Last Updated: Version 1.0

1.

PRIVACY POLICY
1.1 In this policy, “we”, “us”, “our” or “TAS” means Trinity App Studio Sdn. Bhd., its related corporations, affiliates, and “you”, “your” or “yours” means the persons to whom this policy applies.
1.2 Please take a moment to familiarise yourself with this policy that covers how we collect, use, disclose, transfer, and store your personal information. Please note that nothing in this policy shall vary or supersede the terms and conditions that govern our relationship with you.
1.3 This policy applies only to our website at www.trinityappstudio.com (the “Website”) and/or the TAS mobile application and we are not responsible for the privacy practices of any other website or application not operated by us.
1.4 Our Website and our TAS mobile application may use a "click-through URL" linked to content on external websites operated by third parties such as our business partners. We are not responsible for the privacy practices of such websites operated by other parties that are linked to our Website and our TAS mobile application. If you access such websites through our Website and our TAS mobile application, you should read and familiarise yourself with the privacy policies applicable to such third party websites, which may be different from how they will handle any personal information they may collect from you.

2.

PERSONAL INFORMATION
2.1 “Personal information” is information that can be used to identify a natural person. Some examples of personal data that we may collect (depending on the nature of your interaction with us) are:
  		• personal particulars (e.g. name, identity card number, passport number, contact numbers, email addresses, gender, residential address and date of birth);
  		• transactional information based on your activities on our Website and/or the TAS mobile application (such as buying or receiving virtual currency and items to other parties and other content you may generate or that relates to your account with us);
  		• additional information we ask you to submit to authenticate yourself or if we believe you are violating site policies (for example, we may ask you to send us an ID or bill to verify your address, or to answer additional questions online to help verify your identity or ownership of an account);
  		• information about your use of the Website and/or the TAS mobile application and related services, including cookies, Internet Protocol (“IP”) address and account details;
  		• discussions, chats, dispute resolution, correspondences through the Website and/or the TAS mobile application;
  		• precise location data, including the real-time geographic location of your computer or device. Where available, location-based services may use Global Positioning System, wireless networking technologies and your Internet Protocol (“IP”) address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your computers’ or devices' approximate location; and
  		• personal opinions made known to us (e.g. feedback or responses to surveys).
    2.2 Please note that we are the data owner in respect of all personal information you provide or is made available about you when you interact with our Website and/or our TAS mobile application. Your customer relationship on the use of the Website and/or the TAS mobile application is with Trinity App Studio Sdn. Bhd., which processes your personal information in accordance with Personal Data Protection Act of Malaysia and other applicable data protection and privacy laws and regulations.

    3.

    PERSONAL INFORMATION COLLECTION AND USE
    3.1 Generally, we collect personal information on our users in the following ways:
  		• when you sign up for an account with us through the Website or the TAS mobile application;
  		• when you register or make a transaction on the Website or the TAS mobile application;
  		• when you respond to our request for further personal information about you when interacting with our customer service officers through telephone, email or other means of communication;
  		• when you consent to your devices’ location data being sent to us through the use of the Website and/or the TAS mobile application;
  		• when you contact us or request that we contact you for assistance;
  		• when you respond or our request for feedbacks or surveys;
  		• when you request to be included in our marketing communications;
  		• when you respond to our promotions and other marketing initiatives; or
  		• when you disclose any personal information to us for any other reason
    Once you register with us, you are not anonymous to us. Information regarding the usage of our Website and/or our TAS mobile application may also store information about your mobile phone configuration such as your IP address, location, where you have executed transactions stored within the application, screens viewed within the mobile application, cookie information and the parts of the Website and/or the TAS mobile application accessed.
    3.2 When you send items to a third party such as family members and friends, or invite others to participate in our related services, we may collect the personal information you provide about those people. You represent and warrant that the consent of such third party has been obtained for the collection and use of such information in accordance with this policy.
    3.3 We may use personal information collected provided by you for the following purposes:
  		• processing your application for your account with us, and maintenance of such account;
  		• keeping you updated on our announcements, software updates, policy updates, changes to the relevant terms and conditions with us and upcoming events;
  		• communicating with you on marketing activities and responding to any queries, responses or complaints from you;
  		• creating, developing, operating, delivering and improving our services, content and advertising;
  		• developing processes and technologies for loss prevention and prevention, detection and investigation of crimes, including fraud and money laundering;
  		• customizing and displaying content which may be of interest to you on the Website or in the TAS mobile application and to match offers to your preferences;
  		• for verification of identity, assisting with identification of users, and to determine appropriate services;
  		• for delivery of important notices, such as communications about changes to our terms, conditions and policies;
  		• for handling complaints and disputes and the conduct of relevant investigations and proceedings;
  		• for internal purposes such as risk assessment, auditing, data and statistical analysis, and research;
  		• protecting and enforcing our legal rights and obligations;
  		• managing our business operations and to comply with internal policies and procedures;
  		• if you enter into a contest or similar promotion, we may use the personal information to administer those programmes; and
  		• to comply with any applicable laws, regulations, codes and/or guidelines;
  		• to assist in law enforcement and investigations by relevant authorities; and
  		• if you are a corporate, in communicating with your staff regarding any of the above.

