Privacy Policy

A. Introduction

We are Ontrack Digital Sdn Bhd, Company No 1240695-X registered in Malaysia with our registered office at Unit 3-9, Tingkat 3, Dataran Pelangi Utama

Jalan Masjid PJU 6A, 47400 Petaling Jaya, Selangor, Malaysia (and we refer to ourselves as Ontrack, "we" or "us" or "our" in this document). We own and operate Hargapedia mobile application.

We are committed to protecting your privacy. We ask that you please read the following carefully to understand our views and practices regarding your personal data and how we, as data controller of your personal data, will treat it.

We will only use the information that we collect about you lawfully (in accordance with the Personal Data Protection Act 2010 in the Malaysia).

B. The Information: We Collect Big Data

Data we collect from you directly

When you register to use our App, we will ask for the following information: your name, email address, password, IP address and postcode. We may also ask you to provide your age, your phone number, your address and possibly certain other personal details such as gender or where you heard about us.

In addition, you will be able to register for the third-party website of a retailer via Hargapedia. We may use such information if you insert any information in such third party registration form, in accordance with this Privacy Policy.

In addition, from time to time we will run surveys of our users so we can learn more about consumer behaviour in general and our users in particular. You might be invited to participate. Such participation is always voluntary and it will always be clear from the invitation that this is a voluntary survey, and not information that is required to be provided in order to use our App. If you do participate, any data provided will be used in accordance with this Privacy Policy.

Data we collect from your activity on the App

As you use the App and personalise your account, we collect data about your activity on the App. This includes things like:

• Your communications with Hargapedia;
• Information about your current location (for users of Hargapedia App). You may opt out of having this data collected at any time by managing your smartphone location services settings;
• Other Information related to your use of the Services;
• Other information related to your activity, such as which website referred you to us;

Data we collect from other sources

We may receive information about you from third party sources, such as data aggregators and from third parties to whom you have given permission to share your information or from whom you have given us permission to request your information. For instance, by registering for the App using Facebook or another social network, you grant permission to that network to share your details. Depending on the network rules and your settings on it, this may include data such as your date of birth, your marital status, the number of people in your household and other information.

Sensitive Personal Data

Sensitive personal data is defined by the Personal Data Protection Act 2010 and includes details such as information related to your health, sexual orientation, religion, race or ethnic origin. For the most part, we will not need any Sensitive Personal Data in order to provide our services and we will not request it. However, we may be able to assume sensitive personal data about you from the information you provide. By letting us have any sensitive personal data, you expressly consent to us using and telling others about any of your sensitive personal data so we can provide you with the goods or services requested by you and engage in commercial activities in the way set out in this Privacy Policy.

C. How We Use the Information We Collect

We use the personal data we collect to provide the Services, to customise and improve your Hargapedia experience, to make your experience as enjoyable and efficient as possible and for commercial purposes.

Use of Information to Provide the Services

Certain information is required in order for the Services, or certain features of the Services, to operate e.g. we use your IP address to prevent any spam, fraud or abuse of our site.

Use of Information to Customise and Improve the Hargapedia Experience

We want your price comparison experience on Hargapedia to be as enjoyable as possible. We will collect the data about your browsing activities and preferences to customise your account (in addition to how you customise it yourself) and to enable us to provide an efficient and user-friendly service. We will also use it to improve the quality of the App.

Here are some specific examples of how we use your data:

• Paying attention to how you use the App help us to develop improvements to the App and the Services.

• If you have been referred to us by a third-party website, we may keep a record of the website that referred you so that we may work out which websites refer more or less users to our App. We may also have referral arrangements with certain third-party websites and referrers and we may use this data to fulfil obligations that we may have to these third-party websites or referrers.

• We collect and track individual and aggregate information about shopping habits, products and service preferences and selections which users have made and the like. We use this information for the personalisation or general improvement of the Services, but also for the purpose of business research. You can see more about aggregate information below.

