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Privacy Policy
Last updated: July 27th, 2023

Introduction To the Privacy Policy

a.     This policy ("Privacy Policy") describes how SP Beauty Technologies Sdn. Bhd. ("Styla``, ''Company ``,''we ``,''us ``,''our ``), a company incorporated and registered in Malaysia manages Personal Data which is in our possession or under our control.

 

b.    "Personal Data", is defined in the Personal Data Protection Act 2010 of Malaysia (“PDPA”), and currently refers to any information in respect of commercial transactions, that relates directly or indirectly to an individual, who is identified or identifiable from that information or from that and other information which is in our possession and includes any sensitive personal data and expression of opinion about the individual.

 

c.     This privacy policy applies to your use of all the mobile applications, products, software, features, services, websites, publications, email subscription and the content thereof, other services, and your relationship with us (collectively, the “Service”) owned or controlled by Styla, or its affiliated companies.

 

d.    By using our services pursuant to your agreement(s) with us ("Services"), accessing the online platform operated by us (which is accessible through our website at http://my-styla.com/ or through our mobile application or Apps) ("Platform"), websites or mobile applications, or otherwise providing information to or communicating with us, you are taken to have agreed to our collection, use, processing and disclosure of your Personal Data in accordance with this Privacy Policy.

 

e.     This Privacy Policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other rights which we may have at law to collect, use, process or disclose your Personal Data.

 

f.     The words "we", "us", "our" or any of their derivatives refer to Styla and its successors and any novatee, assignee, transferee or purchaser of Styla’s rights and/or obligations hereunder and any reference to Styla includes a reference to such successor, novatee, assignee, transferee or purchaser.

 

g.    The words "you", "your'', "yours" or any of their derivatives refer to the person using our Services, accessing our Platform, website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).

 

h.    This Privacy Policy shall be governed by, and construed in accordance with, the laws of Malaysia.

 

i.    Without prejudice to your rights under any applicable laws, any dispute arising out of or in connection with this Privacy Policy and/or the documents referred to herein, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by the Courts of Malaysia and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the Courts of Malaysia.

 

We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of our Service, and we have the right not to provide you with access to our Service.

Types Of Data That We Collect

We collect personal information that you voluntarily provide to us when registering for our Service, expressing an interest in obtaining information about us or our products and services.

 

Personal Data

 

The Personal Data that we collect or may collect include:

 

a. Information that you provide by filling in forms when using the Website or through the Apps or through other means, registering to use the Website and/or the Apps, subscribing to our services, posting material or requesting further services (including but not limited to):

 

  • email address;

  • first and last name;

  • phone number;

  • address, state, zipcode;

  • usage data

 

b. We may also ask you for information when you report a problem with the Website and or the Apps;

 

c. If you contact us we may keep a record of that correspondence;

 

d. Details of your visits to the Website or the Apps including, but not limited to:

 

  • amounts paid;

  • traffic data;

  • location data;

  • practitioner data; 

  • other communication data;

  • the resources that you access

 

e. Information about your visit:

 

  • including the full Uniform Resource Locators (URL) clickstream to, through and from the Website or our App(s) (including date and time); 

  • products you viewed or searched for; 

  • page response times;

  • download errors;

  • length of visits to certain pages;

  • page interaction information (such as scrolling, clicks, and mouse-overs);

  • methods used to browse away from the page;

  • any phone number used to call our customer service number

 

f. Stylist Notes – The stylist may make notes during the service, e.g.-

 

  • whether there are any pets at the premises;

  • your colour preferences;

  • whether you experienced any discomfort during the service.

  • etc. 

 

Usage Data

 

a. Usage Data is collected automatically when using the Service.

 

b. Usage Data may include information such as:

 

  • your Device's Internet Protocol address (e.g. IP address);

  • browser type;

  • browser version;

  • the pages of our Service that You visit;

  • the time and date of your visit;

  • the time spent on those pages;

  • unique device identifiers;

  • other diagnostic data.

