Privacy Policy

At ELFO, we are committed to maintaining strong and meaningful privacy protections for customers. Our privacy policy is designed to inform you about the information we collect, how we use it, and your options about certain uses of information. This Privacy Statement sets out how Elfo Sdn. Bhd. and its holding, related and subsidiary companies, including but not limited to, Elfo Sdn. Bhd. (collectively referred to as "Elfo Group", "us" or "we") collect, store and handle personal information (as defined below) of individuals in accordance with the Personal Data Protection Act 2010 ("PDPA") and the laws of Malaysia. Please read this Privacy Statement to understand how we use the personal information we may collect from you. By providing your Personal Information to us, you are consenting to this Privacy Statement and the collection, use, access, transfer, storage and processing of your personal information as described in this Privacy Statement.

Definition

Personal Information
Personal information is information that identifies a specific person. It includes name, address, telephone number, email address, payment card number, and government-issued identification number. For the purposes of this Privacy Statement, personal information encompasses sensitive personal information which relates to information relating to your health, political opinions, religious beliefs, etc. For the avoidance of doubt, please note that this Privacy Statement is applicable only if you are a natural person/an individual.

Non-Personally Identifiable Information
Non-personally identifiable information is every kind of information except for personal information. Under this Privacy Policy non-personally identifiable information includes without limitation cookie IDs, device identifiers, hashed values (such as email addresses and other types of information that are transformed into a sequence of random-looking characters that are no longer recognizable as an email address), and IP addresses.

Introduction

This Privacy Statement explains:
• What kind of personal information we collect
• How we collect your personal information
• How we use your personal information
• When we disclose your personal information
• When we transfer your personal information abroad
• Your right to access and correct your personal information

Effectivity Date
This notice is effective as of August 28, 2017.

Collection of Personal Information

In order for us to provide you with our Products and/or Services and to operate in an efficient and effective manner by providing you with the best service possible, we need to collect relevant personal information from you. The personal information collected by us may include (but is not limited to) the following:
• contact information such as your name, date of birth, identification supporting documents (including NRIC or passport number), gender, nationality and race, preferred language, current private and/or business address, installation address, telephone or mobile phone number, fax number, email address
• your credit card information and bank account details
• your mobile phone location (for location based software)
• the status of the Products and/or Services you have acquired from us or subscribed to
• how you use the Products and/or Service (for example traffic data such as numbers and addresses of calls, SMS, MMS, emails and other communications made and received by you and the date, duration, time and cost of such communications)
• the amount of data that has been received and/or sent by you
• the equipment you use when accessing our Products and/or Services (such as your mobile handset, your computer system and platform) to customize the service for you
• >your personal interests and preferences to help us tailor offerings of our Products and/or Services which would suit you best
• clickstream data when you visit any of our websites (for example the pages you access and the Services and/or Products you browsed)
• recording of your image via CCTV cameras when you visit our branches
• recording of calls placed by you to our help desk for our service enhancement and improvement

Means of Collecting Personal Information

We may collect personal information directly from you when you:
• communicate with us (for example when you submit an application form to become our customer, or when you contact us for any enquiries including by calling our customer service)
• register or subscribe for a specific Product and/or Service or our publications (for example, newsletters)
• use our network and other Products and/or Services of Elfo Group
• participate in any of our surveys
• enter into or participate in any competitions, contests or loyalty programs run/organized by us
• register interest and/or request for information of (through our online portals or other available channels) or subscribe to our Products and/or Services
• respond to any marketing materials we send out
• commence a business relationship with us (for example, as a service provider/business partner)
• visit any of our offices
• visit or browse our websites
• lodge a complaint with us
• provide feedback to us (for example via our websites or in hard copy)
• Other than personal information obtained from you directly (as detailed above), we may also obtain your personal information from third parties we deal with or are connected with you (credit reference agencies or financial institutions), and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted.

