This privacy policy (“Privacy Policy”) shall be applicable to IYUNO (M) SDN BHD (“IYUNO”, “we”, “our”, “us”), which is one of the subsidiary or affiliated companies of IYUNO GROUP INC. This Privacy Policy sets out how we manage and process your personal data and information in accordance with the Personal Data Protection Act 2010 (“PDPA 2010”) and the laws of Malaysia.

Please read this Privacy Policy carefully before using our website (“Website”), PRODUB mobile application (“App”) or the documentation (“Documentation”) and services (“Services”) therein, or before you provide or submit any of your personal data and information to us. This Privacy Policy shall form a part of our End User Licence Agreement (“End User Licence Agreement”) and Terms of Use (“Terms of Use”). By using the Website or providing us with your personal data and information, you agree to the provisions of this Privacy Policy and the privacy practices contemplated herein. If you do not agree with the provisions of this Privacy Policy or the privacy practices herein, or any part hereof, please do not continue using the Website, App, Documentation and Services, and do not provide us with your personal data and information.

This Privacy Policy shall only be applicable to the Website, App, Documentations and Services, and we shall not be responsible for any third-party links or websites.

1. What is Personal Data and Information?
   1. In accordance with the PDPA 2010, “personal data” is defined as any information of commercial transactions, which is either being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose, recorded with the intention that it should wholly or partly be processed by means of such equipment, or recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system.
2. What Kind of Personal Data and Information We Collect?
   1. For the purposes of this Privacy Policy, and in order for us to process your registration on the App or your use of the Website or the App, the personal data that we collect includes the data that you provide to us, whether directly or indirectly, which may include, but not be limited to, the following:
      1. Your name, date of birth, gender, country of residence and contact details;
      2. In the event you are representing a company or legal entity, your company name, company registration number, registered and business address, company designation of the authorised representative, and the contact details of the authorised representative;2.1.2. In the event you are representing a company or legal entity, your company name, company registration number, registered and business address, company designation of the authorised representative, and the contact details of the authorised representative;
      3. Internet Protocol (IP) addresses, the type of the devices which is using the Website or the App;
      4. Images, pictures, videos, audios and voice recordings;
      5. Documentation that is exchanged between users of the Website and the App; and
      6. Any other additional information which we may reasonably require.
      Personal Data and Information of a Minor and/or Relevant Person
   2. In the event you are a person who has yet to attain the age of majority, which is eighteen (18) years of age (“Minor”), you will be required to use the Website and App and to register and create an account on the Website and App under the strict supervision of a parents or legal guardian (“Relevant Person”). In such a case, the Relevant Person will be required to provide us with their personal data and information, which may include, but not be limited to the following:
      1. Their name, date of birth, gender, occupation and contact details;
      2. Their relationship with the Minor;
      3. Internet Protocol (IP) addresses, the type of the devices which is using the Website or the App;
      4. Images, pictures, videos, audios and voice recordings;
      5. Documentation that is exchanged between the Relevant Person and other users of the Website and the App; and
      6. Any other additional information which we may reasonably require.
3. How We Collect Personal Data and Information
   1. Your personal data and information may be collected during situations which may include, but not be limited to, any of the following:
      1. Your registration or creation of an account on the Website and/or the App;
      2. Your use of the Website, App, Documentation and/or the Services;
      3. Your download of the App, Documentation and/or the Services;
      4. Your transactions on the Website or the App, whether or not by way of the Documentation and/or Services, with us or other users of the Website or the App (“Transaction”);
      5. Your communication with us for any reason whatsoever;
      6. Your participation in any of our surveys;
      7. Your request to be registered or subscribed to our products or services;
      8. Your response to any marketing materials that we send out; and
      9. Your provision of your personal data and information for any reason whatsoever.
   2. We may also collect your personal data for other purposes, without your knowledge or consent, where this is required or permitted by law. Refusal
   3. The provision of your personal data and information is on a fully voluntary basis. In the event you refuse to provide us with your personal data and information, you will be unable to use the Website, App, Documentation and/or the Services. In the event you do not agree with the provisions of this Privacy Policy, please do not, or do not continue, to use the Website, App, Documentation and/or the Services.
4. Purposes for Processing Personal Data and Information
   1. Your personal data and information are processed on the Website or in the App in accordance with the PDPA 2010 or with the laws of Malaysia. We may process personal data and information collected in accordance with this Privacy Policy for purposes which may include, but not be limited to, any of the following:
      1. To verify your identity as a customer or user of the Website, App, Documentation and/or Services;
      2. To enable you to use, or participate in the use of, the Website, App, Documentation and/or Services;
      3. To facilitate, assess or process your use, or participation in the use, of the Website, App, Documentation and/or Services;
      4. To facilitate, assess or process any Transaction, which include the Documentation, in which you may enter into with another use of the Website and/or the App, in accordance with paragraph 6.3 and paragraph 6.4 below;
      5. To keep in contact with you and to provide you with any information, whether or not requested by you, during the course of your use, or participation in the use, of the Website, App, Documentation and/or Services;
      6. To identify, detect, investigate and/or prevent any fraudulent activities on the Website and/or the App;
      7. To identify, detect, investigate, resolve and/or prevent any dispute, complaint or claim arising out of or in connection with your use, or participation in the use, of the Website, App, Documentation and/or Services;
      8. To assist in the monitoring, maintenance and improvement of the Website, App, Documentation and/or Services;