    4.

    DISCLOSURE OF PERSONAL INFORMATION COLLECTED
    4.1 We will not, without your permission, distribute or sell personal information provided by you to any unaffiliated third party, except under the following circumstances:
  		• for the purposes of providing products or services that you have requested or purchased;
  		• monitoring products and services provided by or made available through the Website and the TAS mobile application;
  		• providing the personal information to third-party service providers under contract who help with our business operations: We may employ other companies and individuals to perform functions on our behalf. Examples include payment processing for purchases of vouchers, sending marketing e-mails and short message services, analyzing data, providing marketing assistance, investigating frauds and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes;
  		• for the purposes of sharing personal information with companies who provide services including, but not limited to, information processing, managing and enhancing customer data, providing customer service, assessing your interest in our services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your personal information in accordance with applicable data protection and privacy laws;
  		• if required by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence for us to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate;
  		• responding to queries or feedback;
  		• addressing or investigating any complaints, claims or disputes;
  		• enforcing obligations owed to us;
  		• seeking professional advice, including legal advice;
  		• complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
  		• financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
  		• we may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.
    4.2 Where your personal information is to be disclosed to any third party, we shall do so in compliance with all applicable laws on data privacy, and we will require such third parties to ensure that any personal information disclosed to them are kept confidential and secure.
    4.3 For the avoidance of doubt, if we have reasonable grounds to believe that you are in breach of any of the terms of this policy, we reserve the right, in our sole and absolute discretion, to cooperate fully with governmental authorities, private investigators, all the rightful owner(s) or interest holder(s) and/or injured third parties in the investigation of any potential or on-going criminal or civil wrong doing.
    4.4 Further, we may disclose your identify and contact information, or such other transaction-related data, if requested by a government or law enforcement body, private investigator, rightful owner or interest holder and/or any injured third party or as a result of a subpoena or other legal action, or if we are of the view, in our sole and absolute discretion, that it would be in our best interest to do so. We shall not be liable for damages or results arising from such disclosure, and you agree not to bring action or claim against us for such disclosure.

    5.

    MARKETING
    5.1 We may also use your personal information to offer you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to:
  		• electronic mails;
  		• short message service;
  		• telephone calls;
  		• other mobile messaging services; and/or
  		• through the Website and/or the TAS mobile application.
    In doing so, we will comply with the Personal Data Protection Act of Malaysia and other applicabledata protection and privacy laws.
    5.2 In respect of sending telemarketing messages to your telephone number via short message service, telephone calls and other mobile messaging services, we shall only do so if we have your clear and unambiguous consent in writing or other recorded form to do so or if you have not otherwise made the appropriate registration of that number with the Do Not Call Registry.

    6.

    WITHDRAWAL OF CONSENT
    6.1 You may withdraw your consent to our collection of your personal information or request that we stop contacting you for marketing purposes at any time by notifying us via email or call to the email address and phone number located under the section below. In that event, we will not be able to identify you and provide you with a safe, smooth, efficient and customized experience while using our Website and our TAS mobile application. As such, your account will be suspended upon withdrawal of your consent and your access to services under the Website and the TAS mobile application will be restricted, including the ability to purchase or redeem vouchers.
    6.2 You agree and acknowledge that any withdrawal of your consent our collection of your personal information will not affect any consent you may have provided to us in respect of the use of your telephone number for marketing purposes unless you specifically request that we stop contacting you for marketing purposes.

    7.

