Policies

This Privacy Policy describes how www.primero.my (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site. At www.primero.my, your privacy is a top priority. Every effort is made to protect the security of your personal data against unauthorized access, use and disclosure by applying appropriate measures and processes.

Collecting Personal Information

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Device information

  • Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
  • Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
  • Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
  • Disclosure for a business purpose: shared with our processor.

Order information

  • Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number.
  • Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
  • Source of collection: collected from you.
  • Disclosure for a business purpose: shared with our processor and with other vendors for the purpose of processing payments (payment gateways), shipping and fulfillment (logistic arrangements) etc.

Consent

When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to us for collecting it and using it for that specific reason only. However, if after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at the following “Contact Us” section.

Minors

The Site is not intended for individuals under the age of 16. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

  • We may use your Personal Information to proceed with your order or reply to your enquiry as described above.
  • We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
  • We may, at times, disclose your personal information to companies and organizations whose products are distributed through or featured in primero.my for the purpose of administering any prize draws, sales campaign, competition or any collaboration with legitimate parties.

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

  • GOOGLE- We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
  • FACEBOOK, INSTAGRAM OR SOCIAL MEDIA PLATFORM- We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
  • THIRD-PARTY LINKS- When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work .

You can opt out of targeted advertising by:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use cookies to optimize your experience on our Site and to provide our services.

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at info@primaniaga.my or by mail using the details provided below:

Prima Niaga Group Sdn. Bhd.
15th Floor, Unit 8, Tower 2, Faber Towers,
Jalan Desa Bahagia, Taman Desa,
58100 Kuala Lumpur KUL, Malaysia.

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: [http://www.pdp.gov.my/index.php/my/]

Overview

This website is operated by PRIMA NIAGA GROUP SDN. BHD. (PNGSB). Throughout the site, the terms “we”, “us” and “our” refer to PNGSB. PNGSB offers this website, including all information, tools and services available from this site to you, the user, conditioned upon your acceptance of all terms, conditions, policies and notices stated here.

By visiting our site and/ or purchasing something from us, you engage in our “Service” and agree to be bound by the following terms and conditions (“Terms of Service”, “Terms”), including those additional terms and conditions and policies referenced herein and/or available by hyperlink. These Terms of Service apply to all users of the site, including without limitation users who are browsers, vendors, customers, merchants, and/ or contributors of content.

Please read these Terms of Service carefully before accessing or using our website. By accessing or using any part of the site, you agree to be bound by these Terms of Service. If you do not agree to all the terms and conditions of this agreement, then you may not access the website or use any services. If these Terms of Service are considered an offer, acceptance is expressly limited to these Terms of Service.

Any new features or tools which are added to the current store shall also be subject to the Terms of Service. You can review the most current version of the Terms of Service at any time on this page. We reserve the right to update, change or replace any part of these Terms of Service by posting updates and/or changes to our website. It is your responsibility to check this page periodically for changes. Your continued use of or access to the website following the posting of any changes constitutes acceptance of those changes.

Section 1 - Online Store Terms

By agreeing to these Terms of Service, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

You may not use our products for any illegal or unauthorized purpose nor may you, in the use of the Service, violate any laws in your jurisdiction (including but not limited to copyright laws).

You must not transmit any worms or viruses or any code of a destructive nature.

A breach or violation of any of the Terms will result in an immediate termination of your Services.

Section 2 - General Conditions

We reserve the right to refuse service to anyone for any reason at any time.

You understand that your content (not including credit card information), may be transferred unencrypted and involve (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices. Credit card information is always encrypted during transfer over networks.

You agree not to reproduce, duplicate, copy, sell, resell or exploit any portion of the Service, use of the Service, or access to the Service or any contact on the website through which the service is provided, without express written permission by us.

The headings used in this agreement are included for convenience only and will not limit or otherwise affect these Terms.

Section 3 - Accuracy, Completeness and Timeliness of Information

We are not responsible if information made available on this site is not accurate, complete or current. The material on this site is provided for general information only and should not be relied upon or used as the sole basis for making decisions without consulting primary, more accurate, more complete or more timely sources of information. Any reliance on the material on this site is at your own risk.

This site may contain certain historical information. Historical information, necessarily, is not current and is provided for your reference only. We reserve the right to modify the contents of this site at any time, but we have no obligation to update any information on our site. You agree that it is your responsibility to monitor changes to our site.