 

c. When You access the Service by or through a mobile device, we may collect certain information automatically, including but not limited to:

 

  • the type of mobile device you use;

  • your mobile device unique ID;

  • the IP address of your mobile device;

  • your mobile operating system;

  • the type of mobile Internet browser you use;

  • unique device identifiers;

  • other diagnostic data.

 

d. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

 

e. Device information: Each time you use our Website or our Apps we may also collect information about your device. This may include:

 

  • information on the type of mobile device that you are using;

  • its unique device identifier, for example: -

 

i. the IMEI number;

ii. the device’s mobile phone number;

iii. the MAC address of the device’s wireless network interface or push ID;

iv. the mobile operating system that you are using;

v. mobile network information;

 

f. Information we receive from other sources.

 

g. Client Consultation Forms

 

  • Prior to receiving the service, you have booked (“Service”) you may be asked to complete a consultation form either by the stylist or via electronic communication in which you will be asked for details of any medical conditions.

  • We will store these on behalf of the stylist.

 

Information from Third-Party Social Media Services

 

a. We work closely with third parties including for example:

 

  • business partners;

  • sub-contractors in technical;

  • payment and delivery services;

  • advertising networks;

  • analytics providers;

  • search information providers;

  • we may receive information about you from them;

 

b. In addition to the information we collect as described above, we use technology to collect anonymous information about the use of the Website e.g.:

 

  • our web server automatically logs which pages of our Website our visitors view;

  • their IP addresses;

  • which web browsers our visitors use.

 

c. Our website contains Hyperlinks to other pages on our website to track how often these links are used and which pages on our website our visitors choose to view.

 

d. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators.

 

e. We do not control these websites and are not responsible for their data or privacy practices.

 

f. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data about yourself.

 

g. The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

 

  • Google

  • Facebook

  • Twitter

  • LinkedIn

  • Tik Tok

  • Snapchat

  • WeChat

 

h. If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, we may collect Personal data that is already associated with Your Third-Party Social Media Service's account e.g.:

 

  • Name

  • Email address

  • Activities

  • Contact list associated to the account

 

i. You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account.

 

j. If You choose to provide such information and Personal Data, during registration or otherwise, you are giving the Company permission to:

 

  • Use;

  • Share;

  • Store it in a manner consistent with this Privacy Policy.

 

This technology does not identify you personally, it simply enables us to compile statistics about our visitors and their use of our websites.

 

Information Collected while Using the Application

 

a. While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

 

  • Information regarding your location

  • Pictures and other information from your Device's camera and photo library

 

b. We use this information to provide features:

 

  • Of our service;

  • To improve our service;

  • Customize our service.

 

c. The information may be:

 

  • uploaded to the Company's servers and/or;

  • a Service Provider's server;

  • or it may be simply stored on Your device.

 

d. You can enable or disable access to this information at any time, through Your Device settings.

 

We get information about you in a range of ways including:

 

Information You Give Us.

 

a. We collect information you directly give us on the Service in a variety of ways, including but not limited to:

 

  • when you register for an account;

  • purchase a product or service;

  • participate in a contest;

  • rewards program or other promotion;

  • use the Service to upload, share, or communicate any content or information;

  • publicly post information via links to social media networks, forums, blogs, message boards, chat rooms or similar functionality;

  • when you request customer support;

  • provide feedback;

  • survey responses.

 

Information We Get From Others.

 

a. We may get information about you from other sources, such as:

  • Facebook,;

  • Twitter;

  • Instagram;

  • or other social-media properties.

  • Other users of the Service, including but not limited to marketplace users.

 

We may add this to information we get from this Service.

 

Information Automatically Collected.

 

a. Traffic and usage information generated from your visit to the Service, including:

 

  • traffic data;

  • logs;

  • pages you visit;

  • your device’s unique device identifier;

  • mobile network;

  • browser information;

  • operating system;

  • IP address;

  • cookie information;

  • the type of device that you use to access the Service;

  • any other communication data arising from your access;

  • use of the Service;

 

b. In connection with your visit or use of the Service, we may automatically collect information about our users such as:

 

  • the numbers of users;

  • the frequency of users;

  • their characteristics;

  • information about similar groups of users;

  • certain age groups;

  • users that live in a particular geographical area.