Use of Personal Information
We may collect and use personal information from you or from the category of third parties identified in this Privacy Statement, for one or more of the following purposes:
• to verify your identity
• to assess and process your application(s) /request(s) for our Products and/or Services
• to provide you with the Products and/or Services you have requested
• to administer and manage the Products and/or Services we provide you (including charging, billing, facilitating payments and collecting debts)
• to investigate and resolve any service issues, billing queries, complaints or other enquiries that you submit to us regarding our network, Products and Services with our customer relations teams
• to assess and/or verify credit worthiness
• to detect and prevent fraudulent activity
• to manage our networks
• to keep in contact with you and provide you with any information you have requested
• to engage in business transactions in respect of Products and/or Services to be offered and provided to you
• to establish and better manage any business relationship we may have with you
• to process any communications you send us (for example, answering any queries and dealing with any complaints and feedbacks)
• to help us monitor and improve the performance of our network, Products and Services, our customer relations teams and service providers and the Elfo Group Websites and to make these more efficient
• to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems
• to manage staff training and quality assurance
• to notify you about benefits and changes to the features of our Products and/or Services
• to determine how can we improve services to you
• to produce data, reports and statistics which shall be anonymised or aggregated in a manner that does not identify you as an individual
• to investigate, respond to, or defend claims made against, or involving the Elfo Group
• to conduct marketing activities (for example, market research)
• to maintain records required for security, claims or other legal purposes
• to comply with legal and regulatory requirements
• for any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities

Disclosure of Your Personal Information

As a part of providing you with our Products and/or Services and the management and/or operation of the same, we may be required or need to disclose information about you to the following third parties:
• law enforcement agencies
• government agencies
• companies and/or organizations that act as our agents, contractors, service providers and/or professional advisers
• companies and/or organizations that assist us in processing and/or otherwise fulfilling transactions and providing you with Products and/or Services that you have requested or subscribed for
• our business associates and other parties for purposes that are related to the purpose of collecting and using your personal information
• other parties in respect of whom you have given your express or implied consent
• subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to the Elfo Group.

We may disclose information that individually identifies our customers or identifies customer devices in certain circumstances, such as:
• to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law; in cases involving danger of death or serious physical injury to any person or other emergencies;
• to protect our rights or property, or the safety of our customers or employees;
• to protect against fraudulent, malicious, abusive, unauthorized or unlawful use of or subscription to our products and services and to protect our network, services, devices and users from such use;
• to advance or defend against complaints or legal claims in court, administrative proceedings and elsewhere;
• to credit bureaus or collection agencies to determine credit risk, for reporting purposes or to obtain payment for Elfo-billed products and services;
• to a third-party that you have authorized to verify your account information;
• to outside auditors and regulators; or
• with your consent.

Direct Marketing
We may use your personal information to provide you with information about our and third party services and/or products, which may be of interest to or benefit you, except where otherwise requested or notified by you. In certain instances, we may disclose your personal information to our preferred merchants and strategic partners. However, please note that we will only disclose your personal information to our merchants and strategic partners where you have subscribed for particular Services or Products which require such disclosure, and/or where your consent has been obtained, subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to Elfo Group. We take reasonable steps to ensure that our agreements with our merchants and/or strategic partners include appropriate privacy and confidentiality obligations. If you do not wish your personal information to be utilized for the purposes of marketing or should you change your mind in relation to your previous decision, please contact us at the Elfo Privacy Centre via the contact details provided below. Your latest written instructions to us will prevail.