Section 4 - Modifications to The Service and Prices

Prices for our products are subject to change without notice.

We reserve the right at any time to modify or discontinue the Service (or any part or content thereof) without notice at any time.

We shall not be liable to you or to any third-party for any modification, price change, suspension or discontinuance of the Service.

Section 5 - Products or Services (If Applicable)

Certain products or services may be available exclusively online through the website. These products or services may have limited quantities and are subject to return or exchange only according to our Return Policy.

We have made every effort to display as accurately as possible the colors and images of our products that appear at the store. We cannot guarantee that your computer monitor's display of any color will be accurate.

We reserve the right, but are not obligated, to limit the sales of our products or Services to any person, geographic region or jurisdiction. We may exercise this right on a case-by-case basis. We reserve the right to limit the quantities of any products or services that we offer. All descriptions of products or product pricing are subject to change at anytime without notice, at the sole discretion of us. We reserve the right to discontinue any product at any time. Any offer for any product or service made on this site is void where prohibited.

We do not warrant that the quality of any products, services, information, or other material purchased or obtained by you will meet your expectations, or that any errors in the Service will be corrected.

Section 6 - Accuracy of Billing and Account Information

We reserve the right to refuse any order you place with us. We may, in our sole discretion, limit or cancel quantities purchased per person, per household or per order. These restrictions may include orders placed by or under the same customer account, the same credit card, and/or orders that use the same billing and/or shipping address. In the event that we make a change to or cancel an order, we may attempt to notify you by contacting the email and/or billing address/phone number provided at the time the order was made. We reserve the right to limit or prohibit orders that, in our sole judgment, appear to be placed by dealers, resellers or distributors.

You agree to provide current, complete and accurate purchase and account information for all purchases made at our store. You agree to promptly update your account and other information, including your email address and credit card numbers and expiration dates, so that we can complete your transactions and contact you as needed.

For more detail, please review our Returns Policy.

Section 7 - Optional Tools

We may provide you with access to third-party tools over which we neither monitor nor have any control nor input.

You acknowledge and agree that we provide access to such tools ”as is” and “as available” without any warranties, representations or conditions of any kind and without any endorsement. We shall have no liability whatsoever arising from or relating to your use of optional third-party tools.

Any use by you of optional tools offered through the site is entirely at your own risk and discretion and you should ensure that you are familiar with and approve of the terms on which tools are provided by the relevant third-party provider(s).

We may also, in the future, offer new services and/or features through the website (including, the release of new tools and resources). Such new features and/or services shall also be subject to these Terms of Service.

Section 8 - Third-party Links

Certain content, products and services available via our Service may include materials from third-parties.

Third-party links on this site may direct you to third-party websites that are not affiliated with us. We are not responsible for examining or evaluating the content or accuracy and we do not warrant and will not have any liability or responsibility for any third-party materials or websites, or for any other materials, products, or services of third-parties.

We are not liable for any harm or damages related to the purchase or use of goods, services, resources, content, or any other transactions made in connection with any third-party websites. Please review carefully the third-party's policies and practices and make sure you understand them before you engage in any transaction. Complaints, claims, concerns, or questions regarding third-party products should be directed to the third-party.

Section 9 - User Comments, Feedback and Other Submissions

If, at our request, you send certain specific submissions (for example contest entries) or without a request from us you send creative ideas, suggestions, proposals, plans, or other materials, whether online, by email, by postal mail, or otherwise (collectively, 'comments'), you agree that we may, at any time, without restriction, edit, copy, publish, distribute, translate and otherwise use in any medium any comments that you forward to us. We are and shall be under no obligation (1) to maintain any comments in confidence; (2) to pay compensation for any comments; or (3) to respond to any comments.

We may, but have no obligation to, monitor, edit or remove content that we determine in our sole discretion are unlawful, offensive, threatening, libelous, defamatory, pornographic, obscene or otherwise objectionable or violates any party’s intellectual property or these Terms of Service.

You agree that your comments will not violate any right of any third-party, including copyright, trademark, privacy, personality or other personal or proprietary right. You further agree that your comments will not contain libelous or otherwise unlawful, abusive or obscene material, or contain any computer virus or other malware that could in any way affect the operation of the Service or any related website. You may not use a false email address, pretend to be someone other than yourself, or otherwise mislead us or third-parties as to the origin of any comments. You are solely responsible for any comments you make and their accuracy. We take no responsibility and assume no liability for any comments posted by you or any third-party.

