RIWAY

PRIVACY POLICY

INTRODUCTION

RIWAY INTERNATIONAL GROUP (“RIWAY”) respects and is committed to protect your personal data and privacy. The Personal Data Protection Policy (“Policy”) was formulated to ensure the proper collection, processing, usage and safeguarding of your personal data in compliance with applicable data protection laws.

1. TYPES OF PERSONAL DATA WE PROCESS

    Based on RIWAY’s nature of business, RIWAY may collect from you various types of personal data, including but not limited to your name and identification information such as your NRIC number, passport number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.

2. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

(a)   We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).
(b)  

We may collect and use your personal data for any or all of the following purposes:

  1. Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
  2. Verifying your identity;
  3. Responding to, handling, and processing queries, requests, customer support, applications, complaints, and feedback from you;
  4. Managing your relationship with us;
  5. Processing payment or credit transactions;
  6. Sending you marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, membership and rewards schemes and other promotions;
  7. Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  8. Any other purposes for which you have provided the information;
  9. Transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether within your country or abroad, for the aforementioned purposes; and
  10. Any other incidental business purposes related to or in connection with the above.
(c)  

We may disclose your personal data:

  1. Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
  2. To third party service providers, agents and other organizations we have engaged to perform any of the functions listed in clause 2(b) above for us.
(d)   The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
(e)   By interacting with our services and/or providing us with your personal data, you are deemed to consent to the collection, use, disclose and transfer in order for us to provide you with the service you request.

3. WITHDRAWING YOUR CONSENT

(a)   The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing.
(b)   Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
(c)   Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing.
(d)   Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

4. CONTACT TO SUCH ACCESS AND CORRECT PERSONAL DATA

(a)  

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.:-

Tel No. : (60) 3 7734 5939

Fax No. : (60) 3 7734 5930

Email : [email protected]
(b)   For any inquiries and/or complaints with respect to your personal data should also be channelled to RIWAY in this manner.
(c)   We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the relevant data protection laws).

5. CONSENT

(a)   You may represent and/or warrant that the consent of third parties whose personal data you have provided and disclosed to RIWAY have been sufficiently obtained to allow RIWAY to process the same in relation to the purpose for collection and processing such personal data within your country or abroad.
(b)   RIWAY trust that you will consent and agree to the policy above with respect to the collection, processing, and storage of your Personal Data as described in this policy by RIWAY. Your participation and submission of Personal Data and/or personal information are voluntary, and you have the right to choose whether to provide it. If RIWAY do not received any feedback and/or response from you, RIWAY shall assume that you have given your consent and agreeable to the same.

6. PROTECTION OF PERSONAL DATA

(a)   To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures to secure access, and security review and testing performed regularly.
(b)   You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

7. ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

8. TRANSFER OF PERSONAL DATA

Please note that all our rights herein may be novated, assigned, transferred and/or otherwise dealt with by us and shall ensure to the benefit of our successors, assignees and/or transferees.

9. CROSS BORDER DATA TRANSFER

Please note that we may transfer your personal data to jurisdictions outside of your country including but not limited to RIWAY affiliated companies, entities related to RIWAY organisations, as well as to third-party service providers. When doing so, we ensure adequate protections are in place to comply with the applicable data protection laws.

10. DATA RETENTION

We retain your personal data and/or information as long as necessary or required by law. Retention periods vary based on the type and purpose of information. If legally obligated or for legitimate reasons, we may retain it longer. If you request deletion, we will make reasonable efforts to comply, unless legally obligated or for valid reasons. Anonymised or aggregated data derived from your information may be used for statistical or research purposes. When no longer needed, we securely delete or anonymise your information to prevent unauthorised access or use.

11. EFFECT OF POLICY AND CHANGES TO POLICY

(a)   This 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.
(b)   We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.