KOSÉ (MALAYSIA) SDN BHD PRIVACY POLICY

1. KOSÉ (Malaysia) Sdn Bhd (hereinafter referred to as “KOSÉ”), in compliance with the Malaysian Personal Data Protection Act 2010 (“PDPA”), adopts the following Privacy Policy (“Policy”). This Policy underscores KOSÉ’s efforts and commitment in ensuring that the privacy of the personal data and information provided to us in respect of commercial transactions is maintained in accordance with the principles of the PDPA. This Policy is a legally binding document.
2. Applicability 
   This Policy forms part of KOSÉ’s guidelines relating to the processing of personal data (including sensitive personal data) and is applicable to KOSÉ’s relationship with the persons to which the PDPA applies, including but not limited to our customers, representatives, employees, clients, investors, sponsors, suppliers, event organisers, event managers, promoters, and contractors, contractual or otherwise or other individuals not specifically mentioned. This Policy is a legally binding document to which adherence is ordinarily expected.
3. This Policy regulates the manner by which KOSÉ collects, uses, retains, maintains and discloses personal information including names, telephone numbers, email addresses, office or residential addresses, payment details, and all such personal identification information (hereinafter referred to as “Personal Data”) from each customer or any other data provider in its record. This Policy correspondingly governs the usage of the KOSÉ website and any other social media websites operated by KOSÉ.
4. KOSÉ’s customers and / or data providers are expected to have read and understood the terms of this Policy in its entirety. This Policy is to be read together with and forms an integral part of any contract entered into with KOSÉ.
5. Personal Data 
   The term “Personal Data” is defined by the PDPA as including any information relating to an identified or identifiable natural person. An identifiable person is someone who can be identified, directly or indirectly, in particular by reference to an identification number or the person’s physical, physiological, mental, economic, cultural or social characteristics.
6. Further to the generality of the terms as defined by the PDPA, Personal Data as referred to in this Policy may also relate to any natural persons, including KOSÉ’s customers, representatives, employees, customers, clients, investors, sponsors, suppliers, event organisers, event managers, promoters, and contractors, contractual or otherwise, or other individuals not specifically mentioned (collectively, “Data Subject”).
7. KOSÉ is authorised and shall be at liberty to collect, maintain and, process the following Personal Data from a Data Subject:-

• Personal details such as name, identity card / passport / social security number, age, gender, nationality, birthdates, residential and business addresses, social media website addresses, contact numbers, email address and such other relevant information that identifies the respective Data Subject;
• Information about businesses, trade, or services that the Data Subject is engaged in;
• Payment transactions - either via cheque, credit or debit card, PayPal or online bank transfers;
• All billing records for services, inclusive of any cancellations that have been made;
• Any such other information that are, have been or will be collected by us in future, or such information which the Data Subject provides to KOSÉ in connection to any services or contractual obligation, including data that is collected from any surveys, questionnaires, transactions or any correspondence with KOSÉ;
• Individual personal preferences of the Data Subject such as to the language, product offered or content interest as well as mode of communication;
• The Data Subject’s choice in regards to receiving future communication as to future events or functions or product launches hosted by KOSÉ;
• Any enquiries, comments or messages sent to KOSÉ via KOSÉ website or any other social media websites operated by KOSÉ
• IP address of a Data Subject who visits KOSÉ website, applies and registers for membership, sends queries or uploads posts / comments in any other social media operated by KOSÉ

• For the performance of a contract to which you are a party;
• At your request, with a view to entering into a contract with KOSÉ;
• For compliance with any legal obligation to which KOSÉ is subject, other than an obligation imposed by a contract;
• To protect your vital interests; or
• For the administration of justice; or
• For the exercise of any functions conferred on any person by or under any law.

• Applications for KOSÉ membership;
• Updates received from a Data Subject with regards to their personal details or any change therein, including a change of address;
• Enquiries and registrations for KOSÉ events or functions or product launches, or promotional events;
• Visits to KOSÉ website and/or any of KOSÉ’s social media webpages;
• Registrations with KOSÉ and/or its event organisers for events or functions or product launches whether online or manually;
• Any transaction or inquiry or communication made with KOSÉ;
• When such personal data is collected by promoters, event managers, event organisers or any associates of KOSÉ in the course of any event, function, meeting or any marketing, expansion and promotional activities; and
• Contracts of/for service or services entered into with KOSÉ.

• To communicate with you about membership, inquiries or other requests;
• To respond to your queries including queries relating to KOSÉ products;
• For administrative purposes, including but not limited to commercial transactions relating to billing and payment;
• To monitor and improve KOSÉ’s services;
• For direct marketing services;
• To update and provide information on promotions and upcoming events or functions or product launches to you;
• To conduct research, surveys and statistical analysis;
• To send emails on updates or on any event that may be of interest to you;
• For the performance of a contract to which you are a party;
• For compliance with any legal obligation to which KOSÉ is subject.

• KOSÉ’s partners, trusted affiliates, promoters, event organisers, researches, and advertisers as part of the efforts to conduct statistical analysis of current or future global trends as well for marketing, advertising and promotional purposes of future products, and/or events;
• Third party service providers which helps operate KOSÉ and its website; as well as all other social media websites operated for and on behalf of KOSÉ and/or administer activities on KOSÉ’s behalf, such as to send out newsletters and/or emails, to conduct text messaging blasting and/or surveys; and
• KOSÉ’s legal representatives, accountants, auditors, consultants, promoters, event organisers and such other service providers in the conduct and administration of its affairs.

• KOSÉ to disclose, maintain, share and transfer your Personal Data for the purposes above; and
• Be included in KOSÉ’s mailing list and agree to receive such information from KOSÉ and its affiliates, associates or any event organiser appointed by KOSÉ.

• Such Personal Data of the Data Subject shall be stored in KOSÉ’s database unless the Data Subject serves a written Notice to KOSÉ requesting for such Personal Data to be destroyed and deleted from KOSÉ database;
• KOSÉ will take reasonable measures to ensure sufficient security measures are taken to protect the Personal Data; and
• The Data Subject has a choice as to whether they wish to receive any future correspondence from KOSÉ with regards to future marketing or promotional information.
• It will be the responsibility of the Data Subject to inform KOSÉ as to whether they wish to remain on the mailing list. Failure to give such notice will be deemed as consent to receiving future correspondence from KOSÉ, its affiliates and associates.

• Request for a copy of the Personal Data maintained by KOSÉ;
• Request to either update your Personal Data submitted to KOSÉ;
• Request that KOSÉ modifies or amends your respective Personal Data in our records.

KOSÉ (Malaysia) Sdn. Bhd. 1st September 2020