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1. INTRODUCTION
ADAPT is committed to protecting your privacy. Please read this Privacy Policy carefully to learn more about how we collect and use your information. This Privacy Policy when read together with the Terms and Conditions and Disclaimer governs your interactions with the Websites and/or the ADAPT Services (including the Convention). By interacting with the Websites and/or the ADAPT Services (including registering for, attending and/or participating in the Convention) or by otherwise submitting information to us, you agree and consent to ADAPT, as well as our respective representatives, sponsors and/or partners collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.
2. DEFINITIONS
The following expressions shall, unless the otherwise expressly stated, bear the following meaning:
ADAPT, our, us and we refers to Adapt Ventures Sdn Bhd (Company Registration No.: 1252836-V) and its Related Corporation(s).
ADAPT Website means https://adaptconvention.com/ and any other websites or other web address(es) as may be used and/or adopted by ADAPT from time to time.
ADAPT Services means any services and/or products and/or a combination of both provided by ADAPT, our Related Corporation(s), authorised affiliated partners or associates and shall include our “online” (e.g., accessed via the ADAPT Website, Convention Website or any related mobile applications however accessed and/or used, whether via personal computers, mobile devices, tablets or otherwise) and “offline” (e.g, collection of data through mailings, telephone, or in person) activities owned, operated, provided, or made available by ADAPT or any of its Related Corporations. For the avoidance of doubt, ADAPT Services shall include the Convention and any services provided by ADAPT in relation to the Convention. Any references to “ADAPT Services” in this Privacy Policy shall mean all the ADAPT Services or any of them as the context requires.
The Convention refers to the ADAPT International Convention organised by ADAPT and held on 14 to 17 December 2021.
Convention Website means any website or online platform or channel (including third-party platforms and channels) through the Convention may be accessed
Non-PII means any information that cannot be used to identify a particular individual.
Personal Data means any data or information which either jointly with other data or on its own can be relating directly or indirectly about you (or any person) from which you (or such person) can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access including any sensitive personal data and expression of opinion about you.
Privacy Policy shall mean this policy and shall include all such further and future amendments.
Process, Processing shall mean any dealings by us with the Personal Data including but without limitation to the collection, recording, holding, storing, use and disclosure of the Personal Data and shall further include, but not be limited to, the organisation, adaptation, alteration of the Personal Data, the access to, retrieval, consultation or use of the Personal Data, the disclosure of the Personal Data by transmission, transfer, dissemination or otherwise making available or the alignment, combination, correction, erasure or the destruction of the Personal Data.
Related Corporation means any subsidiary or holding/parent company of that corporation or any subsidiary of that holding/parent company, or any other affiliated legal entity with whom we are under common corporate control., which has agreed to comply with the terms of this Privacy Policy.
Websites shall mean the ADAPT Website and/or any Convention Websites. For the avoidance of doubt, any reference to the plural shall include the singular and vice versa.
A reference to “person(s)” shall include any company, partnership, individual person, firm, joint venture, association, corporation, statutory body, unincorporated body of persons, trust, bureau, minister, agency, instrument, court, regulatory body, government or state, any authority or other body corporate and vice versa.
A reference to you or the user is a reference to a user of any of the ADAPT Website, any Convention Website and/or the ADAPT Services.
3. HOW DO WE COLLECT YOUR INFORMATION?
We collect your information in various ways including but not limited to those described below. If you wish to stop and/or prohibit us from collecting your Personal Data, we will no longer be able to provide the relevant ADAPT Services to you.
a. During the signing-up/registration process– any personal information provided by you whenever you sign up or register for the Convention or any other ADAPT Services on a Website; or fill in or submit any registration forms/questionnaires, survey, agreements and whether by way of telephone conversation, online submission, or through the Websites or any other mode of telecommunications.
b. From your use of the Websites and/or the ADAPT Services – when using the Websites and/or any other ADAPT Services, we may ask you, among other things, to provide your Personal Data such as your name, occupation and place of occupation, preferred language and other preferences, your mobile number or other unique device identifier assigned to your mobile device, and your contact particulars. In addition to this Personal Data and in accordance with applicable law, we and/or our third-party service providers may use a variety of technologies that automatically (or passively) collect certain Personal Data and Non-PII wheneveryou visit or interact with the Websites and/or the ADAPT Services. Such information may include the browser that you are using, the IP address of your mobile device or other apparatus, areas of the Websites that you visit and the time of the day of your visit. In addition, tracking information may be collected as you navigate or use the Websites and/or the ADAPT Services. For users who are using the Websites and switch on the location services, the location of your mobile device/other apparatus and movement may be collected to capture location details. You may be required to switch on the location, camera services/settings when using the Websites and/or the ADAPT Services. We collect this information for various purposes including to provide you with support, to send you promotions and offers, to notify you when there are upcoming events in your vicinity, to enhance the Websites and the ADAPT Services and for our internal business purposes.
c. Use of “Cookies”– some information will be gathered through the use of “cookies”. “Cookies” are small bits of information that are automatically stored on a person’s web browser. We use cookies to enhance your experience visiting our sites and our partner sites, for example, cookies allow ADAPT to save preferences for you so that you will not have to re-enter them the next time you visit. Cookies also help us to collect anonymous click stream data for tracking user trends and patterns. ADAPT may also use the anonymous clock stream data to help our advertisers deliver better-targeted advertisements (if applicable). The use of “cookies” is common in most websites. If you wish, you may reset your browser either to notify you when you have received a cookie, or to refuse to accept cookies. Please take note that areas of certain sites will not function properly if you set your browser to not accept cookies.