Section 10 - Personal Information

Your submission of personal information through the store is governed by our Privacy Policy.

Section 11 - Errors, Inaccuracies and Omissions

Occasionally there may be information on our site or in the Service that contains typographical errors, inaccuracies or omissions that may relate to product descriptions, pricing, promotions, offers, product shipping charges, transit times and availability. We reserve the right to correct any errors, inaccuracies or omissions, and to change or update information or cancel orders if any information in the Service or on any related website is inaccurate at any time without prior notice (including after you have submitted your order).

We undertake no obligation to update, amend or clarify information in the Service or on any related website, including without limitation, pricing information, except as required by law. No specified update or refresh date applied in the Service or on any related website, should be taken to indicate that all information in the Service or on any related website has been modified or updated.

Section 12 - Prohibited Uses

In addition to other prohibitions as set forth in the Terms of Service, you are prohibited from using the site or its content: (a) for any unlawful purpose; (b) to solicit others to perform or participate in any unlawful acts; (c) to violate any international, federal, provincial or state regulations, rules, laws, or local ordinances; (d) to infringe upon or violate our intellectual property rights or the intellectual property rights of others; (e) to harass, abuse, insult, harm, defame, slander, disparage, intimidate, or discriminate based on gender, sexual orientation, religion, ethnicity, race, age, national origin, or disability; (f) to submit false or misleading information; (g) to upload or transmit viruses or any other type of malicious code that will or may be used in any way that will affect the functionality or operation of the Service or of any related website, other websites, or the Internet; (h) to collect or track the personal information of others; (i) to spam, phish, pharm, pretext, spider, crawl, or scrape; (j) for any obscene or immoral purpose; or (k) to interfere with or circumvent the security features of the Service or any related website, other websites, or the Internet. We reserve the right to terminate your use of the Service or any related website for violating any of the prohibited uses.

Section 13 - Disclaimer of Warranties; Limitation of Liability

We do not guarantee, represent or warrant that your use of our service will be uninterrupted, timely, secure or error-free.

We do not warrant that the results that may be obtained from the use of the service will be accurate or reliable.

You agree that from time to time we may remove the service for indefinite periods of time or cancel the service at any time, without notice to you.

You expressly agree that your use of, or inability to use, the service is at your sole risk. The service and all products and services delivered to you through the service are (except as expressly stated by us) provided 'as is' and 'as available' for your use, without any representation, warranties or conditions of any kind, either express or implied, including all implied warranties or conditions of merchantability, merchantable quality, fitness for a particular purpose, durability, title, and non-infringement.

In no case shall PNGSB, our directors, officers, employees, affiliates, agents, contractors, interns, suppliers, service providers or licensors be liable for any injury, loss, claim, or any direct, indirect, incidental, punitive, special, or consequential damages of any kind, including, without limitation lost profits, lost revenue, lost savings, loss of data, replacement costs, or any similar damages, whether based in contract, tort (including negligence), strict liability or otherwise, arising from your use of any of the service or any products procured using the service, or for any other claim related in any way to your use of the service or any product, including, but not limited to, any errors or omissions in any content, or any loss or damage of any kind incurred as a result of the use of the service or any content (or product) posted, transmitted, or otherwise made available via the service, even if advised of their possibility. Because some states or jurisdictions do not allow the exclusion or the limitation of liability for consequential or incidental damages, in such states or jurisdictions, our liability shall be limited to the maximum extent permitted by law.

Section 14 - Indemnification

You agree to indemnify, defend and hold harmless PNGSB and our parent, subsidiaries, affiliates, partners, officers, directors, agents, contractors, licensors, service providers, subcontractors, suppliers, interns and employees, harmless from any claim or demand, including reasonable attorneys’ fees, made by any third-party due to or arising out of your breach of these Terms of Service or the documents they incorporate by reference, or your violation of any law or the rights of a third-party.

Section 15 - Severability

In the event that any provision of these Terms of Service is determined to be unlawful, void or unenforceable, such provision shall nonetheless be enforceable to the fullest extent permitted by applicable law, and the unenforceable portion shall be deemed to be severed from these Terms of Service, such determination shall not affect the validity and enforceability of any other remaining provisions.

Section 16 - Termination

The obligations and liabilities of the parties incurred prior to the termination date shall survive the termination of this agreement for all purposes.