 

This data is only used in the aggregate as a statistical measure and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies and beacons.

 

Information from public databases and third parties

 

a. When you access or use the Service, or any portion thereof, we may collect physical location information that is sufficiently precise to allow us to locate a specific person or device (“Location Information”).

 

b. We only collect Location Information with your permission such as:

 

  • when you agree to provide it to us after you initially access or use the Service.

 

c. We may use Location Information and provide it to third parties to provide you with content and services that are relevant to a particular location, such as:

 

  • Advertising;

  • Search results;

  • Directions

 

d. The Service may access metadata and other information associated with other files stored on your device which may include but not limited to:

 

  • Photographs;

  • audio and video clips;

  • personal contacts;

  • address book information.

 

e. If you do not want us to collect this information, do not download the Service or delete it from your device.

 

f. We also may use these technologies to collect information about your activities over time and across third-party websites, apps or other online services (behavioural tracking).

 

To Summarise: We collect personal information that you provide to us such as name, address, contact information, telephone number, occupation and security data.

Use Of Personal Data

We may use your Personal Data for our business purposes, including the provision and continuing operation of the Platform and the Services provided to you.

 

This includes, the following purposes ("Purposes"):

 

a. To provide, operate, maintain, improve, and promote the Service, and any other information, products or services that you request from us.

 

b. To enable you to access and use the Service, including:

 

  • Uploading;

  • Downloading;

  • Collaborating;

  • Sharing content;

  • Photos;

  • Images;

  • Videos;

  • Information with other users or third parties.

 

c. To process, verify, and carry out transactions, and send you related information, including:

 

  • purchase confirmations and invoices;

  • to carry out our obligations;

  • enforce our rights arising from any contracts entered into between you and us including: -

 

  1. for billing;

  2. collection;

  3. enforcement;

  4. to build a user database.

 

d. To send transactional messages, including:

 

  • responding to your comments, questions, and requests;

  • providing customer service and support;

  • sending you technical notices, updates, security alerts, and support and administrative messages;

  • when we have location information, we use it to tailor our Service for you and others.

 

e. To process and deliver contest entries and rewards.

 

f. To send information including:

 

  • Confirmations;

  • Invoices;

  • Technical notices;

  • Updates;

  • Security alerts;

  • Support and administrative messages.

 

g. To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.

 

h. To monitor and analyse trends, usage, and activities in connection with the Service and for marketing, advertising, administrative, analytical, research, optimization, and other purposes e.g.:

 

  • to measure interest in the various areas of the Service;

  • for development purposes;

  • to inform advertisers and partners in aggregate and anonymous terms about consumers who click on their advertising or other messages.

  • IP addresses are also used for systems administration and troubleshooting purposes.

 

i. Transaction Data

 

  • as used in this Privacy Policy includes: -

 

i. Personal Data which may include:

 

  • your name;

  • email address;

  • billing address;

  • shipping address;

  • payment method information (such as credit or debit card number, bank account information or payment card image selected by you);

  • merchant and location;

  • purchase amount;

  • date of purchase;

  • some information about what you have purchased;

  • your phone number;

  • past purchases

 

j. End User

 

  • provide End User Services where do not act as a service provider or processor to Businesses but instead provide the Services directly to you for your personal use (e.g. Link).

  • Provide more information about our collection, use and sharing of Personal Data in our Privacy Center, including the legal bases which rely on for using (processing) your Personal Data.

 

k. Using Link or Connecting your Bank Account

 

  • We offer you the opportunity to store your payment methods with us so that you can conveniently use it across merchants who are our Business Users.

  • When you opt in to Link, you agree to let us store your Personal Data such as your payment method so that you can more readily make purchases through Link with Business Users of our payment processing Business Services e.g.: -

 

  1. Name;

  2. Contact information;

  3. Payment method details (e.g. card number, cvc, and expiration date));

  4. When you choose to pay with Link, will also collect Transaction Data related to your transactions. 

 

l. If you choose to share bank account information (including for use in Link) with us, we will periodically collect and process your account information e.g.: -

 

  • bank account owner information;

  • account balances;

  • account number and details;

  • account transactions;

  • credentials

 

With your separate permission, will share this Personal Data with Business Users that you choose. You can ask us to stop collecting and sharing this information.   