You should be aware that ADAPT cannot control the use of cookies (or the resulting information) by third-parties and use of third-party cookies is not covered by this Privacy Policy.
d. Use of Web Beacons and other Technologies – small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) or other similar technologies may be included in our web site and mobile pages and messages. The web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored in a user’s computer hard drive, web beacons are embedded invisibly on Web pages. Web beacons or similar technologies help us to better manage content on the Websites and the ADAPT Services by informing us what content is effective, helping us count users, monitor how users navigate and interact with the Websites and/or the ADAPT Services, count how many e-mails that we send were actually opened, and so on.2
e. Embedded Scripts– an embedded script is programming code that is designed to collect information about your interactions with the Websites and/or the ADAPT Services, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to a Website and/or ADAPT Service and is deactivated or deleted thereafter.
f. Social Media and Widgets– The Websites and/or the ADAPT Services may include social media features, such as the Facebook Like button, Twitter, Pinterest, Google+, and widgets such as a “Share This” button, or interactive mini-programs that run on our online and mobile Websites and/or ADAPT Services. These features may collect your IP address, which page you are visiting on our online or mobile Websites and/or ADAPT Services and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our online Websites and/or ADAPT Services. We have no control over such linked sites, applications and widgets and we cannot accept responsibility for the conduct of such company(ies). Your interactions with these features and widgets are governed by the privacy policy of the company(ies) providing them. Before disclosing your Personal Data on any other website or using these applications or widgets we advise you to examine the terms and conditions of using that website and the relevant third-party’s data collection practices and control in their respective privacy policies.
g. Marketing Communications & Postings– We may collect your Personal Data through direct communications with you (including by way of SMS, MMS, any form of text, e-mails, telephone conversations and any other mode of telecommunications) and when you respond to requests from us (such as contests, questionnaires or surveys). We may also collect and process any postings/views/comments/opinions from you which you posted on the Websites or ADAPT Services. The Personal Data will be collected with your knowledge and consent and is provided by you voluntarily. If you do not agree to this information being collected and used by us then you should not provide or post it, which in turn means that you may not be able to participate in or receive the full benefit of such communications, contest, polls, questionnaires or surveys.
h. Non-PII –Specific or aggregate information may be collected to help maintain accurate accounts, assist in marketing of our products and services and to help make our websites more useful to you. ADAPTmay provide aggregated statistical information about user behaviour to reputable third parties. For avoidance of doubt, such information collected or collated as part of a statistic, is not Personal Data.
4. HOW WE PROCESS PERSONAL DATA
Your Personal Data may be processed for various purposes, including but not limited to the following purposes:
a. to provide the ADAPT Services to you and for the performance of any transaction between you and ADAPT;
b. to contact you, manage your relationship with us and to promote and market to you (including but not limited to by way of direct mail, bill inserts, telemarketing, SMS, MMS, any form of text, e-mail and/or any other mode of telecommunications) other services or products provided by us or our Related Corporation(s), sponsors and strategic partners; and/or products, services, promotions or special offers of third parties whose products and services we think may be of interest to you;
c. to locate you;
d. to help us to monitor and improve the performance of the Websites and/or the ADAPT Services including but not limited to our customer relations and other service providers etc;
e. to maintain and develop our services, business systems and infrastructure, including testing and upgrading of the system;
f. to gain an understanding of you in order for us to enhance our services or to improve your overall experience in using the Websites and/or the ADAPT Services;
g. to conduct research and development and statistical analysis in connection with the Websites and/orthe ADAPT Services and to identify your needs, preference and market trend;
h. to investigate and resolve any service issues, complaints or other enquiries regarding the Websites and/or the ADAPT Services;
i. to detect and prevent fraudulent or criminal activity;
j. to comply with any law, rule or regulation to which we are subject;
k. to verify your identity and to conduct background checks and/or credit worthiness checks on you (if required);
l. any other uses to which you have explicitly consented; and
m. such other uses as we may deem reasonably necessary to provide the Websites and/or the ADAPT Services.
5. TRANSFER AND STORAGE OF PERSONAL DATA OVERSEAS
Please note that all of your information may be transferred to and maintained on computer networks which may be located outside of the state, province, country or other governmental jurisdiction in which you reside, and the countries in which these computer networks are located may not have privacy laws as protective as the laws in your country. When you provide us with your Personal Data, you also consent to your Personal Data being transferred overseas.
We may also share your Personal Data with our service providers and other third parties located outside of the country in which you reside so that they can provide you with any products or services requested by you, including contacting you in relation to the products or services. As these entities are located outside of the country in which you reside, the legal framework in relation to personal data protection or privacy protection may vary in degree in different countries/jurisdictions.