Online Dealings with Elfo Group
Cookies – We collect information about your use of our websites from cookies. Cookies are packets of information stored in your computer which assist your website navigation by customizing site information tailored to your needs. Cookies in themselves do not identify the individual user, just the computer used. You are not obliged to accept cookies. If you are concerned, you can set your computer either to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time. However, rejection of cookies may affect your use of our websites as we will be unable to personalize aspects of your use of the website. Links to Third Party Websites Please be informed that this Privacy Statement applies solely to Elfo Group Websites and does not apply to any third party websites you may access from our websites. To determine how they deal with your Personal Information, you should ensure that you read their respective privacy policies. You have choices about whether certain information collected on websites, including Elfo's, is used to customize advertising based on predictions generated from your visits over time and across different websites and apps. Please note that many opt outs use browser cookies or device controls and are specific to the device and browser you are using. If you buy a new computer, change web browsers or devices or delete the cookies on your computer, you may need to opt out again. In addition, ads you receive may still be tailored using other techniques such as publisher, device or browser-enabled targeting. You should check the privacy policies of the products, sites, apps and services you use to learn more about any such techniques and your options. You also can limit the collection of certain website information by deleting or disabling cookies. Most computers' Internet browsers enable you to erase stored cookies, block all cookies, or receive a warning before a cookie is stored. Disabling cookies may prevent you from using specific features on our sites and other websites, such as ordering products or services and maintaining an online account.

Transfer of your Personal Information outside Malaysia
It may be necessary for us to transfer your personal information outside Malaysia if any of our service providers or strategic partners (“overseas entities”) who are involved in providing part of an Elfo Group Products and/or Services are located in countries outside Malaysia or if you use the Products and/or Services from a country other than Malaysia. You consent to us transferring your personal information outside Malaysia in these instances. We shall take reasonable steps to ensure that any such overseas entities are contractually bound not to use your personal information for any reason other than to provide the Products and/or Services they are contracted by us to provide and to adequately safeguard your personal information.

Updates to our Privacy Statement
We may amend this Privacy Statement from time to time and the updated version shall apply and supersede any and all previous versions, including but not limited to, leaflets or hard copy versions. Please check our website for information on our most up-to-date practices.

Contact Us
If you have questions, concerns or suggestions related to our Privacy Policy or our privacy practices, e-mail us or contact us at:
Elfo Sdn. Bhd.
C-5-1 Megan Avenue 2
12 Jalan Yap Kwan Seng
Kuala Lumpur 50450
MALAYSIA
Fax: +60 3 2162 2729

TERMS AND CONDITIONS

Your use of this website and all material contained within it is regulated by this notice. Please read it carefully. Access to and use of the Elfo Sdn. Bhd. ‘ELFO’ website is subject to the following terms.

ELFO is not responsible for any errors or omissions contained in this website and reserves the right to make changes without notice. ELFO believes all information given to be reliable but the accuracy is not warranted or guaranteed. ELFO IS NOT LIABLE IN ANY EVENT FOR ANY DAMAGES WHATEVER ARISING OUT OF OR RELATED TO THIS WEBSITE OR THE INFORMATION CONTAINED IN IT.

You may not distribute, modify, transmit, reuse, re-post, or use the content of this website for public or commercial purposes without ELFO's written permission. You may download materials displayed on this website for non-commercial or personal use only, provided you do not remove or modify any copyright and other proprietary notices contained in these materials. Nothing contained in this website should be construed as granting a license or right to use any of ELFO's intellectual property rights displayed in this website without the written permission of ELFO.

ELFO refers to Elfo Sdn. Bhd. and its subsidiaries including without limitation Forest Interactive Sdn. Bhd.

The information given on this website is not intended to create any relationship, whether in contract or otherwise, with you. Nothing on this website is intended to be or should be taken as being advice or a recommendation and you should not rely on the information in the website for any purpose.

This website may contain materials in which third parties have proprietary rights, including without limitation logos or brand names which are the trademarks of third parties. ELFO grants no license regarding their use and disclaims any liability with regard to infringement of such third parties rights.

At various points throughout the website you may be offered automatic links to other internet sites relevant to a particular aspect of this website. This does not indicate that ELFO or affiliates are necessarily associated with any of these other sites or their owners. While it is the intention of ELFO that you should find these other sites of interest, neither ELFO, nor affiliates, nor any of its affiliates, officers, employees and agents have any responsibility or liability of any nature whatever for these other sites or any information contained in them, none of which have been verified or endorsed by ELFO or its affiliates. If at any time you find that you have accessed another site you may return to this site by clicking on the "backwards" arrow, or by keying in the domain address of ELFO (https://elfo.com).