Privacy Policy | Surely Insurance Agency

Effective Date: 26 September 2017

The Personal Data Protection Act 2010 (as may be amended from time to time, hereinafter referred to as the “Act”), which regulates the processing of personal data in commercial transactions, applies to Magnum Wealth Sdn Bhd and our related companies (hereinafter collectively referred to as “Magnum Wealth”, “Surely”, “our”, “us” or “we”). For the purposes of this personal data policy, the terms “personal data” and “processing” shall have the meaning prescribed in the Act.

Surely collects information about you when you use our mobile applications, websites, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us. The Services are provided by Magnum Wealth Sdn Bhd, and this Privacy Statement applies to information collected and used by Surely.

Please read this Privacy Policy to understand how we use and process the personal data we have collected or may collect from you.

By providing your personal data and/or using our site and/or service, you are consenting to this Privacy Policy and the collection, use, access, transfer, storage and processing of your personal data described in this Privacy Policy as may be modified from time to time by Magnum Wealth. Any changes to this Privacy Policy will be updated and uploaded to our site, http://surely.com.my/. Any such revised Privacy Policy will continue to apply to all personal data that has previously been collected as well as information that has been stored or processed on an ongoing basis by Surely. Therefore, you are encouraged to check the version of the Privacy Policy whenever you visit the site for any updates or changes.

If you are under 18, you should ensure that you obtain the consent of your parents or legal guardian before using our services and/or products. If you are a firm, corporation or entity supplying personal data of your partners, directors, shareholders, employees, officers and/or other persons to us, please do ensure that you have obtained their consent and bring this Privacy Policy to their attention.

1. WHAT THIS PRIVACY POLICY EXPLAINS
This Privacy Policy sets out:
1.1 what kind of personal data is being processed;
1.2 the purposes for which the personal data is being or is to be collected and further processed;
1.3 the source of that personal data;
1.4 the persons to whom we disclose or may disclose your personal data;
1.5 where it is obligatory for you to supple the personal data, the consequences to you if you fail to supply the personal data;

1.6 the choices and means that you may limit the processing of your personal data, including personal data relating to other persons who may be identified from that personal data; and

1.7 your right to request access to and to request correction of your personal data and how to contact us with any inquiries or complaints in respect of the personal data.

2. COLLECTION OF INFORMATION

The personal data collected by us may include (but is not limited to) the following:
. contact information - e.g. your name, date of birth, identification number (such as NRIC or passport number), gender, nationality, race, address, contact number, fax number, email address;
. billing information - your credit card information and bank account details;
. the status of the services you have acquired from us or subscribed to - e.g. account number, account balance, account activities, payment history;
. transaction information - e.g. information requested by you from our services, such as status of motor insurance policy;

. your personal interests and preferences to help us tailor offerings of our services and products which would suit your best.

If need arises, we will obtain explicit consent from you to process sensitive personal data. We may however process personal data without your consent in limited circumstances as permitted by law.

The provision of your Personal Data is voluntary. However, if you do not provide Surely your Personal Data, Magnum Wealth will not be able to process your Personal Data for the Purposes and Additional Purposes outlined below.

If you are an agent, vendor, supplier or service provider, provision of your Personal Data is mandatory and failure to provide your Personal Data, may be a breach of laws or regulatory requirements, and may cause Surely to be unable to engage you to provide services or products or issue payments to you for products or services provided.

2.1 Information You Provide to Us
We collect the information that you provide directly to us when you create or modify your account, fill up application or registration forms or other similar forms, request on-demand services, contact customer support, or otherwise communicate with us. This information may include: name, email, phone number, postal address, profile picture, payment method, items requested (for delivery services), delivery notes, and other information you choose to provide.

2.2 Information We Collect Through Your Use of Our Services
When you use our Services, we may collect information about you in the following general categories:

Location Information: When you use the Services, we may collect location data from the Surely app if you permit the Surely app to access location services through the permission system used by your mobile operating system (“platform”). We may also collect the precise location of your device when the Surely app is running in the foreground or background. We may also derive your approximate location from your IP address.
Contacts Information: If you permit the Surely app to access the address book on your device through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Statement or at the time of consent or collection.
Transaction Information: We collect transaction details related to your use of our Services, including the type of service requested, date and time the service was provided, amount charged, and other related transaction details. Additionally, if someone uses your promo code, we may associate your name with that person.
Usage and Preference Information: We collect information about how you and site visitors interact with our Services, preferences expressed, and settings chosen. In some cases, we do this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers.

To learn more about these technologies, please see our Cookie Statement.
Device Information: We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and version, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
Call and SMS Data: Our Services facilitate communications between Users and Drivers. In connection with facilitating this service, we receive call data, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of the SMS message.
Log Information: When you interact with the Services, we collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.

2.3 Important Information About Platform Permissions
Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Surely app wants permission to access certain types of data and will allow you to provide your consent (or refuse consent) to that request.

Android devices will notify you of the permissions that the Surely app seeks before you first use the app, and your use of the app constitutes your consent.

2.4 Information We Collect from Other Sources
We may also receive information from other sources and combine that with information we collect through our Services. For example:

If you choose to link, create, or log in to your Surely account with a payment provider (e.g., Google Wallet) or social media service (e.g., Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
If you also interact with our Services in another capacity, for instance as an agent or user of other apps we provide, we may combine or associate that information with information we have collected from you in your capacity as a User or agent.

