Privacy
Policy
JT
International Trading Sdn. Bhd. ("JTI",
"we", "our", "us") respects the privacy of our
consumers.
This Privacy
Policy ("Privacy Policy") (together with our Website Terms of Use and
any other documents referred to in it) sets out how we use and process personal
data of customers of our products and services and other individuals, including
the visitors of our website (www.ploom.my),
online platforms, systems and applications that we are responsible for (our
"Platforms") and accredited users of our Platforms (e.g. mentors and
experts appointed by our contracted agencies) (“you”) in compliance with
applicable data protection laws, in particular, the Malaysia Personal Data
Protection Act 2010 (“Act”). For the purposes of this Privacy Policy, the terms
“personal data” and “process” and/or “processing” shall have the meaning as
prescribed in the Act.
Please read
this Privacy Policy together with any other document or information that we may
provide to you from time to time in relation to specific initiatives and
activities that we may undertake to understand our views and practices
regarding your personal data.
It is
important that the personal data we hold about you is accurate, complete, not
misleading and kept up to date. Please keep us informed if any of your personal
data changes during your relationship with us.
For the purposes
as detailed in section 6 of this Privacy Policy, we may process the following
categories of personal data:
·
Full name;
·
Age;
·
Birthday;
· Contact details (e.g. address, e-mail address and phone number);
·
Information
in relation to our products/services you have purchased or used, including
information about your account, purchase history, orders, customer feedback, market research and other
sales data;
·
Details of
your interactions with us, including service messages and notes of your
communications and conversations with us;
·
Details of
your visit to a retail store or an event, how frequently you visit, which areas
you visit and for how long, and which purchases you make;
·
Details of
whether you have referred a friend to us;
·
Recordings of
your voice that we make and store on our servers when you contact our Ploom Care Team;
·
Personal
preferences and habits in relation to the products and services we provide;
·
Technical
information about the use of our Platforms and contact center, including time
and duration, the Internet Protocol (IP) address used to connect your device to
the Internet, your login information, browser type and version, time zone
setting, traffic data, browser plug-in types and versions, operating system and
platform and information about the use of cookies and tracking technologies.
Strictly necessary cookies will always be switched on and you may also enable
additional cookies as well. For more information on cookies and how to accept
or refuse cookies, please see our Cookies Policy.
·
Marketing and
communications information, including marketing preferences for receiving
marketing communications from JTI and/or third parties.
·
Nickname,
likeness, pseudonym, rights of publicity, live or recorded performance,
autograph, photographs and your biographical information.
·
All other
details provided by you to us from time to time and all other personal data we
again collect from you on any subsequent occasion.
Where you provide financial and credit card information on our
Platforms, please note that we do not access or store this personal data. We
use trusted third parties to process your payment and we have no access to your
financial and credit card information.
We will
identify the categories of personal data that are mandatory to be provided by
you in our forms (collectively, “compulsory personal data”). We may
refuse to process the personal data for any of the purposes specified in this
Privacy Policy if you fail to supply the compulsory personal data.
We may obtain
your personal data from you in a number of ways, including when you:
·
register to
be a member of our databases (including loyalty programs), which will include performing
age verification in person or online;
·
register
directly with us to take part in our business initiatives and activities (e.g.
surveys, offers, competitions, prize draws, campaigns, 14 Day Ploom Trial,
Ploom Club, trade tools etc.) in person or online;
·
use our
Platforms;
·
fill in any
forms on our Platforms, or our associated platforms and micro-sites;
·
register a
device with us;
·
register to
receive email alerts or marketing;
·
participate
in events organized by us;
·
sign up to
the 14 Day Ploom Trial;
· communicate with us via our Ploom Care
Team, our Platforms, phone, e-mail, social media or otherwise (e.g. Trial SMS,
Live Chat etc.). This includes information you provide when you register to use
our Platforms, subscribe to our service, search for a product, place an order
on our Platforms, enter a competition or survey, when you report a problem with
our Platforms and when you post on our social media.
