PRIVACY POLICY.

INSPIRENOW SDN BHD PRIVACY POLICY

SWIFT values your privacy. This Privacy Policy sets out how INKA Creative Sdn Bhd collect, store and handle personal information (as defined below) of individuals in accordance with the Personal Data Protection Act 2010 (“PDPA”) and the laws of Malaysia. Please read this Privacy Policy to understand how we use the personal information we may collect from you. By providing your Personal Information to us, you are consenting to this Privacy Policy and the collection, use, access, transfer, storage and processing of your personal information as described in this Privacy Policy.

This Privacy Policy explains:

• Types of personal information we collect
• Methods we use to collect your personal information
• How we use your personal information
• When we disclose your personal information
• Your right to access and correct your personal information

What if I need more space?

SWIFT offers upgrades as add-ons. Please get in touch with your Dedicated Account Manager for more details.

The Definition of Personal Information

Personal information refers to any information which relates directly or indirectly to you. This includes any information that can be used to distinguish, identify or contact you. For the purposes of this Privacy Policy, personal information encompasses sensitive personal information which relates to information regarding your health, political opinions, religious beliefs, etc. For the avoidance of doubt, please note that this Privacy Policy is applicable only if you are a natural individual residing in Malaysia, as SWIFT is under the jurisdiction of Malaysian courts.

Scope of This Privacy Policy

This Privacy Policy is incorporated into the SWIFT Terms of Service and applies to the information we obtain through your use of the Service. Capitalised terms used in this Privacy Policy and not otherwise defined shall have the meanings provided for those terms in the Terms of Service.

Our Commitment To You

We are committed to protecting your personal information. To ensure that you can make informed decisions confidently about supplying your Personal Information to us when using InspireNow Sdn Bhd websites, Products and/or Services, we provide you with this Privacy Policy outlining our practices and the choices you have concerning how your Personal Information is being collected and used by us.

The Personal Information That SWIFT Collects

In the course of serving its customers, SWIFT acquires, stores, and transmits customer communications and information that customers may regard as private or sensitive. Some of this information – such as the customer’s name, address, telephone number, and credit card data – is provided to SWIFT by its customers in order to establish service. Other information – such as the customer’s account status, choice of services, and customer logs – is created and maintained by SWIFT in the normal course of providing service. SWIFT also uses cookies, which are small pieces of information that a website can store in a designated file on a user’s computer for various reasons. In addition, SWIFT may store customers’ e-mail and other communications as a necessary incident to the transmission and delivery of those communications. SWIFT also records how you use the Products and/or Service (for example the website that you are hosting and emails that are being sent out or receive) and the calls you made to our Account Managers or any of SWIFT's full-time employees for our service enhancement and improvement.

How We Collect Your Personal Information

We may collect personal information directly from you when you:-

a. communicate with us (for example when you submit an application form to become our customer, or when you contact us for any enquiries including but not exclusively by calling our customer service)
b. register or subscribe for a specific Product and/or Service
c. use Products and/or Services of INKA Creative Sdn Bhd
d. participate in any of our surveys
e. enter into or participate in any competitions, contests or loyalty programmes run/organised by us
f. commence a business relationship with us (for example, as a service provider/business partner)
g. visit our office
h. visit or browse our websites
i. lodge a complaint with us
j. provide feedback to us (for example via our websites or in hard copy)

Other than personal information obtained from you directly (as detailed above), we may also obtain your personal information from third parties/affiliates we deal with and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted.

Our Commitment To Data Security

SWIFT will protect the confidentiality of its customers’ information, account information and personal communications to the fullest extent possible and consistent with the law and the legitimate interests of SWIFT, its partners, its employees and other customers of SWIFT services. To protect the loss, misuse, and alteration of information that is collected from customers, SWIFT has appropriate physical, electronic, and managerial procedures in place.

Online Actions With SWIFT

Cookies
SWIFT collects information about your use of our websites through cookies. Cookies are packets of information stored on your computer that assist your website navigation by customising site information to your needs. Cookies only identify the computers used. You are not obliged to accept cookies. If you are concerned, you can set your computer either to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time. Please note that rejection of cookies may affect your use of our websites as we will be unable to personalise aspects of your use of the website.

Links to Third Party Websites
Please be informed that this Privacy Policy applies solely to INKA Creative Sdn Bhd Websites and does not apply to any third party websites you may access from our websites. To determine how they deal with your Personal Information, you should ensure that you read their respective privacy policies.