• We collect and track individual and aggregate connection information such as browser type and version, operating system and platform; other software and hardware information and the like. We use this information to understand how and when our users access our services, and so we can further develop our App and Services to suit.

Use of Information for Commercial Purposes

Hargapedia does not charge non-commercial users for use of the App. In terms of data which is personal to you however, we earn revenues from this (which allows us to keep the App updated and totally free to our non-commercial users) through industry standard sources and methods including advertising sales which may be targeted to you (including online behavioural advertising, including and personalised retargeting advertising, ) and through the sale of business intelligence data (which is anonymised).

Here is how your information is used for this:

Use of Your Email Address

We use your email address to communicate with you. Some of these are service emails and are so we can communicate with you about App updates or your activity on the App. For instance, we may send you service emails:

• to send you information which you have asked for; and
• to contact you about the status of ratings or reviews you have submitted using our Services.

In addition, from time to time we may email you marketing emails with App news and updates or details of sales offers or promotions. These may be marketing for the App itself or on behalf of third parties. We may also contact you for market research purposes, either for commercial purposes or so we can get feedback about the App.

Your acceptance of the Hargapedia Terms of Use means that you are giving us consent to send you these emails. However, you can easily opt out of receiving marketing emails by clicking "unsubscribe" in the relevant email or by updating your email preferences in the "My Account" section of the App at any time. Even if you opt out, we will still send you service emails about the App itself, your account and your activities on the App.

Aggregate Information

Aggregate information is data we collect about a group or category of products, services or users, from which individual user identities have been removed and from which it is not possible to work out individual customer identities. In other words, information about how you use a service may be collected and combined with information about how others use the same service, but all such information will be anonymised and no identifying information will be included in the resulting data.

Aggregate data helps us to understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. We use and disclose anonymised aggregate information to provide other products and services, as well for the purposes of evaluating and improving our existing products and services. We also sell such aggregate information through other channels.

D. Security Measures

All of the information we collect about you is stored on our secure servers and will be held securely in accordance with our internal security policy and the law. For example, we use secure encryption to hold passwords (e.g. the password allocated as part of the registration process - which may later be changed) or your login details for a Supermarket (if you authorise us to save this information).

We may send your information internationally including to countries. While we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, some places outside of Malaysia may not have adequate data protection laws at all or may offer differing levels of protection of personal information which are not as high as in the Malaysia. By submitting your data to us, you acknowledge that provided we have used your data in the ways set out in this Privacy Policy, we cannot be held responsible for any use of your data by third parties who receive and process your data.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Operating Purposes

• We may share your personal information to any member of our group of companies, which means any subsidiaries of Ontrack Digital Sdn Bhd, or its ultimate holding or parent company and its subsidiaries.

• At times we work with other companies who help us to provide the Services to you or provide other support services pertaining to the operation of the App. These companies receive only the personal information required in order to provide services, and are not allowed to use that information for anything aside from providing the services.

• We reserve the right to investigate suspected violations of the Terms of Use of the App or illegal, fraudulent or inappropriate behaviour on the App; and to engage in activities needed to protect the rights, property, or safety of ourselves, of our users, or of others. To that end, and to the extent necessary to achieve the forgoing, we may exchange information with other companies and organisations, including but not limited to Supermarkets, our affiliates and partners and law enforcement agencies.

Corporate and Statutory Purposes

• We may transfer our databases containing your personal information if we sell our business or part of it and engage in another similar corporate transaction.

• We will share personal information where we are required to share your personal data in order to comply with any legal obligation.

Modification of the Privacy Policy

Ontrack reserves the right to amend this Privacy Policy anytime without prior notice. You are responsible for regularly viewing of this Privacy Policy. Should you continue to use Hargapedia app, it shall be deemed that you provide consent to such changes.

E. Request deletion of data

If you wish to have your data removed from our platform, you may make simple request by emailing our customer support by clicking this link.

Remove my data

F. Questions or Comments?

If you have any further questions about our Privacy Policy, please refer to our Terms of Use or contact our Customer Support via Hargapedia email. (cs@askhargapedia.com)