These Terms of Service are effective unless and until terminated by either you or us. You may terminate these Terms of Service at any time by notifying us that you no longer wish to use our Services, or when you cease using our site.

If in our sole judgment you fail, or we suspect that you have failed, to comply with any term or provision of these Terms of Service, we also may terminate this agreement at any time without notice and you will remain liable for all amounts due up to and including the date of termination; and/or accordingly may deny you access to our Services (or any part thereof).

Section 17 - Entire Agreement

The failure of us to exercise or enforce any right or provision of these Terms of Service shall not constitute a waiver of such right or provision.

These Terms of Service and any policies or operating rules posted by us on this site or in respect to The Service constitutes the entire agreement and understanding between you and us and govern your use of the Service, superseding any prior or contemporaneous agreements, communications and proposals, whether oral or written, between you and us (including, but not limited to, any prior versions of the Terms of Service).

Any ambiguities in the interpretation of these Terms of Service shall not be construed against the drafting party.

Section 18 - Governing Law

These Terms of Service and any separate agreements whereby we provide you Services shall be governed by and construed in accordance with the laws of Malaysia.

Section 19 - Changes to Terms of Service

You can review the most current version of the Terms of Service at any time at this page.

We reserve the right, at our sole discretion, to update, change or replace any part of these Terms of Service by posting updates and changes to our website. It is your responsibility to check our website periodically for changes. Your continued use of or access to our website or the Service following the posting of any changes to these Terms of Service constitutes acceptance of those changes.

Section 20 - Contact Information

Questions about the Terms of Service should be sent to us at info@primaniaga.my.

Mobile App Privacy Policy

Effective Date: 16 March 2022

Updated: 1 June 2023

Prima Niaga Group Sdn. Bhd. and subsidiaries (“we”, “us”, “our”, “Prima Niaga Group Sdn. Bhd.”) are committed to protecting your privacy. This Privacy Policy (“Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of the following services, products, and related mobile applications (collectively, the “Products”):

· Primero Mobile Application

Before you use our Products, please carefully read through this Policy and understand our purposes and practices of collection, processing of your Personal Data, including how we use, store, share and transfer Personal Data. In the Policy you will also find ways to execute your rights of access, update, delete or protect your Personal Data.

When you accept this Policy when you register with your Personal Data, or if you start to use our Products and does not expressly object to the contents of this Policy, we will consider that you fully understand and agree with this Policy. If you have any question regarding this Policy, please do not hesitate to contact us via:

Prima Niaga Group Sdn. Bhd.

privacy@primaniaga.my

Definition

In this Policy, Personal Data means information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other information we have access to about that individual.

Personal Sensitive Data includes personal biometric information, communication records and contents, health information, transaction information, and precise location information. When we collect Personal Sensitive Data from you, we will generate an explicit notification for your consent before we collection personal sensitive data about you.

Smart Devices refers to those computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.

Apps refers to those mobile applications developed by Prima Niaga Group Sdn. Bhd. that provides end users remote control to Smart Devices and with the ability to connect to the supplier IoT Platform.

What Personal Data Do We Collect

In order to provide our services to you, we will ask you to provide necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide you with our products or services.