 

m. With your separate permission, will share contact information with Business Users that you do business with e.g.: -

 

  • shipping address;

  • billing address;

  • phone number

 

n. Payment

 

  • If you are buying goods or services directly from us, receive Transaction Data.

  • For example, when you make a payment to us , we will collect contact information, payment method information, and information about that transaction.

 

o. Identity/Verification Services

 

  • Provide an identity verification service that automates comparing an identity document with your image (e.g., selfie). 

  • You may choose to opt-in to allow us to store that verification for future use across other merchants and/or separately consent to letting us use your biometric data to improve our verification technology.

  • You can also ask us to stop providing you these services.   

 

p. Transactions

 

  • For payment transactions, End User Personal Data is shared with others to enable or “process” the transaction.

  • For example, when you choose to use a payment method for the transaction (e.g. credit card, debit card, buy now pay later, or direct debit), the third-party provider of your payment method will receive Transaction Data that includes your Personal Data.

  • When you use Styla payment wallet, the merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and your bank account information (separate consent form).

  • Please review the privacy policies of your payment method and the merchants who you choose to learn more about their processing of your Personal Data. 

 

q. To link or combine user information with other Personal Data.

 

r. To protect, investigate, and deter against:

 

  • Negligence;

  • Fraud;

  • Theft;

  • Other illegal activities.

 

To Summarise: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

Disclosure And Sharing Of Your Personal Data

We may from time to time disclose and share your Personal Data to our directors, officers, employees, representatives, agents or delegates or any third parties, whether located in Malaysia or otherwise, to carry out the Purposes.

 

We may process or share data based on the following legal basis:

 

a.     Consent

 

  • We may process your data if you have given us specific consent to use your personal information for a specific purpose.

 

b.    Legitimate Interests

 

  • We may process your data when it is reasonably necessary to achieve our legitimate business interests.

 

c.     Performance of a Contract

 

  • Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.

 

d.    Legal Obligations

 

  • We may disclose your information where we are legally required to do so

 

  • We comply with:

 

i. applicable laws and regulations;

ii. governmental requests;

iii. judicial proceeding;

iv. court order;

v. legal process

 

  • Such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

 

e.     Vital Interests

 

  • We may disclose your information where we believe it is necessary to:

 

i. Investigate;

ii. Prevent;

iii. Take-action

 

  • Regarding potential violations of our policies such as:

 

i. suspected fraud;

ii. situations involving potential threats to the safety of any person;

iii. illegal activities;

iv. as evidence in litigation in which we are involved.

 

We may need to process your data or share your personal information in the following situations:

 

a.     Vendors, Consultants and Other Third-Party Service Providers

 

  • We may share your data with:

 

i. third party vendors;

ii. service providers;

iii. contractors;

iv.agents

v. who perform services for us or on our behalf and require access to such information to do that work.

 

  • We may allow selected third parties to use tracking technology on the Service, which will enable them to collect data about how you interact with the Service over time.

 

  • This information may be used for but not limited to:

 

i. analyse and track data;

ii. determine the popularity of certain content;

iii. better understanding online activity.

 

  • Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

 

  • These third parties may have their own privacy policy in place, you are advised to be familiar with their privacy policies.

 

b.    Business Transfers

 

  • We may share or transfer your information in connection with or during negotiations of;

 

i. any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

 

c.     Business Partners

 

  • We may share your information with our business partners to offer you certain products, services or promotions.

 

We only share and disclose your information to departments within Styla, our affiliates, and the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices.

