PRIVACY POLICY

(LAST UPDATED AS AT 12.08.2022)

This Privacy Policy sets out the basis which we, O Psych Sdn. Bhd. may collect, use, disclose or otherwise process the Personal Data (defined below) from our users.

For the avoidance of doubt, when the terms “you”, “your” or “yours” are used in this Privacy Policy, they refer to our users. When the terms “us”, “our” or “we” are used in this Privacy Policy, they refer to O Psych Sdn. Bhd.

We collect, use, disclose and process your Personal Data in accordance with the Malaysia Personal Data Protection Act 2010 in connection with your access and use of the services offered by us through the relevant mobile application made available for download (“app”), our website at [app.o- psych.com] or any other applications or software we provide from time to time, including but not limited to O Psych App (collectively known as the “Platform”).

This Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of organisations which we have engaged to collect, use, disclose or process Personal Data for the purpose provided in this policy.

By accessing and using the Platform, you affirm that you have read this Privacy Policy, as may be amended, supplemented and/or updated from time to time, and that you understand, agree and acknowledge all the terms and conditions contained herein.

If you do not agree to be bound by the terms of this Privacy Policy, you shall stop accessing and/or using the Platform and/or any other services connected thereto immediately.

1.

COLLECTION AND PROCESSING OF PERSONAL DATA

We hereby inform you that we (O Psych, ‘Website’, ‘O Psych App’), O Psych Sdn Bhd (312942-K) may collect, record, hold, store, use, disclose and/ or process one or all of the following categories of personal information about you: –

(i)

General and Demographic information: name, gender, age, nationality, occupation;

(ii)

Contact details: email address;

(iii)

Other information, e.g.: mental health or condition, or any other sensitive personal data as prescribed by the law;

(iv)

Other information you voluntarily provide through free text input forms, multiple type questionnaires, chats or other means; and

(v)

Any such information as we deem necessary or appropriate from time to time in connection with your commercial relationship with us.

(collectively referred to as “Personal Data”)

2.

SOURCES OF INFORMATION

Your Personal Data will be obtained from the following sources, where applicable, or such other sources which we see fit from time to time:

(i)

Information provided or submitted by you through among others, the use and/or access of our Platform;

(ii)

Information gathered through promotional activities;

(iii)

Cookies that your web browser store on your computer or phone when you visit a website;

(iv)

As applicable, publicly available or publicly accessible information; and

(v)

Such other information you provided to us through free text input forms, multiple type questionnaires, chats or other means in the course of using our Platform.

3.

PURPOSE OF PROCESSING PERSONAL DATA

We will process the Personal Data you have provided to us for the following purposes, which include but are not limited to:

(i)

Manage and verify your account and identity;

(ii)

Deliver notices, services or products to you;

(iii)

Enable us to provide our services and perform our services;

(iv)

Notify you about the benefits and changes to the services offered;

(v)

Improve our services;

(vi)

Maintain records required for security, claims or other legal purposes;

(vii)

Develop, market and communicate to you in relation to products and services offered by us;

(viii)

Contact you for product or customer satisfaction surveys and market research;

(ix)

Conduct statistical analysis and run machine learning algorithms and create a data pool so that we can better understand our client’s profile and improve our services to you;

(x)

Conduct research, analysis, data and development activities, including but not limited to data analytic, surveys, product and service improvements and development, analysis relating to application usage;

(xi)

Produce data, reports and statistic which have been anonymised or aggregated in a manner that does not identify you as an individual;

(xii)

Disclose to third party of whom we have contracted to provide services to us (such as analysis on our behalf) for any of the purposes as described above. We ensure that any such data is used only to provide services to us when we disclose your Personal Data to third parties.

(xiii)

Comply with any applicable laws, regulations, codes of practices, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and

(xiv)

Fulfil any other incidental business purposes related to or in connection with the above.

4.

DISCLOSURE

We may engage other companies, service providers or individuals or any third party to perform functions on our behalf and consequently may provide access to disclose your Personal Data to the third party such as those listed below (this list not exhaustive):

(i)

Information technology service providers;

(ii)

Data entry service providers;

(iii)

Regulatory and governmental authorities in order to comply with any statutory and government requirements;

(iv)

Potential buyer or transferee in the event of any re-organisation, sale, joint venture or disposal of our business or any part thereof;

(v)

Pursuant to a court order of a competent jurisdiction;

(vi)

Our subcontractors, agencies, third party service or product providers as may be determined to be necessary or appropriate.

5.

TRANSFER OF PERSONAL DATA OUTSIDE OF MALAYSIA

We may require to transfer your personal information outside of Malaysia in the course of our business. However, we will to our best endeavours ensure that the Personal Data will be protected at a standard that is compatible to that under the PDPA of that country.

6.

SECURITY MEASURES TO PROTECT PERSONAL DATA

We will keep all personal data confidential and endeavour to implement the appropriate administrative and security safeguards and procedures in accordance with the applicable laws and regulations to prevent the unauthorized or unlawful processing of personal data and accidental loss or destruction of, or damage to, personal data.

7.

RETENTION OF PERSONAL DATA

We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected or as required or permitted by applicable laws.

We will cease to retain your Personal Data, or remove the means by which the Personal Data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected and is no longer necessary for legal, regulatory or business purpose or for such time obligated by laws.

8.

ACCESS AND CORRECTION OF PERSONAL DATA

You have the right to request access to and/or correct your Personal Data and/or limit the Processing thereof. In this respect, you may:

(i)

Check whether we hold or use your Personal Data and request access to such data;

(ii)

Request that we correct any of your Personal Data that is inaccurate, incomplete or out-of-date;

(iii)

Withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period.

Please note that depending on the information requested and where permitted by law, a nominal administrative fee may be charged. We will endeavour to provide the information back to you as soon as practicable; however, we also reserve the right to validate all requests for the authenticity of the request. We may refuse to comply with data access requests in circumstances as provided by the law.

However, we have the right to deny access to personal information and data at our discretion:

(i)

That access to this information will pose a serious threat to the life, health or safety of the individual involved or any other individual;

(ii)

Is against an order of court;

(iii)

the request for information is frivolous or vexatious; in which case the individual will be asked for a reason for the need to access this information.

Your written request should be addressed to:
O Psych Sdn Bhd
Address: A-23-4 Kiaramas Sutera. No 7 Jalan Desa
Kiara. KL 50480
Contact No.: +60169926306
Attention: Hetal Doshi
Email Address: [email protected]

9.

YOUR CONSENT

By giving us the Personal Data, you are giving us consent to collect, use and disclose Personal Data under the terms of this Privacy Policy and any relevant policy and data protection laws in Malaysia. If you do not wish to give us consent, then please do not use any of the electronic forms in our Platform.

10.

EFFECTS OF NOTICE AND CHANGES TO NOTICE

This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.

We reserve all rights to amend, supplement and/or update this Privacy Policy from time to time without prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of the Platform constitutes your acknowledgment and acceptance of such changes.