6. DISCLOSURE TO THIRD PARTIES
Your Personal Data or non-PII may be disclosed to third parties, including but without limitation to the following persons:
a. any of our Related Corporation(s);
b. any person engaged/contracted/appointed by us (including, but not limited to, our employees, workers, staff, shareholders, directors, agents, contractors, business or strategic partners or associates) to facilitate the performance and provision of the ADAPT Services and/or any other purpose which is necessary or related to the provision of ADAPT Services to you;
c. if you have subscribed to a service through the operating system on your mobile device (including, but not limited to Google’s “Google Now” service), we will disclose information such as your search history to Google. You can opt out of us providing such information to Google through the operating system on your mobile device;
d. payment channels including but not limited to financial institutions;
e. any person for the performance of a contract to which you are a party;
f. any person as required by law, rule or regulation to which we are subject;
g. any person for the assessment or collection of any tax or duty or any other imposition of a similar nature;
h. any person for the purpose of responding to services or technical issues or marketing activities;
i. our professional advisors on a need to know basis for the purpose of those advisors providing advice to us;
j. any person which acquires all or part of the assets or business of ADAPT;
k. any person when there is a complaint, dispute or conflict, including an accident;
l. any person in order to enforce the Terms and Conditions or Disclaimer governing your use of the Websites and/or the ADAPT Services;
m. any person if it is necessary, in our sole discretion, to protect the safety, rights, property or security of ADAPT, the Websites and/or the ADAPT Services or any third party;
n. any person in order to detect, prevent or otherwise address fraud, security or technical issues and/or to prevent or stop any activity which in our sole discretion is deemed to be illegal, unethical, unlawful, or poses a serious risk to the society in general; and
o. otherwise as permitted under the applicable law.
7. YOUR OBLIGATIONS
You are responsible for updating your Personal Data with us and you hereby confirm that all Personal Data furnished to us is true, accurate, complete, not misleading and kept up-to-date. You shall immediately report and notify us in the event of any error or necessary update in the Personal Data which you have submitted and/or provided to us and/or otherwise collected by us whether through your usage the Websites and/or the ADAPT Services or otherwise.
If you do not wish to receive certain information from us whether via SMS, MMS, or any form of text, e-mail or otherwise you shall notify us and request to be excluded from such services, failing which you shall deemed to have accepted the services voluntarily.
We shall not be responsible for any Personal Data made available by you on any third-party sites which may have a link on a Website and/or the ADAPT Services.
8. SECURITY
We take reasonable precautionary measures to safeguard your Personal Data against loss, theft, unauthorised access, or use. However, please note that we cannot guarantee the security of your Personal Data and we do not assume or accept any liability for any improper access or use of it or any theft or loss of it.
9. YOUR DECLARATION
BY AGREEING TO THIS PRIVACY POLICY AND/OR BY REGISTERING FOR OR CONTINUING TO USE THE WEBSITES AND/OR THE ADAPT SERVICES, YOU ACCEPT AND AGREE TO YOUR PERSONAL DATA BEING COLLECTED, PROCESSED AND DISCLOSED BY US AS SET OUT IN THIS PRIVACY POLICY. YOU ALSO EXPRESSLY CONSENT TO ADAPT’S USE OF LOCATION-BASED SERVICES.
PLEASE TAKE NOTE THAT YOU MAY REFUSE TO PROVIDE US WITH ANY PERSONAL DATA AND TO TERMINATE YOUR RELEVANT ADAPT SERVICES TRANSACTION WITH US AT ANY TIME.
10. RELEASE OF LIABILITY
You waive and release ADAPT from any and all liability, claims, causes of action, losses, expenses or damages arising from your use of the Websites and/or the ADAPT Services.
11. YOUR RIGHTS
12. AMENDMENTS TO THIS PRIVACY POLICY
ADAPT reserves all rights to amend, modify, vary, terminate, delete and/or add any part or all of this Privacy Policy at any time and from time to time and any notice in relation to any such amendment, modification, variation, termination, deletion and/or addition shall be posted on the ADAPT Website and/or the ADAPT Services. Your continued usage of any Website and/or ADAPT Service after being notified of any changes to this Privacy Policy shall be deemed to be an agreement by you to such changes. If you do not agree to any such changes, you may terminate any agreement between you and ADAPT in relation to your use of the Websites and/or the ADAPT Services.
13. CONFLICT
If there is any conflict in any different language versions of this Privacy Policy, this English version shall prevail.
14. LAW AND JURISDICTION
These Privacy Policy, and any non-contractual obligations arising out of or in connection with them, shall be governed and construed in accordance with the laws of Malaysia. Any dispute arising out of or in connection with these Privacy Policy (including as to the existence, validity, interpretation, performance, breach or termination thereof) or any dispute regarding non-contractual obligations arising out of or in connection with the Privacy Policy will be subject to the exclusive jurisdiction of the Singapore International Arbitration Centre in Singapore in accordance with the arbitration rules of the Singapore International Arbitration Centre (the SIAC Rules) and the SIAC Rules are deemed incorporated into these Privacy Policy by reference.