 

We may also disclose your information to:

 

a. auditors, lawyers, advisors, accountants, agents, or other representatives who are under the duty of confidentiality with us;

 

b. any relevant authorities, governmental or otherwise;

 

c. any fraud prevention agencies;

 

d. any central credit reference information systems;

 

e. any other authorized person under the laws of the jurisdiction which are applicable to us

 

To Summarise: We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations

Privacy Rights and Rectification Of Data

Account Information

 

a.     If you would at any time like to review or change the information in your account or terminate your account, you can log into the Service, navigate to Profile and update or revise your user account and other information related to your account or to delete your data.

 

b.    Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases.

 

c.     However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

 

Opting out of email marketing

 

a.     You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below.

 

b.    After unsubscribing, there will still be transactional emails that are necessary for the administration and use of your account (e.g.: order confirmations).

 

Violation of principles

 

a.     If you have reason to believe that we have violated the principles set out in this Policy, we urge you to contact us.

 

b.    You can email us at admin@my-styla.com with your concerns.

 

c.     Upon receipt of such an email, you will receive a response from us within 1 month.

 

d.    We may take longer to resolve if the case is more complex and that there is not enough evidence to back the complaint.

 

e.     If we find that the complaint is justified, we will resolve the matter.

 

To Summarise: You may review, change, or terminate your account at any time.

 

 

Data Retention

 

a.     We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including:

 

  • for the purposes of satisfying any legal, accounting, or reporting requirements.

 

b.    to determine the appropriate retention period for Personal Data, we consider:

 

  • the amount, nature, and sensitivity of the Personal Data;

  • the potential risk of harm from unauthorised use or disclosure of your Personal Data;

  • the purposes for which we process your Personal Data;

  • whether we can achieve those purposes through other means;

  • and the applicable legal requirements.

 

c.     The Company will also retain Usage Data for internal analysis purposes.

 

d.    Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

 

e.     In some circumstances you can ask us to delete your data.

 

f.     In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

To Summarise: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law.

 

 

Transfer Of Your Personal Data

 

a.     Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located.

 

b.    It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

 

c.     Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

 

d.    The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy

 

e.     No transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

 

 

Delete Your Personal Data

 

a.     You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

 

b.    Our Service may give You the ability to delete certain information about You from within the Service.

 

c.     You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information.

 

d.    You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

 

e.     Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure Of Your Personal Data

Business Transactions

 

a.     If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred.

 

b.    We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.


 

Law Enforcement

 

a.     Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

 

 

Other Legal Requirements

 

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

 

a.      Comply with a legal obligation

 

b.      Protect and defend the rights or property of the Company

 

c.       Prevent or investigate possible wrongdoing in connection with the Service

 

d.      Protect the personal safety of Users of the Service or the public

 

e.      Protect against legal liability

Data Protection & Security

a.     The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.

 

b.    While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

 

 

We agree that we:

 

a. will only process your information in accordance with the instructions given by you and in accordance with the PDPA

 

b. will take appropriate measures in terms of management and technical services to protect your information from:

 

  • any processing or usage which is not authorized;

  • the loss or destruction caused by our negligence;

 

c. will not keep your information longer than is reasonably necessary for the fulfilment of the lawful purposes which are permitted by law.

 

 

Security Measures

 

a.     We have implemented physical, electronic, and managerial procedures designed to secure your personal information from:

 

  • accidental loss;

  • unauthorised access;

  • to maintain data security;

  • to correctly use the information we collect online.

 

b.    All information you provide to us is stored on our secure servers behind firewalls.

 

c.     Any payment transactions will be encrypted using SSL technology.

 

d.    The safety and security of your information also depends on you.

 

e.     Where we have given you (or where you have chosen) a password for access to certain parts of the Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

 

 

No Security Guarantees

 

a.     Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through the Service.

 

b.    Any transmission of Personal Data is at your own risk.

 

c.     We are not responsible for circumvention of any privacy settings or security measures we provide.

 

d.    Although we take appropriate measures to safeguard against unauthorised disclosures of Personal Data, we cannot assure you that Personal Data will never be disclosed, altered or destroyed in a manner that is inconsistent with this Privacy Policy.

 

To Summarise: We aim to protect your personal information through a system of organizational and technical security measures.

Children’s Privacies

Under Age

 

a.     Our Service does not address anyone under the age of 18.

