App - Privacy Policy - Vealth.me Malaysia

1. General Description

1.1 We are Lunix Health Sdn Bhd ("we", "us" and/or "our") and we own and operate the Vealthme mobile application on Android and Apple platform (“App”).

1.2 We recognises and undertakes its responsibilities under the Personal Data Protection Act 2010 (“PDPA”) and its regulations. This Privacy Policy (“Privacy Policy” or “Policy”) will inform you of your rights with regards to your Personal Data that has been and/ or will be collected, used, processed and disclosed by us, whether now or in the future in connection with your usage of the App.

1.3 By providing your Personal Data to us, you acknowledge and agree that you have fully read and understood this Policy, and consented to the collection, use, processing and disclosure of your Personal Data as described in this Policy.

2. Collection of Personal Data

2.1 Your Personal Data is information that relates directly or indirectly to you, who is identified or identifiable from that information or from that and other information to which we have or may have access to (“Personal Data”). This includes any sensitive personal data, religious belief or any other beliefs. It is important that the information has the data subject as its focus and affects the individual’s privacy in some way.

2.2 When you become a user of the App or communicate with us via our support email or WhatsApp communications channel, we may collect a variety of your Personal Data, which may include but not limited to the following:

(a) Name;

(b) National registration identity card number;

(d) Race, ethnic origin and religious beliefs;

(e) Postal address;

(f) Telephone number (home, mobile, office);

(g) Email address;

(h) Contact preferences;

(j) Employer details and / or supporting documents;

(k) Occupation;

(l) Marital status;

(m) Residential status;

(n) Location Data

(o) Images (still/recording)

(p) Sensitive personal data such as blood type, age, health conditions etc.;

(q) IP address

(r) Physical or Digital Signatures

2.3 The list of Personal Data stated above is not exhaustive and may include other personal data depending on the nature of your usage of the App.

2.4 You agree not to submit Personal Data which is inaccurate and misleading, and you agree to inform us of any inaccuracies or changes to the Personal Data you have provided to us. You acknowledge that the Personal Data you provide us and which we collect from you, is your own information or information which you have been authorised to provide to us. we shall reserve the right to request further documentation for the purpose of verifying the Personal Data provided by you.

3. Personal Data that we may collect

3.1 During the course of you using the App, you may be requested to furnish your Personal Data from time to time. we and our third party service providers may share the Personal Data with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products and services. Any and all Personal Data collected will be stored in servers located within and outside Malaysia.

3.2 We may obtain your Personal Data from among others, the following sources:

(a) when you create an account with us;

(b) when you submit any form, including but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;

(d) when you subscribe to our publications or marketing collaterals;

(e) when you participate in any activity, event or campaign on the App;

(f) when interact with us via an external service or application, such as social media platforms, if any;

(g) when you grant permissions on your device to share information on the App;

(h) when you carry out transactions through our App;

(i) when you provide us with feedback, rating or complaints;

(j) when you submit your personal data to us for any reason;

3.3 The above does not purport to be exhaustive and sets out some common instances of when Personal Data about you may be collected.

3.4 We may collect and store certain information automatically when you visit the App. This including but not limited to your computer or device’s Internet Protocol (IP) address, connection information such as browser type and version, your operating system and platform, type of mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, login details, cookie identifier and your activity on the App, including the pages you visited, the times of visit and the searches you made. This data is collected for analysis and evaluation in order to help us improve our App and the services we provide.

3.5 Our App may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more Purposes including but not limited to, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer.

4. How we use your Personal Data

4.1 We collect, use, disclose, and otherwise process your Personal Data for, among others, the primary purposes to provide our services to you. In addition, we may collect, use, disclose and otherwise process your Personal Data for, among others the following purposes (the “Purposes”):

to create, administer and update your account;
to optimize and customize your user experience with our App;
to allow you to use all available functions and services within the App;
for identification and verification purposes (where necessary);
to monitor and analyse usage and activity trends;
to maintain and administer any App updates and support that may be required from time to time to ensure the smooth running of our services;
to keep you posted on our latest services or product announcements and upcoming events;
to conduct market research and development activities for surveys, profiling and statistical analysis for the improvement of our services to you or to improve any of our marketing programmes or events;
to deal with, process and/or administer marketing campaigns conducted by us or on our behalf which you have consented to participate in;
to share your Personal Data with third party providers for the purposes of, including but not limited to, promoting third party services, allowing you to claim benefits, discounts, deals, or other incentives made available to you by the App;
to disclose to a third party to comply with any law, legal requirements, orders, directions or requests from any court, authority or government body of any relevant jurisdiction, which may be within or outside Malaysia;
to prevent or investigate any fraud, unlawful activity, omission or misconduct whether or not there is any suspicion of the aforementioned, relating to your use of our services;
to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Malaysia.
any other purposes which we notify you of at the time of obtaining your consent.
for any of the purposes relating to the above.