1. Information You Voluntarily Provide Us

  • Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.
    If you authorize login to the Products with a third party account, we will obtain from such third party your account information (such as portrait, nickname, region, gender, etc.) which may be bound with your Prima Niaga Group Sdn. Bhd. account for quick login. We will ensure compliance with applicable data protection laws and regulations, as well as agreements, policies or documentations agreed with such third party regarding sharing personal information, in processing your Personal Data.
  • Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.
  • Information based on additional functions: In order to offer you with more convenient and higher-quality Services with optimized user experiences, we may collect and use certain information if you consent to use additional functions in the App. Please note, if you do not provide such information, you may continue to use basic Services of the App and connected Smart Devices, but certain features based on these additional functions may not be available. These additional functions may include:
    1. Additional functions based on location information:
      When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to enable these functions, such as pairing with your Smart Devices. Also, we may collect information about your real-time precise or non-precise geo-location when you use certain Smart Devices or the Services, such as robot cleaner and weather service.
      Based on your consent, when you enable the geo-fence feature, your location information will be generated and shared with Google Maps services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details: https://privacy.google.com/businesses/gdprservices/. You may reject such use of your location information by managing the permission settings in the Services, upon which we will cease to collect and use your location information.
    2. Additional services based on camera:
      You may use the camera to scan the code by turning on the camera permission to pair with a Smart Device, take video, etc. Please be aware that even if you have agreed to enable the camera permission, we will only obtain information when you actively use the camera for scanning codes, video recording, etc.
    3. Additional services for accessing and uploading pictures/videos based on photo albums (picture library/video library):
      You can use this function to upload your photos/pictures/videos after turning on the photo album permission, so as to realize functions such as changing the avatar, reporting device usage problems by providing photo proofs, etc.. When you use the photos and other functions, we will not recognize this information; but when you report a device usage problem, we may use the photos/pictures you upload to locate your problem.
    4. Additional services related to microphone-based service:
      You can use the microphone to send voice information after turning on the microphone permission, such as shooting videos, waking up the voice assistant, etc. For these functions, we will collect your voice information to recognize your command. Please be aware that even if you have agreed to enable the microphone permission, we will only obtain voice information through the microphone when you voluntarily activate the microphone in the App.
    5. Additional services based on storage permissions:
      The purpose is to ensure the stable operation of the App by utilizing the storage permission. After you give or indicate the permission to read/write your mobile device’s storage, we will access pictures, files, crash log information and other necessary information from your mobile device’s storage to provide you with functions, such as information publications, or record the crash log information locally.
      Please note that if you turn on any permission, you authorize us to collect and use relevant personal information to provide you with corresponding Services. Once you turn off any permission, we will take it as canceling the authorization, and we will no longer continue to collect Personal Data based on the corresponding permissions, and the related functions may be terminated. However, your decision to turn off the permission will not affect the previous collection and use of information based on your authorization.

2. Information We Collect Automatically

  • Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.
  • Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.
  • Log Information: When you use our app, the system and exception log may be uploaded.
    Please note that one cannot identify a specific individual by using Device Information or Log Information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such non-personal information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will anonymize and desensitize such non-personal information.
  • Location Information: When you enable location-based functions through permission settings on your mobile device, we will collect and process your location information to enable certain functions, such as pairing with your Smart Devices. Also, we may collect information about your real-time precise or non-precise geo-location when you use our specific Products or Services, such as Smart Gateway, IP camera & etc.
    Based on your consent, when you enable the geo-fence feature on the Products, your location information will be generated and shared with Google Map services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details: https://privacy.google.com/businesses/gdprservices/ . You may reject such use of your location information by managing the permission settings in the Products, upon which we will cease to collect and use your location information.

3. Smart Devices Related Information:

  • Basic Information of Smart Devices: When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.
  • Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with our Products or Services, we may collect different information reported by your Smart Devices. For example: smart scales or fitness trackers may report your height, weight, body fat content (BFM) , Body mass index (BMI) and skeletal muscle content (SMM); Whether integrated third-party health analysis functions, such as Apple Health, Google Health, etc. Please note that when you actively agree to enter the Primero and the application is connected to the Apple Health app, we will share your measurement data with Apple Health (including only your BMI, height, weight and body fat% data). The purpose of sharing data is only to measure and analyze health-related indicators related to you, and it will never be disclosed to other third parties. You can close at any time by managing the HealthKit settings page. Primero. The application is authorized to connect with Apple Health; For example, smart cameras may collect images or videos taken by them.

Purposes and Legal Basis for Processing Personal Data

The purpose for which we may process information about you are as follows:

  • Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested or purchased. The legal basis for this processing is to perform our contract with you according to our Terms of Use.,
  • Improve Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
  • Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. At the same time, we will also send you notifications related to the services you have purchased, such as alert services. You can check the [App Notification] in the App to manage these communications. When you decide not to enable the Notifications function, we will no longer process your information for such purpose. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
  • Marketing Communication: We may process your Personal Data to provide marketing and promotional materials to you on the Services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature. If you do not agree to Prima Niaga Group Sdn. Bhd. sending you marketing communications, you may opt out when you enter the App, or by changing your preferences in [Privacy Settings] of the App. The legal basis for this processing is your consent.
  • Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of the Services. If you do not allow us to process your Personal Data for personalization, you may opt out when you enter the App, or by changing your preferences in [Privacy Settings] in the App. The legal basis for this processing is your consent.
  • Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

If there is any change in the purposes for processing your personal data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

Who do we Share Personal Data with?