 

b.    We do not knowingly collect personally identifiable information from anyone under the age of 18.

 

c.     If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us.

 

d.    If We become aware that We have collected Personal Data from anyone under the age of 18 without verification and parental consent, We will take steps to remove that information from Our servers.

 

e.     If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

 

 

Tracking Technologies

 

a.     We may use one or more of the following tracking technologies, and similar future tracking technologies, to automatically collect information:

 

  • Cookies;

  • Local shared objects;

  • Web beacons;

  • Unique telephone numbers;

  • General log information;

  • Referral information from third-party services.

 

 

Cookies

 

a.     We may log information using "cookies".

 

b.    Cookies are small data files stored on your hard drive by a website.

 

c.     We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on the Service.

 

d.    This type of information is collected to make the Service more useful to you and to tailor the experience with us to meet your special interests and needs.

 

 

Web Beacons

 

a.     Web Beacons, also known as Internet tags, pixel tags, single-pixel GIFS or clear GIFs, link web pages to web servers and their cookies.

 

b.    Web Beacons can be embedded in web pages, videos, or emails, to collect certain types of information from your browser.

 

c.     Check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the content, the IP address of your computer, and the URL of the web page from which the content was viewed.

 

d.    Our Service may contain links to other websites that are not operated by Us.

 

e.     If You click on a third-party link, You will be directed to that third party's site.

 

f.     We strongly advise You to review the Privacy Policy of every site You visit.

 

g.    We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

 

 

Local Shared Objects

 

a.     Local Shared Objects, sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalise your visit.

 

 

“Ad IDs” and Other In-App Tracking Methods

 

a.     There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings.

 

b.    Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activity to a particular app.

 

 

Google Analytics

 

a.     We use Google Analytics (“Google Analytics”), a web analytics service provided by Google Inc. (“Google”).

 

b.    Google Analytics uses “cookies”.

 

c.     The information generated by the cookies about your use of the Service (including your IP address) will be transmitted to and stored by Google.

 

d.    Google will use this information for the purpose of evaluating your use of the Service, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

 

e.     Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

 

f.     Google will not associate your IP address with any other data held by Google.

 

g.    You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this, you may not be able to use the full functionality of the Service.

 

h.    By using the Service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

 

To Summarise: We may collect information, your Personal Data, through cookies on our Platform, website and mobile applications. We use analytics programs such as Google Analytics to manage and improve our websites, mobile applications, the Platform and/or our Services. We may with the help of Google Analytics use your browsing behaviour and prior usage patterns together with any other Personal Data previously provided by you in accordance with this Privacy Policy.

Users from Other Jurisdictions

a.     By using the Service, you acknowledge that you accept the practices and policies outlined in this Privacy Policy

 

b.    You consent to having your data transferred to and processed on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

 

c.     If you do not accept this Privacy Policy, please do not use the Service.

 

d.    The Service is controlled and operated by the Company from Malaysia.

 

e.     If you are not a resident of Malaysia or you are located outside of Malaysia and choose to use the Service or provide information to us, please note that we will transfer the information, including Personal Data, to Malaysia and process it there.

 

f.     Your acceptance of this Privacy Policy, followed by your submission of such information represents your agreement and consent to that transfer.

 

g.    We do not represent or warrant that the Service, or any portion thereof, are appropriate or available for use in any particular jurisdiction.

 

h.    Those who choose to access the Service do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations.

 

i.      You are also subjected to Malaysia export controls in connection with your use of the Service and are responsible for any violations of such controls, including, without limitation, any Malaysia embargoes or other federal rules and regulations restricting exports.

 

j.      We may limit the availability of the Service, in whole or in part, to any person, geographic area or jurisdiction that we choose, at any time and in our sole discretion.

 

 

Third Party Sites

 

a.     Our web sites may contain links to other web sites which are not maintained by us.

 

b.    This Privacy Policy only applies to our websites, mobile applications, the Platform and/or our Services.

 

c.     When visiting these third-party websites, you should read their privacy policies which will apply to your use of the web sites.

 

This Privacy Policy does not apply to third-party web sites which may be linked to our web sites.

