PRIVACY NOTICE

Apigate Sdn Bhd (hereinafter, “ Apigate”, “we”, “us”, or “our”) (Company No. 1259684-W) values privacy and are committed to protect all Personal Data (as defined below) kept by us, in accordance with relevant laws (including the Personal Data Protection Act, 2010), this Privacy Notice, ApigateHub and ApigatePro General Terms.   For the avoidance of doubt, unless the context requires otherwise, the words used in this Privacy Notice shall have the same meanings stipulated in the ApigateHub and ApigatePro General Terms.

This Privacy Notice describes our practices regarding the Personal Data we collect through your use of our Boost Connect website ( https://connect.myboost.co ) and all content, products, services and functionality available and the various products and/or services offered on our Boost Connect website (collectively, the “Services”). This Privacy Notice is also issued to all vendors/suppliers/distributors/service providers/partners of Apigate (which includes all its subsidiaries, related and/or associated companies).

This Privacy Notice explains:

• The type of Personal Data we collect and how we collect it;
• How we use your Personal Data;
• The parties that we disclose the Personal Data to; and
• The choices we offer, including how to access and update your Personal Data.

In the event of any conflict between the English and other language versions, the English version shall prevail. By using the Services, you agree to the terms of this Privacy Notice and you have expressly consented to the collection, use and disclosure of your Personal Data in accordance with this Privacy Notice.

What Kind of Personal Data We Collect and How We Collect It

 “ Personal Data ” means any information that relates to you or allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, date of birth, your identification number,  information about your subscription with the Services such as account activities, purchase habits and Services usage trends as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Information”, means, data that is not associated with or linked to your Personal Data including, aggregated information. Anonymous Information does not, by itself, permit the identification of individual persons.

In order to enable us to provide you this Service we may need to and/or may be required to collect, record, hold, use, disclose and store (i.e. “process”) Personal Data and Anonymous Information, including, but not limited to:

 a. Information you provide to us through your relationship with us, for example, information provided by you when subscribing and/or purchasing to the Services provided by Apigate, and when taking part in customer surveys, competitions and promotions. These include:

• Personal Data from you, such as your first and last name, profile picture, photos or avatar, gender, age, ethnicity, marital status, educational level, interests, hobbies, precise location-based information, e-mail and mailing addresses, phone numbers, device ID numbers, and any other information you directly give us through the Services (including, but not limited to messages that you send through the Services).

• Information about the products and services you are subscribing to or purchasing from Apigate.

• Information you disclose through the Boost Connect website.

• Information necessary to complete a transaction for the Services, including your name and billing information, where applicable.

• Information from written communications when you provide us feedback or contact us e.g. your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

b. Information collected by technology when you access Boost Connect website. For example:

• Information from you , including your web browser type, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, user profiles, and/or a date/time stamp for your visit, and, with respect to your mobile phone, the unique device identifier.

• Information from third party service providers , with your consent, which may include your profile content or other types of personally identifiable information.

• Cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Boost Connect website. Persistent Cookies can be removed by following web browser’s directions.

• Information from corresponding technologies used in connection with mobile phones, including the Android ID, to record date, time, search and viewing information related to your mobile phone.

• Information about how you use and interact with our Boost Connect website and the Services via third party analytics services . Such third-party analytics services may use Cookies to gather information such as the pages you visited, your IP address, a date/time stamp for your visit and the sites that redirected you to our Boost Connect website.

c. Information from third parties connected with you or from other permissible or authorized sources which you have given your consent to disclose information relating to you and/or where not otherwise restricted.

How We Use Your Personal Data

a. For general use or collected by technology. Other than as stated above, we may use your Personal Data either to respond to requests that you make, or to aid us in serving you better, whether or not through technological means for one or more of the following purposes:

• to facilitate the creation of and secure your account on our Boost Connect website;

• to identify you as a user in our system;

• to notify visitors about updates to the Services;

• to promote the Services; or products, services and special offers of third parties whose products and services we think may be of interest to you;

• to improve and customize the quality of experience when you interact with the Services;

• to send you a welcome e-mail and to verify ownership of the e-mail address provided by you in Boost Connect website;

• to send you administrative e-mail notifications, such as security or support and maintenance advisories;

• to respond to your inquiries related to employment opportunities or other requests;

• to send offers and promotional materials related to the Services and for other marketing purposes;

• to respond to your inquiries or complaints on our products and/or Services;

• to process your invoice in relation to the Services, sale/supply/distribution of your products and/or services and other purposes required to operate and maintain our business or related to your relationship with us;

• to track user-specific information on what pages’ users access or visit; and

b. Creation of Anonymous Information. We may also anonymise or aggregate your Personal Data by excluding information (such as your name) that make the data personally identifiable to you. This Anonymous Information may be used to personalize the Services, including directing certain Advertisements to make them more relevant to you or to analyse request and usage patterns so that we may enhance the content of the Services for any related market research purposes, either internally or through third parties.