How We Use Your Personal Information

We may collect and use personal information from you or from the category of third parties identified in this Privacy Policy, for one or more of the following purposes:-

• to provide you with the Products and/or Services you have requested
• to verify your identity (and/or your customer status with us)
• to assess and process your application(s) /request(s) for our Products and/or Services
• to administer and manage the Products and/or Services we provide you (including charging, billing, facilitating payments and collecting debts)
• to investigate and resolve any service issues, billing queries, complaints, or other enquiries that you submit to us regarding our network, Products and Services with our team
• to assess and/or verify credit worthiness
• to detect and prevent fraudulent activity
• to keep in contact with you and provide you with any information you have requested and information we deem as important to you
• to engage in business transactions in respect of Products and/or Services to be offered and provided to you
• to establish and better manage any business relationship we may have with you
• to process any communications you send us (for example, answering any queries and dealing with any complaints and feedbacks)
• to help us monitor and improve the performance of our Products and Services, our employees and INKA Creative Sdn Bhd Websites and to make these more efficient
• to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems
• to manage staff training and quality assurance
• to notify you about benefits and changes to the features of our Products and/or Services
• to determine how can we improve services to you
• to produce data, reports and statistics which shall be anonymised or aggregated in a manner that does not identify you as an individual
• to investigate, respond to, or defend claims made against, or involving INKA Creative Sdn Bhd.
• to conduct marketing activities (for example, market research)
• to maintain records required for security, claims or other legal purposes
• to comply with legal and regulatory requirements for any other purposes that are required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities

From time to time, SWIFT may send its customers information about various products and services that may be of interest. We will not send you information of this type without specifically allowing you to “opt out” of such mailings. You can opt out by sending an e-mail to support@swift.com, however by doing so, you may miss important communication regarding your service.

Disclosure of Your Personal Information

As a part of providing you with our Products and/or Services and the management and/or operation of the same, we may be required or need to disclose information about you to the following third parties:-

• law enforcement agencies
• government agencies
• companies and/or organisations that act as our agents, contractors, service providers and/or professional advisers
• companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions and providing you with Products and/or Services that you have requested or subscribed for
• our business associates and other parties for purposes that are related to the purpose of collecting and using your personal information
• other parties in respect of whom you have given your express or implied consent

Note that the personal information you provide us is subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to INKA Creative Sdn Bhd.

Your Rights To Correct Your Personal Information

SWIFT is able to assist you to access and correct your personal information held by us, by your request. Where you wish to have access to your personal information in our possession, or where you are of the opinion that such personal information held by us is inaccurate, incomplete, misleading or where relevant, not up-to-date, you may make a request to us by email or any means of communication media with your Dedicated Account Manager. You should quote your name, address and phone/account number and provide brief details of the information you want a copy of in any such request. We will use reasonable efforts to comply with your request to access or correct your personal information within a period of time which we would relay to you upon receiving your request.

Please note that we may have to withhold access to your personal information in certain situations, for example when we are unable to confirm your identity or where the information requested for is of a confidential commercial nature or in the event we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.

Your Responsibilities

You are responsible for providing accurate and complete information to us about yourself and any other person whose personal information you provide us and for updating this personal information as and when it becomes incorrect or out of date by emailing us at support@swift.com or through the Dedicated Account Manager we assigned to you. This obligation is a condition to the provision of our Products and/or Services to you and/or any other person authorised or permitted by you or your organisation/company to use the Products and/or Services. In the event you may need to provide us with personal information relating to third parties (for example about your spouse or children or where you are the designated person in charge (from an organisation or company) for dealing with us, if you are acquiring and are responsible for a service and/or product that they will use), you confirm that you have:-

a. their consent or otherwise entitled to provide their personal information to us and for us to use accordingly, and
b. informed them to read this Privacy Policy on SWIFT's website.

Disclosure of Your Information and Communications

Unless SWIFT has reason to believe that disclosing such information is necessary to identify, make contact with, or bring legal action against someone who may be causing harm or interfering with the rights or property of SWIFT, SWIFT customers, or others, or where SWIFT has a good faith belief that the law requires such disclosure, SWIFT will not disclose its customers’ personal and account information.

SWIFT also will not, except for reasons stated below, disclose to third parties the contents of any e-mail or other electronic communications that SWIFT stores or transmits for its customers. The circumstances under which SWIFT will disclose such electronic customer communications are when:-

a. it is necessary in order to provide service to the customer;
b. it is necessary to protect the legitimate interests of SWIFT and its customers;
c. it is required to cooperate with interception orders, warrants, or other legal processes that SWIFT determines in its sole discretion to be valid and enforceable; and
d. it is necessary to provide to a law enforcement agency when the contents are inadvertently obtained by SWIFT and appear to pertain to the commission of a crime.

SWIFT disclaims any intention to censor, edit or engage in ongoing review or surveillance of communications stored on or transmitted through its facilities by customers or others. SWIFT will, however, review, delete or block access to communications that may harm SWIFT, its customers or third parties. The grounds on which SWIFT may take such action include, but are not limited to, actual or potential violations of SWIFT policies.

Updates To Our Privacy Policy

As SWIFT evolves, we may need to update this Policy to keep pace with changes in the Service, our business and laws governing us and you; we will, however, continue to respect your privacy. We will post any revisions to this Policy, along with their effective dates, in an easy to find area of our web site, so we recommend that you check our website for information on our most up-to-date practices. The updated version of our Privacy Policy shall apply and supersede any and all previous versions, including but not limited to hard copy versions.

Contact Us

Contact Us SWIFT welcomes your feedback regarding this Privacy Policy. Please contact us by email at support@swift.com or through the Dedicated Account Manager we assigned to you. Should you wish, you may also mail SWIFT at:

INKA Creative Sdn Bhd
21-05, The Vertical Office Suites, Tower A, 59200 Kuala Lumpur.