At Prima Niaga Group Sdn. Bhd., we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:

  • To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.
  • To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our Sites and Services.
  • To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your Personal Data, and choices you may have regarding your Personal Data.
  • As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • To subsidiaries or affiliates within our corporate family, to carry out regular business activities.
  • Except for the third parties described above, to third parties only with your consent.

International Transfer of Information Collected

Prima Niaga Group Sdn. Bhd. will comply with applicable data localization requirements in corresponding jurisdictions with respect to storage of data. To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence. When we do so, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:

Agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46. For more information, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en .

If you would like further detail on the safeguards we have in place, you can contact us directly as described in this Privacy Policy.

Your Rights Relating to Your Personal Data

We respect your rights and control over your Personal Data. You may exercise any of the following rights:via the privacy office email address privacy@primaniaga.my , or via the route of Feedback imbedded in the App: Me&rt;Personal Center&rt;Account and Security&rt;, etc.

You do not have to pay a fee and we will aim to respond you within 30 days. If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

You may:

  • Request access to the Personal Data that we process about you;
  • Request that we correct inaccurate or incomplete Personal Data about you;
  • Request deletion of Personal Data about you;
  • Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;
  • Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and
  • Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.
  • Withdrawal of consent: We will exercise your privacy right to withdraw consent through the following approaches:
    1. For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notifications and other related functions;
    2. In the marketing communications that you agree to, the information we send to you contains instructions that allow you to withdraw your consent in accordance with the “unsubscribe” method described in the information;
    3. Unbind the Smart Device through the app, and the information related to the Smart Device will not be collected;
    4. By using product with the visitor mode, we will not collect any personal data about you;

When you withdraw your consent or authorization, we may not be able to continue to provide you with the products or services correspondingly. However, your withdrawal of your consent or authorization will not affect the processing of personal information based on your consent before the withdrawal.

Security

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Prima Niaga Group Sdn. Bhd. provides various security strategies to effectively ensure data security of user and device. As for device access, Prima Niaga Group Sdn. Bhd. proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing privacy@primaniaga.my

Data Retention

We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.

Children’s Privacy

Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13) (or such other age provided by applicable law in your country/region of residence), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from anyone under the age of thirteen (13) unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from anyone under the age of thirteen (13) without permission from that child’s parent or legal guardian, we will take steps to remove that information.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any questions about our practices or this Privacy Policy, please contact us as follows:

Prima Niaga Group Sdn. Bhd.
Postal Mailing Address: 15-08, Tower 2, Faber Towers, Jalan Desa Bahagia, Taman Desa, 58100 Kuala Lumpur, Malaysia.
Email: info@primaniaga.my

Mobile App User Agreement

Welcome to Prima Niaga Group Sdn. Bhd.

Before accepting the Agreement, you are supposed to thoroughly read all contents of the Agreement, and fully know its terms, especially restrictive clauses or exceptions. Restrictive clauses or exceptions are bold or highlighted in other forms to catch your attention. In case of any doubt for the terms of the Agreement, please contact relevant business department of Prima Niaga Group Sdn. Bhd. You are not allowed to use the service before you have read and accepted all terms of the Agreement, relevant agreements and rules, etc. Once you select "agree and submit the Agreement" (see registration page for detailed wordings) and complete the registration procedure, or you use the service in any form, it will be deemed that you have read and agreed with the restriction of the Agreement and rules above. In case of any breach of the Agreement, Prima Niaga Group Sdn. Bhd. has the right to unilaterally restrict, suspend or terminate the service for you, and has the right to investigate your relevant responsibilities.

The Service Agreement (hereinafter referred to as "the Agreement") is signed by you and Prima Niaga Group Sdn. Bhd.. It includes (but not limited to) Prima Niaga Group Sdn. Bhd. Privacy Policy and other contents. In case of change, Prima Niaga Group Sdn. Bhd. will announce by means of the licensed software sending a message without further notification. Upon announcement, the changed agreement and rules become a part to the Agreement automatically, without further notification to you for your consent. In case of objection to such relevant changes, stop use Prima Niaga Group Sdn. Bhd.'s service; if you keep using it, it will deemed as that you hold no objections against the changed rules and agree to abide by them.

I. Definitions of Terms

  1. Licensed software refers to software system developed by Prima Niaga Group Sdn. Bhd., downloaded and installed and applied in specified system mobile terminals.
  2. Services refer to services provided for you by Prima Niaga Group Sdn. Bhd. and its suppliers. You can use such services on the mobile terminal with the licensed software.