Disclosure of Your Personal Data

Subject to any laws (including regulations, guidelines and/or obligations) applicable to us and our Affiliates (as defined below) (whether in or outside Malaysia), we may disclose your Personal Data as described below and elsewhere in this Privacy Notice:

a. Third Party Service Providers . We may share your Personal Data  with third party service providers who may be located within or outside Malaysia (a) to provide you with the Services that we offer you through our Boost Connect website; (b) to conduct quality assurance testing; (c) to facilitate creation of accounts; (d) to provide technical support; and/or (e) to provide other services to us. These third-party service providers are not required to use your Personal Data other than to provide the Services requested by us.

b. Group of Companies and other relevant Third Party . We may share your Personal Data to our group of companies (including our subsidiaries, related and/or associated companies), our professional advisers, vendors, suppliers, agents, contractors, service providers, business partners, customers, insurance companies, banks, financial institutions, successor in title to us, any governmental agencies, regulatory authorities and/or statutory bodies, parties involved in any corporate exercise (e.g. proposed or actual mergers and/or acquisitions, joint venture, funding exercise, asset sale or for any other matter of such nature which relates to Apigate), within or outside Malaysia,

c. Affiliates and Acquisitions. We may share some or all of your Personal Data with our joint ventures, or other companies under a common control (our “Affiliates”), in which case we will require our Affiliates to honour this Privacy Notice.

d. We Do Not Share Personal Data with Advertisers, however, we do allow advertisers to request that their advertisements are directed at certain users (e.g., users in a certain geographic location, or age, gender and/or with certain interests). In the event that you interact with certain advertisements, the advertisers (or the company which the advertiser works with, for example, its advertising agency or an advertising network) may determine certain characteristics about you.

e. Other Disclosures. Regardless of any choices you make regarding your Personal Data, we may disclose Personal Data if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights or property or users of the Services; and/or (d) to investigate or assist us in preventing any violation or potential violation of the laws, this Privacy Notice, or the Terms of Use.

Third Party Websites

When you click on a link or, in case of smartphone and mobile device, swipe left to connect to any other website or location, you will leave the Boost Connect website and may be redirected to another site and another entity may collect Personal Data or Anonymous Information from you. We have no control over, do not review, and cannot be responsible for, these external websites or their content. This Privacy Notice do not apply to these external websites or their content, or to any collection of data after you click on links or swipe left to connect to these external websites.

Retention and Security of Your Personal Data

We place great importance on ensuring the security of your Personal Data and will regularly review and implement up-to-date technical and organisational security measures to safeguard the confidentiality and security of all your Personal Data. This includes contractual agreements with the relevant third parties, whereby we shall endeavour to procure them to incorporate our standards as a minimum. Your Personal Data will also be retained in compliance with this Privacy Notice and/or the terms and conditions of your agreements for the duration of your relationship with us, for such period as may be necessary to protect our interests as may be deemed necessary, where otherwise required by the law or relevant regulation.

Additionally, it is important to note that system-recorded Personal Data is not editable. When we delete any information, it will be deleted from the active database, but may remain in our archives. To the extent permitted by law, we may also retain your information for fraud prevention or similar purposes required by laws.

Your Rights to Access and Correct Your Personal Data

Choices. We offer you choices regarding the collection, use, and sharing of your Personal Data. It is necessary for us to collect and process your Personal Data. If you do not provide us with your Personal Data, we will not be able to effectively engage you to provide our products and/or services and for you to provide your products and/or to us and/or on our behalf.Nevertheless, should you decline to provide any Personal Data  that is essential to us to enable us to process the same, we may not be able to process your application/request or provide you with the Services.

Changes and limitations to Personal Data . You may have access to or change your Personal Data in our possession. You have the right to request for access to, request for a copy of and request to update or correct, your personal data held by us. You also have the right at any time to request us to limit the processing and use of your personal data (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes), subject to our right to rely on any statutory exemptions and/or exceptions to collect, use and disclose your personal data.

Your written requests or queries should be addressed to ConnectInfo@myboost.co.

Your Consent to Your Personal Data

By providing your personal data to us, you consent to us processing your personal data in accordance with this Privacy Notice, and you confirm that all personal data provided by you is accurate and complete, and that none of it is misleading or out of date. You will promptly update us in the event of any change to your personal data.

To the extent that you have provided (or will provide) personal data about your directors, shareholders, employees, representatives, agents (if you are a corporate entity/an organisation) and/or other individuals, you confirm that you have explained (or will explain) to them that their personal data will be provided to, and processed by, us and you represent and warrant that you have obtained their consent to the processing (including disclosure and transfer) of their personal data in accordance with this Privacy Notice.

Transfer of Personal Data to places outside Malaysia

We may need to transfer Personal Data to a place outside Malaysia to our affiliates or relevant third-parties outside of Malaysia where such transfer is required to deliver the Services. We will take reasonable precautions to ensure that any such affiliates or relevant third-parties are contractually bound not to use your Personal Data for any reason other than to provide the Services.

Please note that your Personal Data may be sent to other countries in order to route your communications that are sent via the Services in the most efficient way. We store customer data on servers located in Malaysia and on the cloud, and we may also store this data on servers and equipment in other countries. By using the Services, you consent to the transfer of your Personal Data outside Malaysia as mentioned above.

Revisions to Privacy Notice

We may review and update this Privacy Notice from time to time to reflect changes in the laws, in our business practices, procedures and structure, and the community’s changing privacy expectations. The latest version of the Privacy Notice will be made available on the Boost Connect website.

Where we consider, at our sole discretion, that the revisions made on the Privacy Notice are substantive, notice of such revisions will be provided on the Boost Connect website or by such other means of communication deemed suitable by us, for example, by sending you an e-mail to the last e-mail address you provided to us. Please note that at all times you are responsible for updating your Personal Data and to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice.

If you do not agree to the changes in our use of your Personal Data, you must notify us immediately. Continued use of our Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Should you have any query in relation to this Privacy Notice or how we handle your Personal Data, kindly contact the below:

Boost Connect Legal Division
Level 32, Axiata Tower, 9 Jalan Stesen Sentral 5,
Kuala Lumpur Sentral,
50470 Kuala Lumpur, Malaysia
Email: ConnectLegal@myboost.co