Privacy Notice

1. Introduction

This privacy notice applies to all persons accessing the website: https://horosys.com (hereinafter referred to as the “Websites”) operated by Softwell Sdn. Bhd. (Company No. 202101041961 (1442261-W)) (“we” or “us”) as well as all other persons connected to the use of the services or related services offered by the Websites. This privacy notice explains the type of data we collect and how we collect the data, the purposes of processing such data, the parties we disclose the data to, and your rights relating to your personal data provided to us.

2. Our Commitment

We may from time to time require your personal information to be submitted for you to gain access to information and services offered through the Websites. Your privacy is important to us. Therefore, we are committed to ensuring that the confidentiality and security of all personal information provided to us are fully protected at all times in accordance with the Personal Data Protection Act 2010 (the “PDPA”), and may only be disclosed or used by us in accordance with this privacy notice or where it is permitted under the law.

3. What Information Do We Collect

We collect, share, and process personal information provided by you depending on the service you access through us. The types of information we collect and process, or is processed on our behalf includes those required to establish your identity and background as an individual (e.g. name, age, marital status, identity documents, address, contact, etc.).

3.1 Why We Collect and Process Your Personal Information

The main purpose we collect and process information related to you is for the operation of the day-to-day business or services offered by the Websites, and includes those relating or incidental to such purpose, such as:

Website Administration:

To administer the Websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
To allow you to utilize the functions and features offered on or through our websites and system.
To develop, support, and maintain IT systems for the services offered.
To keep this Websites safe and secure.
To provide you with information relating to services offered through the Websites.

Personal Identification and Assessment:

To verify your identity, background, and ensure the accuracy of information provided by you.
To assess your eligibility and suitability to participate in our services.
To conduct searches, inquiry with Government authorities or credit bureau, or any third parties to ensure creditworthiness and for compliance with the law.

Provision of Services:

To generate agreements, contracts, or other documents and incorporate details into documents.
To respond to your customer service requests and support needs more efficiently.
To understand how you and others (as a group) use the services and resources provided by us.
To send you the information and updates pertaining to your order, and to respond to your inquiries, questions, or other requests.
To keep you and/or related parties personally updated and informed through notices, letters, and other documents and forms of communication.
To perform all other obligations as a service provider whether present or future.
To customize, market, or improve our services or Websites.
To keep an internal record and database for audit purposes.
To update, manage, and maintain your accounts.
To carry out internal monitoring and control and enforcement of obligations of participants.
To maintain a transparent system to enable risk-related assessments. Other purposes which we deem necessary.

Legal Compliance:

To prevent or report on any criminal act such as money laundering and fraud.
To enforce our rights to recover debts owing to us or any other user of the Websites or any other remedies available to us whenever necessary.
To comply with any obligation under applicable laws and for any other purposes permitted under PDPA.

3.2 How Do We Collect Information

We will collect your personal information from a variety of sources including those mentioned below:

Information collected from you directly:

When you register or apply as a user for our services.
When you enrol in a course provided by us.
When you browse or visit our websites and use any of our services.
Via any verbal, written, or electronic communications with us or our authorised agents.
When managing or transacting your accounts and when making payments.
When you subscribe to a newsletter, and in connection with other activities, services, features, or resources prepared or made available by us via the Websites and others.
When you take part in surveys, promotions, and advertisements on the Websites, etc.

Other sources:

Credit reporting agencies and publicly available sources such as searches at government authorities or agencies.
Any other sources which have your consent to disclose your information.
Other sources where permitted by law or not otherwise restricted.

3.3 Personal Information about Third Parties

When you provide personal information related to third parties to us, such as your next of kin or nominees, you confirm that you have obtained their consent to do so and we are authorized to use or disclose such information. You will inform such third parties of their right to access their information held by us.

3.4 Mandatory or Voluntary Information

It may be mandatory or optional for you to supply your personal information to us, depending on situations.

Mandatory Information:

Where such information is compulsory and MUST be provided by you. If you refuse to do so, we will NOT be able to offer our services to you.

Voluntary Information:

Where such information is optional and you may choose whether to provide us with such information or otherwise. If such information is not provided, it shall not affect your use of our services.

3.5 Disclosure to Third Parties

Apart from our staff, employees, affiliates, subsidiaries, and holding companies, we may share and disclose your personal information to certain third parties, including but not limited to those mentioned below:

Our insurers and/or professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Our agents, representatives, advisers, consultants, operators, programmers, developers, engineers, or system providers who are employed or engaged to run, process, or administer the Websites and services offered under the Websites.
Payment services providers we have chosen to support us with financial transactions relating to our websites.
Other external professionals providing services to us or on your behalf, such as auditors, advocates and solicitors, trustees, valuers, tax consultants, banks, financial institutions, and accountants.
Liquidators/receivers and managers, auctioneers.
Prospective buyer(s) and/or dealer(s) of any of our business or assets.
Credit reporting agencies, debt collection agencies, regulatory authorities, police, officers, and/or public authorities.
Any person(s) as required by any applicable laws, rules, regulations, court orders, or guidelines.
Any of our assignees or transferees of our rights, interests, or obligations.
Any other person as required and authorized by us to run our day-to-day operations of the business and services offered via the Websites.

We may process your personal data, including contacting you for the purpose(s) stated herein, via telephone calls, text messaging, emails, cross-platform mobile messaging applications, post, facsimile, social media, or by any other available modes of communication.

4. Transfer Abroad

We may transfer your personal data to places outside Malaysia when carrying out any of the purposes stated herein.

5. Cookies

You agree and consent that we may from time to time set up cookies on your computer and may access those cookies. Cookies can be disabled and enabled in your web browser. Any information so collected by us will be non-personal and anonymous, and such information is obtained solely to understand your use of our websites.

6. Your Right to Complain and Access Your Information

You may e-mail our customer support at wayne@softwell.asia if you wish to do any of the following:

Request to update/change/delete/amend/correct your personal information held by us by providing us with the specific details if the same cannot be done via your profile page.
Make any complaint or inquiry you have in respect of the use of your personal data.
Check or request from us any of your personal information being held or processed by us.
Request from us a copy of your personal data being held or processed by us.

Your request above is, however, subject to:

Our right to refuse your request as allowed under the PDPA.
Your payment of charges imposed by us for processing the abovementioned request(s) made by you.

It shall be your responsibility to update and check the accuracy of your personal information supplied to us or held by us, and we shall not be responsible for any inaccuracy or error found in your personal information.

7. Limiting Information Processing

You have the option of withdrawing your consent or limiting or preventing the distribution or processing of your personal information, or personal information relating to other persons or entities who may be identified from your personal data, by e-mailing our customer support at wayne@softwell.asia.

8. Changes to Privacy Notice

Please note that this privacy notice may be amended from time to time at our own discretion, and it is your responsibility to visit the Websites on a regular basis to keep yourself informed of updates and changes. By continuing to use the Websites and the services provided therein, or by omitting to withdraw your consent, you are deemed to have accepted and consented to all of the terms set out herein and any such revisions/updates/amendments made by us from time to time.

9. English Version Shall Prevail

This Privacy Notice is issued in both English and Bahasa Malaysia. In the event of any inconsistencies or discrepancies between the English version and the Bahasa Malaysia version, the English version shall prevail.