In addition
to obtaining personal data directly from you, we may also collect your personal
data indirectly through the following means:
·
when you use
any of the other platforms that we operate or the other services we provide,
which may be run by our platform providers and their related third parties;
·
from other
third parties we work closely with (including, for example, other JTI group
companies, hosting providers, payment service providers, delivery providers,
retailers, customer services providers, product assistants, loyalty and review
platform providers, customer relationship management services, consumer data
platform providers, marketing automation providers, information services providers, age
verification providers, events organizers, consumer
feedback providers, sub-contractors in technical, payment and delivery
services, analytics providers, search information providers, credit reference
agencies, marketing agencies);
· from our trusted network of agents, customers and partners,
including at events organized by our business partners, retail stores, agents,
experts and mentors, where you interact with them online or offline.
In this Privacy
Policy, we refer to all the methods by which you are in contact with us as
"JTI touchpoints". JTI touchpoints include both physical (for
example, retail outlets and events), and digital (for example, websites).
As mentioned
above, we may collect information about you automatically through the use of
cookies and similar tracking technologies (such as web beacons/pixels) that you
receive when you visit digital JTI touchpoints or get an electronic message
from us. The specific cookies and other mechanisms used will depend on the
touchpoint in question. To learn about these mechanisms used on a JTI
touchpoint, including how you can accept or refuse cookies, please see the
information made available on or through that touchpoint. These mechanisms may
include Google analytics cookies (see
www.google.com/policies/privacy/partners/.)
Where
permitted by law, we may acquire information about you from third parties. This
may include information shared between JTI affiliates, publicly available
profile information (such as your preferences and interests) on third party
social media sites (such as Facebook and Twitter), marketing lists and
supplementary information acquired from third party agencies.
Where
permitted by law, we may infer information about you from information about you
that we already have. For example, we may use aggregated information about
people in certain geographical areas, that we acquire from third parties, to
infer your preferences.
We may also
collect your personal data in other contexts made apparent to you at the time.
Your personal
data is being or is to be collected and further processed by us for the
following purposes:
·
To comply
with our legal obligations to verify your age and only sell age restricted
products to adults.
·
To process and discharge our contractual obligations to you as a buyer
of our products, including fulfilling orders, sending
receipts, processing payments and providing warranty services.
·
To provide sales-related
services including dealing with your queries and requests, general
administration, troubleshooting and corresponding with you. We may also use
your data for administering trial, warranty and loyalty programs.
·
To market our
products and services to you (or provide you with information about third party
products and services) by email, mail, telephone, SMS, social media or other
online platforms.
·
To allow
other third parties to directly contact you with marketing messages.
·
To determine
which of our products and services may be of interest or relevance to you.
·
To personalise your customer experience on our website based
on what we have learned about your interests, preferences and how you use our
Platforms.
·
To undertake
customer surveys and market research.
·
To invite you
to participate in our events.
·
For internal
management and administrative purposes.
· For other purposes authorized by you or directly related or
ancillary to the foregoing.
We may send you direct marketing messages about our products and
services via the communication channels (email, mail, telephone, SMS, social
media or display pop-ups on other online platforms).
We will always provide you with the opportunity to opt-out of
receiving direct marketing communications from us in the future. You can do
this through updating your Contact Preferences in your account, unsubscribing
from email marketing by clicking on the unsubscribe link in the email you
receive, following any opt-out instructions provided in the marketing
communication or contacting us. Please note that it may take up to 30 days for
us to process your request.
Our Platforms
may contain links to other websites of interest. However, once you have used
these links to leave our site, you should note that we do not have any control
over that other website. Therefore, we cannot be responsible for the
protection, security and privacy of any information which you provide whilst
visiting such sites and such sites are not governed by this Privacy Policy. You
should exercise caution and read the privacy policy applicable to the website
in question before proceeding to visiting that website.
We may share your personal data with third parties, where
required, including:
·
with our
third party service providers to support us provide you with our services and
goods, carry out our business operations and comply with our legal obligations
(e.g. hosting providers, payment service providers, delivery providers,
retailers, customer services providers, product assistants, loyalty and review
platform providers, information services providers, age verification providers,
event's organizers, consumer feedback providers, sub-contractors in technical,
payment and delivery services, analytics providers, search information
providers, credit reference agencies, providers of customer relationship
management services, consumer data platform providers, marketing automation
providers, SMS service providers, cloud services and information technology
services).
