1. Purpose of Policy
2. Information we may collect from you
2.1 We may collect and process the following data about you:
2.1.1 Information that you provide by filling in forms on the Site. This includes information provided at the time of registering to use the Site, subscribing to our service, posting material or requesting further services, such as your full name and contact information and goods and services purchased. We may also ask you for information when you enter a competition or promotion sponsored by us or when you report a problem with the Site.
2.1.2 If you contact us, we may keep a record of that correspondence.
2.1.3 We may also ask you to complete surveys that we use for research purposes, although you are not required to do so.
2.1.4 We may also keep your reviews, feedback and opinions about our products and services as well as other data you choose to provide us.
2.2 Details of your visits to the Site, including but not limited to:
• Log Information: we may collect system log information about your use of the Site, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Site.
• Device Information: we may collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers (such as, IP address, IMEI number, the address of the device’s wireless network interface, or mobile phone number used by the device) and mobile network information.
• Location Information: we may collect information about the location of your device each time you access or use one of our mobile applications or otherwise consent to the collection of this information. You can turn off location services for a device at any time, but this may turn off some useful features.
3. Where we store your personal data
3.1 The term “Personal Data” in line with the PDPA and the GDPR is defined as including any information relating to an identified or identifiable natural person. An identifiable person is someone who can be identified, directly or indirectly, in particular by reference to an identification number, location data, online identifiers that refer to the person’s physical, physiological, mental, economic, cultural or social identity of the person. Further to the generality of the terms as defined by the PDPA, Personal Data as referred to in this Policy may relate to any natural persons, including BOH Plantations representatives, employees, customers, clients, investors, suppliers, sponsors, contractors or other individuals not specifically mentioned.
3.2The data that we collect from you may be transferred to, and stored at, a location in Malaysia (server location) or another location inside or outside the European Economic Area (EEA).
3.3 All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share any passwords with anyone.
3.4 Sensitive Personal Data is any personal data consisting of information on your physical (racial or ethnic origin) genetic data or biometric data or mental health or condition, political opinions, religious beliefs or other beliefs of a similar nature, the commission or alleged commission of an offence or any such other information prescribed by the PDPA as Sensitive Personal Data.
3.5 It is our express Policy not to collect and process Sensitive Personal Data unless required by any applicable or relevant laws in carrying out specific obligations. You are advised NOT to submit any kind of sensitive personal data if you do not want the BOH to collect or process such data.
3.6 In the event that you have submitted Sensitive Personal Data to us, it will be deemed to have been submitted on your own volition and with your explicit consent. BOH shall treat all Sensitive Personal Data as confidential and such data shall be subject to the terms and conditions of the Policy.
3.7 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
4. Uses made of the information
4.1 We use information held about you in the following ways:
4.1.1 To ensure that content from the Site is presented in the most effective manner for you and for your computer or mobile device.
4.1.2 To provide you with information, products or services that you request from us or that we feel may interest you, where you have consented to be contacted for such purposes.
4.1.3 To carry out our obligations arising from any contracts entered into between you and us.
4.1.4 To allow you to participate in interactive features of our service, when you choose to do so.
4.1.5 To notify you about changes to our service.
4.1.6 To create and manage your personal account at BOH Plantations.
4.1.7 To notify the winners in competitions arranged online.
4.1.8 To test and improve our systems by which the services are provided.
4.1.9 To prevent misuse or improper use of our services.
4.1.10 To meet legal and regulatory requirements and administer general record keeping.
4.1.11 To send you surveys regarding your satisfaction with our services (performed by BOH Plantations or by third parties on our behalf), products and overall experience in connection with BOH Plantations.
4.2 If you are an existing customer, we will only contact you by electronic means (e.g., e-mail, SMS, APP) or by mail with information about goods and services similar to those that were the subject of a previous sale to you.
4.3 If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means or by mail only if you have consented to this.
4.4 If you do not want us to use your data in this way or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the order form) or contact us via [email protected]
4.5 We may share non-personal, non-individual statistics or demographic information in aggregate form with our marketing partners, advertisers or other third-parties for research purposes.
4.6 Direct Marketing
4.6.1 From time to time, we would like to use your name, email address, mobile phone number, and other relevant contact information to send you either via emails, SMS messages, telephone calls, push notifications, post, or social media (e.g. Facebook) information that we think may be of interest to you, including about our products and services, satisfaction surveys, events, offers and promotions, but we can only do so with your consent.
4.6.2 You may opt-out from receiving marketing communications at any time, free of charge, by following the unsubscribe instructions contained in the marketing communications or contacting BOH Plantations in accordance with the section “Your Rights” below. If you opt out of these communications, we may still send you non-promotional communications, unless we are prohibited from doing so by applicable laws.
5. Disclosure of your information
5.1 We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who may be inside or outside of Malaysia or the EEA.
5.2 We may disclose your personal information to third parties:
5.2.1 Who help us to administer the Site (such as our Internet service providers) or to provide the services you are requesting. These third parties must at all times provide the same levels of security for your personal information as BOH Plantations.
5.2.2 With our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations
5.2.3 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
5.2.5 If BOH Plantations or substantially all of its assets or any member of our group are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
5.2.7 With any law enforcement, courts, Government or regulatory bodies (in whatever jurisdiction), or otherwise in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, court order or legal process.
5.2.8 We may also share your personal data if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of BOH Plantations, our affiliates or others.