 

 

Supply Of Data

 

a.     Except as otherwise provided in this Privacy Policy, we only collect the Personal Data that you provide to us.

 

b.    If you would prefer that we do not collect Personal Data from you, please do not:

 

a.     Provide us with such information;

b.    Use our Services;

c.     Operate any account maintained with us;

d.    Access our Platform, websites or mobile applications.

 

c.     By using our Services, visiting our Platform, websites or mobile applications or otherwise, providing information to, or communicating with us you shall be deemed to have read and provided your consent to our collection, use, processing and disclosure of your Personal Data or Personal Data relating to other persons in the manner as described in this Privacy Policy.

 

d.    You may withdraw your consent to our collection, use, processing and disclosure of the Personal Data for any of the above Purposes, at any time by contacting us via the contact details provided below.

 

e.     If we do not receive any notification from you concerning our collection, use, processing and disclosure of the Personal Data, we shall proceed to continue to process the same for the Purposes as set out above, on the basis that you have consented to our current as well as all our previous collection, use, processing and disclosure of the Personal Data in accordance with this Privacy Policy.

 

f.     Please note that we may not be able to provide you with our Services if you do not provide us with your consent or withdraw your consent to the collection, use, processing and disclosure of the Personal Data for any of the Purposes.

 

g.    Where you provide us with the Personal Data of other individuals, we shall assume, without independent verification, that you have obtained such individual’s consent to our collection, use, processing and disclosure of their Personal Data in accordance with this Privacy Policy.

 

To Summarise: You consent to us collecting, using, processing and disclosing your Personal Data in the manner as described in this Privacy Policy. You may withdraw your consent at any time by contacting us. In the event that you withdraw your consent, we may not be able to provide you with our Services. If you provide us with the Personal Data of other individuals, you will ensure that the individual has given their consent to our collection, use, processing and disclosure of their Personal Data in accordance with this Privacy Policy.

 

 

Policy Updates

 

a.     Our Privacy Policy may change from time to time.

 

b.    We will post any privacy policy changes on this page, for which you will be notified.

 

c.     If you continue to use our Services, access our Platform, websites or mobile applications, and/or otherwise provide information to or communicate with us, you are deemed to have agreed to such changes without reservation.

 

To Summarise: Yes, we will update this policy as necessary to stay compliant with relevant laws. If you continue to use our Services, access our Platform, websites or mobile applications, and/or otherwise provide information to or communicate with us, you will be treated as if you have agreed to the changes.

General Data Protection Regulation (“GDPR”) For Residents of The European Union (“EU”)

a.     This Privacy Policy describes how Styla (“we”) collects, uses and shares your Personal Data.

 

b.    If you are a resident of the EU, you are subject to the GDPR, which became effective on May 25, 2018, and the following terms also apply to you.

 

c.     Styla is the Controller and responsible for your Personal Data.

 

d.    We are based in Malaysia, which is where all of your Personal Data will be processed.

 

 

Lawful Bases to Process Your Personal Data

 

a.     This Privacy Policy describes the Personal Data we collect from you and how we use it. We will only use your Personal Data when the law allows us to.

 

b.    Most commonly, we will use your Personal Data in the following circumstances:

 

  • Where we need to perform the contract we are about to enter into or have entered into with you;

 

  • Where it is necessary for our legitimate interests (or those of a third-party) and your interests and fundamental rights do not override those interests;

 

  • Where we need to comply with a legal or regulatory obligation.

 

c.    You have the right to withdraw consent to marketing at any time by contacting us.