·
in order to
provide you with a more tailored and effective customer service experience
certain of our service providers may, on a secure basis, pool the information
we provide to them with information provided by other companies to which you
have also provided information. Our service providers analyze this information
and provide technical data which enables you to receive an enhanced customer
experience, including being contacted at times which are most convenient for
you. If you wish to receive further information regarding the information
collected for this purpose, please contact us using the Contact Us Form.
·
with our
trusted network of agents, customers and partners, including retail stores,
agents, experts and mentors.
·
with JTI
group companies to provide you with our services and goods, carry out our
business operations and comply with our legal obligations.
·
if you are
referred as part of one of our referral programs we
will share limited personal identity data with the person who referred you.
·
with
regulatory authorities and government departments where required by law,
including in response to a request from law enforcement authorities or other
government officials.
·
when we
consider disclosure to be necessary or appropriate to prevent physical harm or
financial loss or in connection with an investigation of suspected or actual
illegal activity.
·
in the
context of organizational restructuring.
·
in the event
that we sell or buy any business or assets, in which case we may disclose your
personal data to the prospective seller or buyer of such business or assets.
·
if JTI or
substantially all of its assets are acquired by a third party, in which case
personal data held by it about its customers will be one of the transferred
assets.
· in the event that we need to disclose your personal data to
external professional advisers such as accountants, bankers, insurers, auditors
and lawyers.
Depending on
the nature of the personal data and the purposes of data processing, the
personal data we collect may be transferred from Malaysia to other countries as
part of our standard operations.
Whenever we
transfer your data abroad, we will limit access to your data only to those who
need to see it, process your data in accordance with our internal data
protection standards, protect it appropriately and only transfer information in
compliance with applicable data privacy laws. When data is transferred, we will
require the receiving party to keep your data confidential, delete it when it
is no longer required and act in accordance with this Privacy Policy. Accordingly, your personal data may be transferred
outside of your jurisdiction and you hereby consent to such transfer.
When using
information as described in this Privacy Policy, your personal data may be
transferred either within or outside the country or territory where it was
collected, including to a country or territory that may not have equivalent
data protection standards.
In all cases,
appropriate security measures for the protection of personal data will be
applied in those countries or territories, in accordance with applicable data
protection laws.
Subject to
the Act, you have the following rights:
·
Right to request
access to your personal data.
·
Right to request
correction of your personal data where the personal data is inaccurate,
incomplete, misleading or not up-to-date.
·
Right to object
to processing of your personal data for direct marketing purposes, as referred
to above.
· Right to limit the processing of your personal data including the
right to withdraw consent previously given to us (in full or in part) to the
processing of your personal data, subject to any applicable legal restrictions
and a reasonable duration of time for such notice/request to be effected.
If you wish
to exercise any of the rights set out above, or if you have any inquiries or
complaints in respect of your personal data, please contact us at:
Designation: [to insert designation], Ploom Care TeamPloom Care Team Specialist
Telephone number: 1800 228 338
E-mail address: ploomcare@ploom.my [to insert if there
is any]
We may charge
a reasonable fee to access your personal data. We may refuse to comply with
your request in these circumstances and shall inform you of our refusal and
reasons for our refusal in writing.
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). This is a security measure to ensure that your personal data is
not disclosed to any person who has no right to receive it. We may also contact
you to ask you for further information in relation to your request to speed up
our response.
Any changes
we may make to our Privacy Policy in the future will be posted on this page
and, where appropriate, notified to you by e-mail. Please check back frequently
to see any updates or changes to our Privacy Policy. By continuing to engage
with us after the issuance of such amendment notice, you will be considered as
having agreed to this Privacy Policy (as amended and updated).
In
the event of any inconsistency between the English version and the Bahasa
Malaysia version of this Privacy Policy, the English version shall prevail over
the Bahasa Malaysia version.
UPDATED ON MAY
2024