    INTEGRITY AND RETENTION OF PERSONAL INFORMATION

    7.1 We make it easy for you to keep your personal information accurate, complete and up to date. We will retain your personal information for the period necessary to fulfil the purposes outlined in this policy unless a longer retention period is required or permitted by law.
    7.2 We hold personal information using a combination of secured electronic data storage facilities as well as paper based filings and records. We endeavour to protect your personal information and any personal information we no longer require would be destroyed or have particulars or information which may identify individuals removed.

    8.

    ACCESS TO PERSONAL INFORMATION
    8.1 You can help ensure that your contact information and preferences are accurate, complete, and up to date by accessing your account details under [“Account Settings”] in the TAS mobile application. For other personal information we hold, we will provide you with access for any purpose including to 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.
    8.2 We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

    9.

    COLLECTION AND USE OF NON-PERSONAL INFORMATION
    9.1 We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
  		• We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, and location where our Website and our TAS mobile application is used so that we can better understand customer behaviour and improve our services and advertising; and
  		• We may collect information regarding customer activities on our Website and our TAS mobile application. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our Website and our TAS mobile application and services are of most interest. Aggregated data is considered nonpersonal information for the purposes of this policy.
    9.2 If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

    10.

    COOKIES
    10.1 Our Website and our TAS mobile application, email messages, and advertisements may use "cookies" and other technologies such as pixel tags and web beacons. We use these technologies to help us in the following:
  		• Track information such as number of users, frequency of use, profile of users and their preferred website;
  		• better understand user behaviour;
  		• tell us which parts of our Website and our TAS mobile application people have visited;
  		• make our Website and TAS mobile application easier to use and to customize products and services according to users’ interests and needs;
  		• facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non-personal information. However, to the extent that IP addresses or similar identifiers are considered personal information, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this policy; and
    10.2 We use cookies and other technologies in mobile advertising services to control the number of times you see a given advertisement, deliver advertisements that relate to your interests, and measure the effectiveness of advertisement campaigns.
    10.3 We also use cookies and other technologies to remember personal information when you use our Website and our TAS mobile application.
    10.4 As is true of most internet services, we gather some information automatically and store it in log files. This information includes IP addresses, browser type and language, internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data
    10.5 We use this information to understand and analyse trends, to administer our Website and our TAS mobile application, to learn about user behaviour on our Website and our TAS mobile application, to improve our services, and to gather demographic information about our user base as a whole. We may use this information in our marketing and advertising services.
    10.6 In some of our messages pushed through our Website and our TAS mobile application, we may use a "click-through URL" linked to content on external websites. When users of our Website and our TAS mobile application click one of these URLs, they pass through a separate web server before arriving at the destination page on such other websites. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in such electronic messages.
    10.7 Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

    11.

    ACCOUNT INFORMATION
    11.1 You can:
  		• change your account information at any time by changing the details through the Website or the TAS mobile application or by contacting us; or
  		• terminate your account for the Website and the TAS mobile application by e-mailing contact@trinityappstudio.com and requesting that we delete your account. You will not be able to purchase, receive or redeem any electronic items once your account has been deleted. By agreeing to terminate your account without first receiving any item intended to be send to you, redeeming any outstanding item or transferring any such outstanding item to any person, you agree not to hold us responsible for any loss or damage arising from such termination, and you agree not to bring action or claim against us in connection with such termination. Any information that may have been collected during your use of the our Website and/or the TAS mobile application may remain after your account has been permanently deleted for aggregated reporting and analysis, but this information may not be used to uniquely identify you.
    11.2 However, you acknowledge and agree that we reserve the right to send you certain communications relating to our Website and our TAS mobile application, such as service announcements, administrative messages and service notifications that are considered part of your account and you will not be able to opt-out of receiving the foregoing messages and notifications.

    12.

    CHANGES TO THIS POLICY
    12.1 This policy forms part of the Terms & Conditions for use of our Website and our TAS mobile application and forms part of the agreement between you and us.
    12.2 We may update this policy from time to time, in whole or in part, in our sole discretion. Any changes to this policy will be effective immediately upon the posting of the revised policy on our Website and our TAS mobile application.
    12.3 By continuing to use our Website and/or our TAS mobile application following any changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this policy, as it may be amended from time to time, in whole or part, you must terminate your use of our Website and/or our TAS mobile application.
    12.4 We will notify you about significant changes in the way we treat personal information by sending a notice to the email address specified in your account or by placing a prominent notice on our Website and our TAS mobile application.

    13.

    CUSTOMER SERVICE
    13.1 If you have any questions or concerns regarding this policy, please feel free to contact us at contact@trinityappstudio.com.

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