5.3 Personal Data Breach
5.3.1 In the event of a personal data breach, BOH Plantations shall without undue delay, where feasible not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent unless the personal data breach is unlikely to affect the rights and freedom of the natural persons.
5.4 Retention of Personal Data
6. Children and Minor
6.1 Except where required by local laws, we do not knowingly collect personal data from minors. If you are a minor, you may only use our Site and services with the permission of your parent or guardian.
6.2 If you are in the EU, our online services are not directed at children under the age of 13. If you believe we have collected information about a child under the age of 13, please contact us so that we may take appropriate steps to delete such information. If you are at least 13 but under the age of 16, please get the consent of your parent or legal guardian before giving us any personal data about yourself.
7. Your rights
7.1 You may at all times revoke any consent given to processing your data, taking effect as from the date of revocation, by sending us an email or postal mail, or by clicking the corresponding box on the forms used to collect your data. You may at all times request information as to what data from you is being processed and for what purpose. Furthermore, you may in accordance with the law request the correction, blocking or deletion of your data. To assert your rights and for any questions you might have, please write to us at Boh Plantations Sdn Bhd, P.O. Box 10245, 50708 Kuala Lumpur Malaysia, or via [email protected]
7.2 You have the right not to consent to our use of certain cookies. Please see the section below on cookies for more information on this.
7.3 The Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
8. Cookies Policy
8.1 What is a Cookie?
8.2.1 We never use or install spyware on your computer, nor do we use spyware to retrieve information from your computer.
8.2.2 Like many Sites, we use “cookies”, which are files saved on your computer’s hard drive by your browser and used to collect and store certain information about you.
8.2.3 Most browsers accept cookies automatically but allow you to disable them. The help menu on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies all together. You can also disable or delete cookies you have previously accepted if you wish to.
8.2.4 We recommend that you leave cookies “turned on” so that we can offer you a better experience on the Site. If you set your browser to block all cookies (including strictly necessary cookies), you may not be able to access parts of the Site.
8.2.5 We have set certain cookies on your device and recommend that you agree to their use. If you do not, you may still use the Site, but certain parts of it may not work or may not work as well.
8.3 We use the following cookies:
8.3.1 Strictly necessary cookies. These are cookies that are required for the operation of the Site and for you to be able to complete services you ask for. They include, for example, cookies that enable you to log into secure areas of the Site.
8.3.2 Functional cookies. These cookies record information about choices you make on the Website, such as your user name, language or the region you are in. In this way, we are able to personalize your visit to the Site.
8.3.3 Performance cookies. These “analytical” cookies allow us to collect information about how visitors use the Site, for example to count visitors and to see how visitors move around the Website. They record your visit to the Site, the pages you have visited and the links you have followed. These cookies do not collect information that identifies you. All information is anonymous. This helps us to improve the way the Site works.
8.3.3(ii) For visitors accessing our Site from Mainland China (PRC), we may use the Site Monitor service provided by Miaozhen Ltd., Beijing, PRC, instead of Google Analytics, for the same purposes and within the same limitations, but with servers in the PRC. For opting-out the use of Site Monitor on your browser, please visit http://i.miaozhen.com/cookie_opt.html.
8.3.4 Social media cookies. These cookies allow you to share Site content with social media platforms (e.g, Facebook, Twitter, Instagram). We have no control over these cookies as they are set by the social media platforms themselves.
8.3.5 Advertisement cookies. These cookies allow us to deliver tailor-made advertisements to you on third party Sites based on your interests in our products and services manifested during your visit on our Site. These cookies do not collect information that identifies you. All information is anonymous.
8.3.5(i) We engage on our Site in interest-based advertising, including retargeting or remarketing technology provided by third parties (“Third Party Providers”), such as:
• Criteo SA, Paris, France, www.criteo.com (“Criteo”),
• DoubleClick, a division of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, www.doubleclickbygoogle.com, (“DoubleClick”), and
• Google Analytics Advertising Features, a service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
• Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland
• Instagram LLC, 1601 Willow Rd. Menlo Park, CA 94025
• Adform A/S, Copenhagen, Denmark, http://site.adform.com/ (“Adform”)
to analyze your navigation on our Site. Based on that, we are able to approach you with personalized advertisements. For this purpose, cookies are stored on your computer. During your visit on our Site, neither the Third-Party Providers nor BOH Plantations collect any personalized data, only anonymized data. The engagement of such technology is in full compliance with the relevant data protection legislations. Thanks to such data we can, for example, approach you with advertisement on third party Sites which is personalized according to your interests in our products, e.g. after you have visited our Site and showed interest in a particular series of products, this technology may later show you more information in form of advertisements while surfing on another Site. The only goal of engaging this technology is to best adapt the available information to your interests and to make your online experience as informative as possible. You can, however, adjust your browser settings to not store such cookies and to delete already stored cookies. Please find in the following the opt-out functions of the Third-Party Providers under the following links:
• Criteo: www.criteo.com/privacy
• DoubleClick: https://code.google.com/archive/p/google-opt-out-plugin/
• Google Analytics Advertising Features: https://tools.google.com/dlpage/gaoptout/
• Facebook: https://www.facebook.com/help/164968693837950
• Instagram: https://www.instagram.com/about/legal/privacy/
• Adform: http://site.adform.com/privacy-policy/en
8.3.5(ii) Anonymous data created by using Google Analytics Advertising Features may be used for demographics and interest reporting as well as network impression reporting.