3. Use of Information
Magnum Wealth may use and process your Personal Data for business and activities of Magnum Wealth which shall include, without limitation the following (“Purpose”):

3.1 Where you are a customer of the services provided by Magnum Wealth:

to perform the Magnum Wealth’s obligations in respect of any contract entered into with you;
to provide you with the service you have requested;
to process your subscriptions and to deliver the services to you;
where you have requested to download and use the Surely App (“App”), to process your request, to deliver the App to you and to provide you a license for the use of the App;
to process your participation in any events, activities, focus groups, research studies, contests, promotions, polls, surveys or any productions;
to process, manage or verify your application for subscription with the Surely and to provide you the benefits offered to subscribers;
to validate your order and process payments relating to any products or services you have requested;
to understand and analyses our sales as well as your needs and preferences;
to develop, enhance and provide products and services to meet your needs;
to process exchanges or product returns.

3.2 Where you are an agent, vendor, supplier, partner, contractor or service provider:
for the purposes of engaging you to provide services or products;
to facilitate or enable any checks as may be required by Magnum Wealth in order to engage you;
to process payments relating to any products or services you have provided; and
to contact you.

3.3 General:
to respond to questions, comments and feedback from you;
to communicate with you for any of the purposes listed in this Notice;
for internal administrative purposes, such as auditing, data analysis, database records;
for purposes of detection, prevention and prosecution of crime;
for Magnum Wealth to comply with its obligations under law;
and you agree and consent to Magnum Wealth using and processing your Personal Data for the Purposes and in the manner as identified in this Notice. This list is non-exhaustive and may be amended from time to time by us.

3.4 Marketing and promotional purposes
Magnum Wealth may also use and process your data for other purposes such as (“Additional Purposes”):
To send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings from Magnum Wealth, its partners, sponsors or advertisers;
To notify and invite you to events or activities organized by Magnum Wealth, its partners, sponsors or advertisers;
To process your registration to participate in or attend an event or activity and to communicate with you regarding your attendance at the event or activity;

To share your Personal Data amongst its subsidiaries, associate companies and jointly controlled entities as well as with its agent, vendor, supplier, partner, contractor or service provider who may communicate with you to market their products, services, events or promotions by way of post, telephone call, short message service (SMS), by hand and/or by email.

Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than your home nation or otherwise in the country, state and city in which you are present while using any services provided by Magnum Wealth Group (“Alternate Country”), to companies under Magnum Wealth Group which are located outside of your home nation or Alternate Country and/or where Magnum Wealth Group’s servers are located outside of your home nation or Alternate Country. You understand and consent to the transfer of your Personal Data out of your home nation or Alternate Country as described herein.

4. Sharing of Information
We may share the information we collect about you as described in this Statement or as described at the time of collection or sharing, including as follows:

4.1 Through Our Services
We may share your information:

With Agents to enable them to provide the Services that you have requested. For example, we may share your name, contact number, email address, mailing address, NIRC Number, car registration number and motor insurance details;
With Service providers, including, information technology (IT) service providers for infrastructure, software and development work;
With third parties to provide you a service that you have requested through a partnership or promotional offering made by a third party or us;
With the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public;
With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate; and

4.2 Other Important Sharing
We may share your information:
With Magnum Wealth affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and / or investment, insurance, takaful and financial services purposes;
Professional advisors and external auditors, including legal advisors, financial advisors and consultants;
With vendors, consultants, marketing partners, and other service providers who may need access to such information to carry out work on our behalf;
In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our User agreements, Terms of Service, or policies, or to protect the rights, property, or safety of Magnum Wealth or others;
In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
If we otherwise notify you and you consent to the sharing; and
In an aggregated and/or anonymized form which cannot reasonably be used to identify you.

4.3 Social Sharing Features
The Services may integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.

4.4 Analytics and Advertising Services Provided by Others
We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our Services, as well as when you visit other online sites and services. For more information about these technologies and service providers, please refer to our Cookie Statement.

5. Your Choices
5.1 Account Information

You may correct your account information at any time by logging into your online or in-app account. If you wish to cancel your account, please email us at support@surely.com.my. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our Terms, we may seek to resolve the issue before deleting your information.

5.2 Access Rights
Magnum Wealth will comply with individual’s requests regarding access, correction, and/or deletion of the personal data it stores in accordance with the applicable law.

5.3 Location Information
We request permission for our app’s collection of precise location from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, you can later disable it by changing the location settings on your mobile device. However, this will limit your ability to use certain features of our Services.

5.4 Contact Information
We may also seek permission for our app’s collection and syncing of contact information from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, iOS users can later disable it by changing the contacts settings on your mobile device. The Android platform does not provide such a setting.

5.5 Promotional Communications
You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.

5.6 Direct Marketing Purposes
Magnum Wealth does not share your personally identifiable information with third parties for the third parties’ direct marketing purposes unless consent has been obtained from you prior to the sharing of the information.

5.7 Cookies and Advertising
If you do not wish for your Personal Data to be collected via cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.

6. Changes to the Statement
We may change this Statement from time to time. Any changes to this Privacy Policy will be updated and uploaded to our site, http://surely.com.my/. Any such revised Privacy Policy will continue to apply to all personal data that has previously been collected as well as information that has been stored or processed on an ongoing basis by Surely. Your continued use of the Services after such notice constitutes your consent to the changes. We encourage you to periodically review the Statement for the latest information on our privacy practices.

7. Contact Us
If you have any questions about this Privacy Statement, please contact us at support@surely.com.my or write to us at Magnum Wealth Sdn Bhd Attn: Head of Compliance, 11-8 & 11-9, Menara Mutiara Sentral, No 2, Jalan Desa Aman 1, 56100 Cheras, W.P. Kuala Lumpur

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