media account or link your ZCITY account to your social media account or use certain other ZCITY social media features, we may access personal data about you which you have voluntarily provided to your social media provider in accordance with the provider's policies and we will manage your personal data in accordance with this Privacy Policy
3.0 Use and Disclosure of Your Personal Data
3.1 The personal data we collect from you or via third parties may be used for certain purposes, as follows:
| • | To provide customer support for your orders; and |
| • | To verify and carry out payment transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to you and/or Services used by you. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers. |
| • | To facilitate your use of the Services or access to the Platform; |
| • | To administer your account (if any) with us; |
| • | To display your name, username or profile on the Platform (including on any reviews you may post); |
| • | To respond to your queries, feedback, claims or disputes, whether directly or through our third party service providers; |
| • | To display on scoreboards on the Platform in relation to campaigns, new feature or any other activity; |
| • | To assess your application for loan facilities and/or to perform credit risk assessments in relation to application for financing services (where applicable); and |
(ii) Marketing and advertising
| • | To provide you with information we think you may find useful or which you have requested from us (provided you have opted to receive such information); |
| • | To send you marketing or promotional information about our or third-party sellers’ products and services on our Platform from time to time (provided you have opted to receive such information); |
| • | To help us conduct marketing and advertising; and |
| • | To promote the Services and use information that you give to us, such as user-generated content (including video content) that you can choose to upload or broadcast on our Platform and will be accessible on the Internet and may be shared by the public (the latter of which is not within our control), as part of our advertising and marketing campaigns to promote the Platform. |
(iii) Legal and operational purposes
| • | To ascertain your identity in connection with fraud detection purposes; |
| • | To compare information, and verify with third parties in order to ensure that the information is accurate; |
| • | To process any complaints, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Platform; |
| • | To store, host, back up your personal data; |
| • | To prevent or investigate any actual or suspected violations of our Terms of Use, Privacy Policy, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us; |
| • | To perform due diligence checks; |
| • | To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcement requests, in connection with any legal proceedings, or otherwise deemed necessary by us; and |
| • | Where necessary to prevent a threat to life, health or safety. |
(iv) Analytics, research, business and development
| • | To understand your user experience with the Services and the Platform; |
| • | To improve the layout or content of the pages of the Platform and customise them for users; |
| • | To identify visitors on the Platform; |
| • | To conduct surveys, including carrying out research on our users’ demographics and behaviour; |
| • | To improve our current technology (e.g. voice recognition tech, etc) via machine learning or other means; |
| • | To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information; |
| • | To conduct data analysis, testing and research, user movement, monitoring and analysing usage and activity trends; |
| • | To further develop our products and services |
(v) Other
| • | Any other purpose to which your consent has been obtained; and |
| • | To conduct automated decision-making processes in accordance with any of the above purposes. |
Who we disclose your personal data to
4.0 Updating Your Personal Data
4.1 It is important that the personal data you provide to us is accurate and complete for you to continue using the Platform and for us to provide the Services. You are responsible for informing us of changes to your personal data, or in the event you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of date.
4.2 You can update your personal data anytime by accessing your account on the Platform.
4.3 We take steps to share the updates to your personal data with third parties and our affiliates with whom we have shared your personal data if your personal data is still necessary for the above-stated purposes.
5.0 Accessing and Correcting Your Personal Data
5.1 may request information about your personal data which we have collected, or enquire about the ways in which your personal data may have been used, disclosed, stored or processed by us via the personal account information setting on our Platform or by contacting us using the contact details below. You may also request correction of any error or omission in your personal data which we have collected in the same way. In order to facilitate processing of your request, it may be necessary for us to request further information relating to your request. Where permissible under law, we may refuse such correction requests if deemed vexatious or unreasonable.
5.2 Where permitted by applicable data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, we will inform you of the fee before processing your request.
6.0 Security of Your Personal Data
6.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
(a) Restricting access to personal data to individuals who require access;
(b) technology products to prevent unauthorised computer access
(c) implementing other security measures as required by applicable law
7.0 Retention of Personal Data
7.1 We will only retain your personal data for as long as we are either required or permitted to by law or as relevant for the purposes for which it was collected.
7.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected, and is no longer necessary for any legal or business purpose.
8.0 Collection of Computer Data
8.1 We or our authorised service providers may use cookies, web beacons, and other similar technologies in connection with your use of the Services or access of the Platform.
8.2 When you visit the Platform through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website, such as the technical data and usage data outlined in Section 2.2 above.
8.3 This data is collected for analysis and evaluation in order to help us improve our website and the services and products we provide, as well as to help us to personalise the content to match your preferred interests more quickly. The data is also collected to make the Services and the Platform more convenient and useful to you, and to provide more relevant advertising related to market products, services and features to you.
8.4 Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognise a particular device or browser. Web beacons are small graphic images that may be included on our Services and the Platform. They allow us to count users who have viewed these pages so that we can better understand your preference and interests.
8.5 You may be able to manage and delete cookies through your browser or device settings. However, certain cookies are required to enable core functionality, so please note that changing and deleting cookies may affect the functionality available on the Platform or through our Services.
9.0 Third Party Sites
9.1 The Platform may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.
10.0 Internet and Mobile Application Use
10.1 You acknowledge that the provision of your personal data to us over the Internet is entirely at your own risk.
10.2 You further acknowledge that if you post your rating and/or review on the Platform, your rating and/or review will become a public information and will be retained by us even after your account has been terminated. Your email address and phone number will not be visible to others through any rating and/or review that you post.
10.3 If any part of the Platform links you to other websites, those websites do not operate under this Privacy Policy and we do not accept any responsibility or liability arising from those websites.