      9. To process any request and/or communication which you send us;
      10. To investigate, respond to, or defend against claims made against, or involving, IYUNO;
   2. To comply with the PDPA 2010 and/or any other applicable laws and regulations in Malaysia;
   3. To ensure consistency with the End User Licence Agreement or the Terms of Use;
   4. For any other reasonable purpose related to the aforesaid; or
   5. For any other purpose that is required or permitted by any law, rules and regulations, guidelines and/or regulatory authority.
   6. We may further process and use your personal data and information in the following circumstances:
      1. Where you have provided us with your consent, we may use your personal data and information for the purposes of marketing our products and services and those of our strategic partners and business associates for marketing and communication purposes, such as informing you of our latest activities, special offers and promotions. In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us, including but not limited to your participation in promotions or events and your interactions with us.
      2. We will only collect, use, disclose and process your personal data for the above purposes and purposes for which you have consented. In certain situations, we may use your personal data for legitimate purposes, which are not incompatible with the original purposes for which you have provided the personal data. If we wish to use your personal data for a purpose unrelated or other than to what you have provided your personal data to us for, we will notify you and seek your written consent.
5. Disclosure of Personal Data and Information
   Your personal data and information may be disclosed to the following third parties under circumstances which may include, but not be limited to, any of the following:
   1. Another user of the Website, App, Documentation and/or Services, for the purposes of our facilitation of the Transaction in which you may enter into with such user of the Website, App, Documentation and/or Services, in accordance with paragraph 6.3 and paragraph 6.4 below;
   2. Any governmental bodies or agencies, for the purposes of our compliance with the relevant legal and regulatory obligations;
   3. Any court or governmental authority, as a requirement under any applicable law, legislation, statute, by-laws, rules, regulations and/or court order;
   4. Other appointed companies, organisations or service providers, for the purposes of processing personal data and information on our behalf; or
   5. Other appointed companies, organisations or service providers, for the purposes of maintaining, improving, updating or upgrading the Website, App, Documentation and/or Services.
   When disclosing personal data and information to third parties, we will (where appropriate and permissible) enter into contracts with such third parties to protect personal data and information in a manner that is consistent with all applicable laws for the purposes of ensuring that they only process personal data and information in accordance with our instructions.
6. Transfer of Personal Data and Information
   1. Users' Personal Data referred to in point 3 above will be stored by the Administrator:
      1. We do not transfer, sell, lend or otherwise make your personal data and information available to any third party, save and except to one of our subsidiary or affiliated companies or in accordance with paragraph 6.3 and paragraph 6.4 below. In any event of the transfer, sale, lending or availability of your personal data and information, we will obtain your prior consent for the same and we will take reasonable steps to ensure that your personal data continues to receive the same standard of protection in accordance with the PDPA 2010.
      2. We are committed to safeguarding your personal data and information when it is transferred across jurisdictions. We ensure that your personal data and information receives an adequate level of protection at all times for the purposes of preventing unauthorised access and disclosure, misuse, loss, change and/or destruction of your personal data and information.
      Agreement on the Assignment or Transfer of Rights
      1. In the event you have entered into a Transaction with IYUNO or another user, you will be required to enter into Documentation such as the Preliminary Transfer Agreement and the Assignment of Rights, for the purposes of facilitating, finalising and completing the relevant Transaction.
      2. In the event of a Transaction, your personal data and information will be transferred and/or assigned to the relevant user with whom you have entered into the said Transaction by way of the Documentation as described in paragraph 6.3 above. The rights and obligations contained in such Documentation will be strictly adhered to in view of safeguarding your personal data and information.
7. Security and Retention of Personal Data and Information
   1. Whilst reasonable standards of care and measures are taken to ensure security of your personal data and information, we cannot ensure and guarantee a fully-secured collection, use, processing and/or transmission of your personal data and information. Accordingly, we cannot guarantee or warranty the security of any personal data and information with which you provided us.
   2. We cannot guarantee or warrant that our systems, applications and/or networks are fully immune to unauthorised access, security branches or other vulnerabilities. The transmission of your personal data and information shall be at your own risk.
   Retention of Personal Data and Information
   1. We will store and retain your personal data and information for such period as may be necessary and required to fulfil the purposes for which such personal data and information was collected and for the purposes of fulfilling our corporate, business, reporting, compliance and legal obligations.
   2. The period of retention of your personal data and information is dependent on the nature of the personal data and information, such as the following:
      1. We will keep personal data for at least the duration of the limitation period for bringing claims related to the End User Licence Agreement, Terms of Use, Preliminary Transfer Agreement, Assignment of Rights, or the Transaction concluded with IYUNO or for the period if the personal data may be necessary and/or required to commence or defend legal proceedings;
      2. Personal data collected for use for a limited purpose will generally not be retained for more than one (1) year after completion of the purpose; and
      3. Over the period of storing accounting documents or accounting documents related to a Transaction, resulting from generally applicable regulations, depending on which of these periods will be longer.
   We will cease to retain your personal data, or remove the means by which the data and information can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data and information was collected, and is no longer necessary for the purposes of complying with our corporate, business, reporting, compliance and legal obligations.
   
