PRIVACY POLICY

 

INTRODUCTION

Your privacy is important to us, and we take our responsibility of caring for it seriously. We respect your privacy rights and are committed to protecting the personal information that is collected about you and/or protect the information that you provide to us. This Privacy Policy describes what information we collect and how we use, disclose, transfer, and store it. If you do not want us to collect, store, use or share your information in the ways described in this Privacy Policy, you may not be able to use our services.

We collect, stores, and uses your information as a data controller and/or data processor in connection with, and in order to provide services (“Services”) in accordance with this privacy policy (“Privacy Policy”).

All of our Services, whether used on mobile devices, PCs or other platforms, are governed by this Privacy Policy. By using the Services, you hereby consent to this Privacy Policy.

We reserve the right to change this Privacy Policy at any time. In the event that we make material changes to this Privacy Policy, they will be re-posted in the “Privacy” section of our websites and apps with the date the modifications were made indicated at the top of the page. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to it. Your continued use of the Services after such change(s) constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Services or opt out by sending us appropriate notice. If you would like further information about any recent changes made, please send your request to [*email*] and include “Information about Changes” in the subject line.

 

COLLECTION OF YOUR INFORMATION

We collect some information from you when you: (a) use services, (b) make a purchase within our Services and (c) contact our customer service and take part in technical-support sessions. The information we may collect includes:-

i – Information you provide us

  • Contact information (such as your business name, address, phone no., email address, etc)
  • Distribution List
  • Information that you provide when seeking help from our customer service (such as chat logs and customer-support)
  • Other information you provide us

ii – Information we collect automatically directly from you when you use our Services

  • IP address and device identifiers (such as your device ID, advertising ID)
  • Information about your device (such as device name and operating system, browser information)
  • Information we collect using cookies
  • General geolocation information

iii – Information we obtain from our partners

  • Information that we receive if you decide to connect to a third-party social network
  • Information from telco operators and/or billing partners
  • Information for advertising and analytics purposes, so we can provide you with better Services

 

USE OF YOUR INFORMATION

Your information will enable us to provide you with access to all parts of the Sites and to supply the goods or services you have requested. It will also enable us to bill you and to contact you if necessary, concerning the Services and your ongoing account with us. We will also use and analyse the information we collect so that we can administer, support, improve and develop our business.

We will normally collect personal information from you only:-

  • when we have your consent to do so;
  • when we need the personal information to fulfill a contract with you and provide you with the Services;
  • when the processing is in our legitimate interests (when we serve and measure the effectiveness of advertising or marketing campaigns, protect and improve our products and services) and not overridden by your rights; or
  • when we have a legal obligation to collect personal information from you.

 

RETENTION OF YOUR INFORMATION

We retain, use and store your information as long as you are playing our games or using our Services, and also for the period necessary to fulfill all the purposes described in this Privacy Policy, in compliance with the applicable laws of Malaysia. We want to inform you that a longer retention period could be required to resolve disputes, or answer regulatory or police requests. In such cases, the collected information will be used and stored until the request is closed.

 

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:-

  • By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

  • Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, hosting services, customer service, and marketing assistance.

  • Marketing Communications

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

  • Third-Party Advertisers

We may use third-party advertising companies to serve ads when you use the Services. These companies may use information about your use on the Services and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

  • Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

  • Sale or Liquidation

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter into liquidation, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

 

INTERNATIONAL OPERATIONS AND TRANSFERS OF YOUR INFORMATION

As part of our international operations, we may transfer personal information to our affiliates (which means subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership of [**]) from time to time for our legitimate business purposes.

[**] is headquartered in Malaysia, and we have operations, entities and Services provided in Indonesia, Thailand, Philippines, United States and throughout the world. We have taken measures to ensure that your personal information is treated securely and lawfully, and that it receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the European Economic Area (“EEA”) or Switzerland, we provide adequate protection for the transfer of personal information to countries outside of the EEA or Switzerland based on the standard contractual clauses authorized by the European Commission or other appropriate safeguards defined in Article 46, General Data Protection Regulation (GDPR) (EU) 2016/679.

 

TRACKING TECHNOLOGIES

We may use cookies and other tracking technologies on the Services to help customize the Services and improve your experience. When you use the Services, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Services.

 

THIRD-PARTY WEBSITES

The Services may link to external sites that are beyond our control. This Privacy Policy only covers the way we treat personal information and non-personal information we collect on the Services. By accessing any external sites, you agree to the privacy policies of those sites. Please understand that external sites may have different policies with respect to the collection, use and disclosure of your personal information. We have no control over, and are not responsible for, the privacy practices of such third parties. Therefore, you are encouraged to review the privacy policies of all third parties’ services. Without limiting anything in the following section, we are not liable in any way for the actions, inactions or policies of any external services.

 

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

 

LEGAL DISCLAIMER

Our Services operate “AS IS”, and we do not represent or warrant that our Services will be available at all times, or that your use of the Services will be uninterrupted or error-free. We are not responsible for your ability to access the Services or for matters beyond our control.

 

OPTIONS REGARDING YOUR INFORMATION

We ask that you keep the information that you provide to us updated. You can correct any information you have provided to us by contacting us. You represent and warrant that all information you provide to us is true and correct, and relates to you and not to any other person. You can exercise your rights at any time and ask us for access to, or rectification or erasure of, your information.

Please note that other third parties (our data partners) may be controllers of your information. You can obtain more details and opt out of the sharing of your personal information to third parties for any purpose by contacting us. If you have previously consented to any direct marketing communication from us or subscribed to our newsletters, you can unsubscribe by clicking on a link available in each

communication and newsletter we send you. If you want to decline to permit cookies or other tracking technologies, please read our Cookies Policy on our websites.

Please note that other third parties (our data partners) may be controllers of your information. You can obtain more details and opt out of the sharing of your personal information to third parties for any purpose by contacting us. If you have previously consented to any direct marketing communication from us or subscribed to our newsletters, you can unsubscribe by clicking on a link available in each communication and newsletter we send you. If you want to decline to permit cookies or other tracking technologies, please read our Cookies Policy on our websites.

Please note that the Services and features can be affected by your actions. Some of your information and its processing is mandatory for us to provide the Services. Your actions can oblige us to stop providing the Services:-

  • If you ask for the modification of this mandatory information, we may not be able to continue to link the Services to you.
  • If you request limitations to processing that are mandatory for us, or you object to such processing (in which case, we may not be able to provide you with the Services).
  • If you withdraw your consent or ask for the deletion of your information, we will not use or process your information anymore but we will store it to answer regulatory or police requests. We also reserve the right to retain an archive of such information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information.
Elfo

Headquarter

C-5-1 Megan Avenue 2, 12 Jalan Yap Kwan Seng
Kuala Lumpur 50450, MALAYSIA

Phone & Fax

Tel: +60 3 2781 8468
Fax: +60 3 2162 2729

© 2020 Elfo Sdn. Bhd. All rights reserved.

Eflo