10.4 We suggest you to read and understand those websites’ privacy policy before you provide your personal data to those websites.
10.5 We use cookies (an alphanumeric identifier that we transfer to your computer’s or mobile device’s hard drive so that we can recognise your web browser or mobile device, track your visits to the Platform or remember your username and/or password each time log-in) to monitor your use of the Platform. All such demographic data collected through cookies are not personal data and we may use this data in aggregated, statistical and/or anonymised form. You may disable cookies by changing the settings on your web browser or mobile device, although this may mean that certain features on the Platform will not function properly if you set your web browser or mobile device to not accept cookies.
10.6 In addition to using cookies and related technologies as described above, we may also permit certain third party companies to help us tailor advertising that we think may be of interest to users and use other data about user activities on our Platform and/or Service (e.g., to allow them to tailor ads on third party services). These companies may deliver ads that might also place cookies and otherwise track user behavior.
10.7 Please note that when you first install our mobile application on your mobile device, we will set up an account associated with that mobile device (“Account”). We will collect and use your personal data, in accordance with this Privacy Policy, whenever you activate our mobile application on that mobile device. This use includes linking your personal data with your Account. Most mobile platforms (iOS, Android, etc) have different permission systems for obtaining your consent. The iOS platform will alert you the first time our mobile application wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that our mobile application seeks before you first use the mobile application, and your use constitutes your consent.
10.8 The Platform may integrate with social sharing features and other related tools which allow you to share information with your friends or the public, depending on the settings you establish with the social sharing network. The social sharing network’s use of your personal data made available by ZCITY is governed by that social sharing network’s privacy policy, not by this Privacy Policy. By connecting your social sharing network account through the Platform, you agree that we may collect your personal data from your social sharing network account only in accordance with your privacy settings you have set up under your social sharing network account and for the Purposes provided under this Privacy Policy.
10.9 We may automatically receive, record and store location services information from your computer or mobile device when you interact with us. You hereby consent to our use of anonymised location services information collected from you. Where the location services information is personally identifiable, we will give you the options to manage your disclosure of this information. Depending on the functionalities available on your computer or mobile device, you may benefit from advanced options to manage the location services information. A computer or mobile device may report its GPS location at the time you interact with us if the location services settings are enabled. Such information is not identified as personal data, except where we are required to do otherwise under applicable law.
10.10 Our collection of your computer or mobile device location information is solely at your discretion. You can enable or disable location services when you use the Platform at any time, through your computer or mobile device settings. Should you use the Platform with location services enabled, you consent to our collection and dissemination of your computer or mobile device location information through the Platform, as specified in this Privacy Policy. Under no circumstances shall we be liable for claims or for any damages therefrom, arising out of your informed decision to allow other users to see your computer or mobile device location information, as specified in this Privacy Policy.
11.0 Umeng + Ushare SDK
In order to provide you with a one-click sharing service, our product integrates Umeng + Ushare SDK. Umeng + SDK needs to collect your device Mac address, unique device identification code (IMEI/ Android ID/IDFA/OPENUDID/GUID, SIM Card IMSI information), and the social account public information you need to share in order to complete the one-click sharing service. Calibrate report data accuracy by geographic location to provide basic anti-cheating services. For your information security, we have entered into data security and confidentiality agreements with third-party SDK service providers, and these companies will strictly abide by our data privacy and security requirements. Unless we have your consent, we will not share your personally identifiable information with them.
The statistical analysis SDK (Umeng SDK) collects device identifiers (IMEI/Mac/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information), which is used to uniquely identify the device, which is the prerequisite for statistical analysis of data. Collect geographic location to correct the geographical distribution of report data and provide anti-cheating services.
The message push SDK (Umeng SDK) collects the device identifiers (IMEI/Mac/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information), which is used to uniquely identify the device to push messages to the target device. Collect geographic locations to identify push channels and improve the coverage of message push areas.
The social sharing SDK (Umeng + Ushare SDK) collects device identifiers (IMEI/Mac/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information), which is used to uniquely identify the device to share messages with the target device. Collect geographic locations to identify sharing channels and provide anti-cheating services.
12.0 Questions, Feedback, Concerns, Suggestions or Complaints
12.1 If you have any questions on personal data protection or data privacy, please refer to our list of frequently asked questions on data protection / privacy.
12.2 If your queries are not covered in our FAQs, or if you have any queries or complaints about this Privacy Policy or how we handle your personal data, please feel free to contact us via our online chat service or as follows:
Tel: +6 017-715 8336
13.0 User Data Deletion Policy
Data Deletion: It is your right to completely delete any data we have collected on you. Please send an email to our email [[email protected]] to request deletion of your data.
13.1 Purpose
• ZCITY is just a mobile app and we do not save your personal data in our server. But to be compliant with General Data Protection Regulation (GDPR) and according to the Facebook Platform rules, applications that access user data must do one of the following:
i. Implement a Data Deletion Request Callback.
ii. Provide a URL with explicit instructions for app users on how to delete their data by way of a third-party website or tool. The third-party website may be the relevant section in the application's Privacy Policy.
13.2 Instruction of User Data Deletion
• If users want to delete their activities for ZCITY app, you may remove your activities by the following instructions.
1. Go to Your Facebook Account’s Setting & Privacy. Click 'Setting'.
2. Go to 'Security' section, click 'Apps and Websites' and you will see all of your app activities.
3. Select the option box of ZCITY.
4. Click 'Remove' button.
5. Congratulation, you have successfully removed your activities!
Updated 1-Aug-2023