 

d.    We have a lawful basis for processing each type of Personal Data described in this Privacy Policy, which are as follows:

 

  • The lawful basis for collecting your Identity and Contact Data to register you as a new customer is the performance of a contract with you;

 

  • The lawful basis for collecting your Identity, Contact, Financial, Transaction and Marketing and Communications Data to process and deliver your purchases are: -

 

i. the performance of a contract with you;

 

ii. it is necessary for our legitimate interests;

 

  • The lawful basis for collecting your Identity, Contact, Profile, and Marketing and Communications Data to manage a relationship with you are: -

 

i. the performance of a contract with you;

 

ii. it is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

  • The lawful basis for collecting your Identity, Contact, Profile, Usage, and Marketing and Communications Data to enable you to partake in a contest, competition or complete a survey are: -

 

i. the performance of a contract with you;

 

ii. it is necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business);

 

  • The lawful basis to collect your Identity, Contact, and Technical Data to administer and protect our business and the Service is: -

 

i. it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise);

 

  • The lawful basis to collect your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data to: -

 

i. deliver relevant Service content and advertisements to you;

 

ii. measure or understand the effectiveness of the advertising we serve to you;

 

iii. necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy);

 

  • The lawful basis to collect Technical and Usage Data to use data analytics to improve our: -

 

i. Service;

 

ii. Marketing;

 

iii. Customer relationships;

 

iv. Experiences;

 

v. It is necessary for our legitimate interests (to define types of customers for our products and services, to keep our Service updated and relevant, to develop our business and to inform our marketing strategy)

 

  • The lawful basis to collect Identity, Contact, Profile, Usage and Technical Data to make suggestions and recommendations to you about: -

 

i. goods or services that may be of interest to you is that it is necessary for legitimate interests (to develop our products/services and grow our business).

 

e.      do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

 

f.     We do not collect any information about criminal convictions and offences.

 

Note: We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in this Privacy Policy.

 

 

Sharing Your Personal Data

 

a.     We may have to share your Personal Data with the parties set out below for the purposes described in this Privacy Policy.

 

b.    External Third Parties

 

c.     Service providers acting as processors who provide automated marketing services

 

d.    Professional advisers acting as processors including marketing agents, auditors and insurers who provide consultancy and auditing services

 

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

 

 

Data Protection and Security

 

a.     We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

 

b.    In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know.

 

c.     They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

 

d.    We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

 

Data Retention

 

a.     We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

b.    To determine the appropriate retention period for Personal Data, we consider:

 

  • the amount;

  • nature;

  • sensitivity of the Personal Data;

  • the potential risk of harm from unauthorized use or disclosure of your Personal Data;

  • the purposes for which we process your Personal Data;

  • whether we can achieve those purposes through other means, and the applicable legal requirements.

 

c.     In some circumstances you can ask us to delete your data.

 

d.    In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

 

Your Legal Rights under the GDPR

 

Under certain circumstances, EU residents have rights under data protection laws in relation to their Personal Data. If you are an EU resident, you have the right to:

 

a. Request access to your Personal Data.

 

  • This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it;

 

b. Request correction of the Personal Data that we hold about you.

 

  • This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

 

c. Request erasure of your Personal Data.

 

  • This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it.

 

  • You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law.

 

  • Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

 

d. Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

 

e. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

 

f. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

g. Request restriction of processing of your Personal Data.

 

  • This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: -

 

i. if you want us to establish the data's accuracy;

 

ii. where our use of the data is unlawful but you do not want us to erase it;

 

iii. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;

 

iv. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it

 

h. Request the transfer of your Personal Data to you or to a third party.

 

i. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format.

 

  • Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you

 

j. Withdraw consent at any time where we are relying on consent to process your Personal Data.

 

k. Withdrawing will not affect the lawfulness of any processing carried out before you withdraw your consent.

 

l. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

m.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights).

 

n.    This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

 

o.    We may also contact you to ask you for further information in relation to your request to speed up our response.

 

p.    We try to respond to all legitimate requests within one month.

 

q.    Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact Information

We welcome your comments or questions about this privacy policy, You may also contact us at our address:

 

SP Beauty Technologies Sdn Bhd
No. 7A, Jalan Tun Mohd Fuad 3,
Taman Tun Dr Ismail,
60000, Kuala Lumpur.

Telephone: (+60) 3 7728 5188

Email: styla.my@gmail.com

 

 

To Summarise: If you are a resident of the EU, you are subject to the GDPR, which became effective on May 25, 2018, and the following terms also apply to you. You may contact us if you have any questions about this Privacy Policy.

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