Privacy Policy

Last Updated 15 June 2021

  1. Introduction

Welcome to the Rakan Tutor’s privacy policy.

Rakan Tutor respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you provide us with your data (regardless of the manner of provision or the form of data) and tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Rakan Tutor collects and processes your personal data, including any data you may provide through this website when you correspond with us, fill in a form affiliated to or provided by us, sign up to our newsletter or engage in our services or any other activities.

This website is not intended for children and we do not knowingly collect data relating to children.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Rakan Tutor

Email address: tea[email protected]

Postal address: Unit 79-1, Biz Avenue II @ Neocyber, Lingkaran Cyber Point Barat, 63000 Cyberjaya, Selangor

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    • Personal data. Here is a list of personal data we commonly collect to conduct our business activities.
      • Personal details (e.g., name, gender, Organisation name, job title, work and mobile telephone numbers, work and personal email and postal address).
      • Professional details (e.g., job and career history, educational background and professional memberships, published articles). 
      • Financial information (e.g., taxes, payroll, investment interests, assets, bank details, insolvency records).
    • Sensitive personal data. Examples of sensitive personal data we may obtain, or otherwise hold, include:
      • Personal identification documents that may reveal race, religion or ethnic origin, possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
      • Adverse information that may reveal criminal convictions or offences information.
      • Information provided to us by our clients in the course of a professional engagement.
      • Diversity and equal opportunity information volunteered by participants in certain professional empowerment programmes and onboarding processes.
    • Child data. Although we do not intentionally collect information from individuals under 13 years of age, we may occasionally receive details about children attending performances and other events we host with their family or guardians.
    • Location-based data. We may process geographical locations you enter when arranging or providing services to you.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  1. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • apply for volunteer with us or to engaged with our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we may automatically collect data about your equipment, browsing actions and patterns.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.

  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of a number of ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new volunteer or customer(a) Personal data
(b) Sensitive personal
(c) data Location-based data
Performance of a contract with you
To monitor our activities and personnel, including recruitment, performance management and succession planning(a) Personal data
(b) Sensitive personal
(c) data Location-based data
Legitimate interest of us or other third parties (to enable effective management of our activities and personnel)
To process and deliver you our services(a) Personal data
(b) Sensitive personal
(c) data Location-based data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to safeguard our services to you)
To make decisions about our continued engagement(a) Personal data
(b) Sensitive personal
(c) data Location-based data
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Personal data
(b) Sensitive personal
(c) data Location-based data
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to better understand the services or goods that we are providing)
To enable you to partake in an event or complete a survey(a) Personal data
(b) Sensitive personal
(c) data Location-based data
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to better understand the services or goods that we are providing, to develop and to grow our activity)
To administer and protect the Organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Personal data
(b) Sensitive personal
(c) data Location-based data
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)
(b) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness and the safety of our services(a) Personal data
(b) Sensitive personal
(c) data Location-based data
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data in improving our website, products/services, marketing, parties' relationships and experiences(a) Personal data
(b) Sensitive personal
(c) data Location-based data
(a) Necessary for our legitimate interests (to better understand the services or goods that we are providing, to develop and to grow our activity, to keep our website updated and relevant, to inform our outreach strategy)
  1. Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

  1. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your personal data

We may share your personal data with the third parties for the purposes set out in the table above. We may also disclose the data with third parties that we may choose to sell, transfer or merge parts of our activity or our assets. Alternatively, we may seek to acquire others or merge with them. If a change happens to our activity, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know.

We have put appropriate technical and organisational security procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.

If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

    • Request access to your personal data.
    • Request correction of your personal data.
    • Request erasure of your personal data.
    • Object to processing of your personal data.
    • Request restriction of processing your personal data.
    • Request transfer of your personal data.
    • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within 30 days. Occasionally it could take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.

Where our use of the data is unlawful but you do not want us to erase it.

Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.