4.2 You hereby agree and understand that the purpose of such collection and retention and otherwise processing of Personal Data is critical to your usage of the App. By using the App and filling in your Personal Data on the App, you expressly consent for us to retain and process your Personal Data.

4.3 We will only be able to collect your personal data if you voluntarily submit the personal data to us or as otherwise provided for under this Privacy Policy. Note, however, that failure to supply Personal Data may affect our ability to deliver optimised user experience service to our registered users. In addition, failure to provide certain essential Personal Data may result in you unable to use certain functions of the App or the entire App.

5. Disclosure of Personal Data

5.1 Personal Data provided to us will generally be kept confidential but you hereby consent and authorize us to provide or disclose your Personal Data to the following categories of parties (whether located within or outside Malaysia):

any person or authority to whom we are compelled or required to do so under law;
our business partners, affiliates and sponsors that provide benefits, discounts, deals, or other incentives to users of the App;
members of our Group companies and their affiliates;
our auditors, consultants, accountants, lawyers or other professional advisers;
such sub-contractors or third party service or product providers as we may determine to be necessary or appropriate; and
market research firms, third party marketing entities, and technology solutions providers focus in the finance, retail, and services industries.

5.2 We may also disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purposes at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

6. Protection of Personal Data

6.1 We take the necessary precautions, both administrative and technical to safeguard your Personal Data against loss, theft, misuse and unauthorized access, disclosure, usage, alteration or destruction.

6.2 Data stored in cloud services is in encrypted form including when we utilize third-party storage. The level of security of personal data which is kept in a non-electronic environment is also treated with strict procedures and means. However, we do not warrant that any data transmission over the internet or any wireless network can be guaranteed to be totally secure. Therefore, any transmission remains at your own risk.

7. Retention of Personal Data and Access

7.1 We shall endeavour to make it easy for you to keep your Personal Data accurate, complete and up to date. However, it’s also obligatory for you to supply Personal Data to us in the most accurate manner as any loss or damage caused by the provision of erroneous, inexact or incomplete information will be your exclusive and absolute responsibility.

7.2 You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging into the App. For other personal information, we make good faith efforts to provide you with access so you can request that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes.

8. Data Transfer & Sharing

8.1 Where we consider it to be necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your Personal Data to another member of our Group companies or third-party service or product providers within or outside Malaysia in which we are established, under conditions of confidentiality and has similar levels of security safeguards or equivalent personal data protection laws in place.

9. Your Rights of Access and Correction; and Rights of Withdrawal of Consent

9.1 You have the right to request access to and correction of data about you held by us and in this respect, you may:

check whether we hold or use your Personal Data and request access to such data;
request that we correct any of your Personal Data that is inaccurate, incomplete or out-of-date;
request that your Personal Data is retained by us only as long as necessary for the fulfilment of the purposes for which it was collected;
request that we specify or explain our policies and procedures in relation to data and types of Personal Data handled by us;
communicate to us your objection to the use of your Personal Data for marketing purposes whereupon we will not use your Personal Data for these purposes. Your non-consent may curtail our ability to perform some or all of the Purposes for which we have first collected your Personal Data; and;
withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period.

9.2 You may access and request for correction of your personal data and to contact us with any enquiries or complaints in respect of your personal data to the Data Protection Officer at support@vealthme.com.

9.3 Please note that your withdrawal of consent will not affect our ability to collect, use, process or disclose your Personal Data for a specific purpose without your consent, if the PDPA or a provision in applicable law permits us to.

10. Changes to Privacy Policy

10.1 We reserve the right to update and amend this Privacy Policy from time to time without prior notice. Any material changes will be posted on our website with the updated Privacy Policy and we advise you to check our website for this Privacy Policy on a regular basis. To the fullest extent permissible under applicable law, your continued use of the App shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.

11. Other Matters

11.1 If you have any questions regarding this Privacy Policy, please contact the following:

Data Protection Officer

Address: Unit 08-09, Menara K1, Lorong 3/137C, Off, Jln Klang Lama, 58000 Kuala Lumpur, Wilayah Persekutuan Kuala Lumpur

Email: support@vealthme.com

Telephone: +6018-9593957

12. Governing Law

12.1 This Privacy Policy is subjected to Malaysia law.