   After the retention period of the personal data and information, such personal data and information is permanently deleted, destroyed or anonymized (i.e. permanent and irreversible transformation of the personal data and information in such a way that it is not possible to assign information to a specific natural person).
   
   In certain circumstances, we may anonymise your personal data and information, so that it can no longer be associated with you in which case we are entitled to retain and use such data without restriction.
8. Your Rights and Obligations
   Rights
   1. You have several rights in relation to the collection, processing, use and disclosure of your personal data and information, which include the following:
      1. Access: Where we hold your personal data and information, you may request for access to your personal data and information. You will receive a copy of the personal data and information for which you have requested.
      2. Correction: You may request that any incomplete or inaccurate personal data and information, which you submitted and which we hold in our possession, be amended or corrected to reflect the accuracy of such personal data and information.
      3. Objection: You reserve the right to object, at any time, to the processing of your personal data and information.
      4. Withdrawal of Consent: You may withdraw your consent towards our use of your personal data and information.
   2. Subject always to our contractual rights and obligations under relevant laws and regulations, in the event you wish to exercise your rights, you may exercise your rights to limit the use, or the extent of use, of your personal data and information by contacting us at privacy@iyuno.com or +603 7727 1658.
   3. We may be permitted under applicable laws to refuse a request, such as:
      1. We may refuse a request for erasure where the personal data and information is required for in connection with claims; or
      2. We may raise an objection to your request and continue processing your personal data and information based on compelling legitimate grounds for such processing.
   Obligations
   4. 1. You are fully responsible for providing us, at all times, with true, accurate and complete information about yourself and/or any other person with whose personal data that you provide us. In the event you become aware of any untrue, inaccurate or incomplete information with which you have submitted to us, please contact us at privacy@iyuno.com or +603 7727 1658 to amend or correct any such untrue, inaccurate or incomplete information.
      2. You are also fully responsible for adhering, at all times, to this Privacy Policy, the End User Licence Agreement and the Terms of Use.
9. Updates to this Privacy Policy
   1. We reserve the right to amend this Privacy Policy from time to time, and the latest updated version of this Privacy Policy shall apply and supersede any and all previous versions. You are fully responsible for keeping yourself informed and updated on this Privacy Policy by checking the Website and/or App, or by visiting this Privacy Policy regularly.
10. Our Contact Details
    1. Please do not hesitate to contact us should you have queries or concerns relating to the above. Please contact us at any of the following:
       1. Email Address: privacy@iyuno.com
       2. Telephone : +603 7727 1658
       3. Address : IYUNO (M) Sdn Bhd, B-09-3A, Menara Bata PJ Trade Centre, No. 8 Jalan PJU 8/8A, Bandar Damansara Perdana, 47820 Petaling Jaya, Selangor