II. Service

  1. Prima Niaga Group Sdn. Bhd. offers you intelligent life equipment management services, based on which you can access the intelligent terminals on Prima Niaga Group Sdn. Bhd. and its suppliers' smart platform through the Prima Niaga Group Sdn. Bhd. Control, and realize interlinkage among intelligent equipment. Service contents include intelligent equipment management, scene interlinkage and analysis report, etc. Such functions may be optimized or modified according to changes of users' demands or judgment of service supplier, and service supply may be suspended due to regular and irregular maintenance.

III. Scope of Service

  1. Prima Niaga Group Sdn. Bhd. grants you with the right to use the product based on this software.
  2. You are prohibited to license, sell, lease, transfer, issue the product in any form, or use the product for other commercial purpose.
  3. Due to limitations on software adaptation platform and terminals, you can only use the licensed software in the authorized system platform and terminal; if you install the licensed software on other terminal equipment, it may damage your hardware or software function.
  4. You acknowledge that the licensed software can only be used for non-commercial purpose and installation, application and running of the licensed software is prohibited. If such commercial operation is necessary, prior written authorization and permission from Prima Niaga Group Sdn. Bhd. shall be obtained.
  5. Prima Niaga Group Sdn. Bhd. and its suppliers may change, upgrade or transfer the licensed software or relevant functions from time to time, and may add new functions or services in the licensed software system. If no separate agreements are accompanied with the aforesaid new functions or services, you are entitled to the corresponding functions and services, which is also subject to the Agreement.
  6. You shall be responsible for the accuracy, reliability, integrity and legality of input data and legality of the way in which you obtain the data, and shall back up data and information from time to time. You shall bear all risks for damage and loss of such information.
  7. You shall properly keep your account number and password. In case of any safety loophole for your account (including but not limited to divulgence of user password), you shall notify Prima Niaga Group Sdn. Bhd. in time, and Prima Niaga Group Sdn. Bhd. will assist you in taking relevant measures. Otherwise, all behaviors related to your account shall be assumed by you and you will bear all responsibilities.

IV. A Third Party

  1. You acknowledge that certain service of Prima Niaga Group Sdn. Bhd. and its suppliers is based on software or services provided by a third party. Such service is set to facilitate your application and necessary legal authorization is obtained from the third party.
  2. The product includes certain information and services of the third party. Prima Niaga Group Sdn. Bhd. and its suppliers neither controls nor bears responsibility for information and services of the third party.
  3. You acknowledge that Prima Niaga Group Sdn. Bhd. and its suppliers cannot guarantee that the licensed software always uses or contains such services, or that other software provided by the same third party will be used in future. Likewise, it may use similar services supplied by another third party. Upon application, the aforesaid corresponding software or services are subject to this Agreement.

V. Service Application Standard

  1. You shall use the licensed software in a normal manner. The following ways are in breach of the application standard:
    1. Issue or share computer virus, worms, malicious codes, or software that deliberately damages or changes computer system or data;
    2. Collect information or data of other users without authorization, for example, email address and the like;
    3. Maliciously use the product in an automatic way, causing over load to the server, or interfere with or damage web server and network links in other forms.
    4. Attempt to visit server data or communication data of the product without authorization;
    5. Interfere with or damage the production application by other users.
  2. You understand and agree that:
    1. Prima Niaga Group Sdn. Bhd. will determine whether or not you are involved in violation of standards above, and suspend or terminate your application license according to determination results or take other restrictions according to agreements.
    2. Prima Niaga Group Sdn. Bhd. will directly delete information in breach of laws, or infringing others' legal rights, or in breach of the Agreement issued by you when using the licensed software.
    3. If a third party suffers from damage due to your breach of application standards, you shall independently bear legal responsibility in your name, and protect and indemnify Prima Niaga Group Sdn. Bhd. from losses or additional expenses generated therefrom. Otherwise, Prima Niaga Group Sdn. Bhd. has the right to claim compensation.
    4. If Prima Niaga Group Sdn. Bhd. and its suppliers suffers from any loss due to your breach of relevant laws or the Agreement, you shall compensate Prima Niaga Group Sdn. Bhd. and its suppliers for losses and (or) expenses generated therefrom.

VI. Information Content Standard

  1. You promise that you will not conduct any act in breach of laws or improper behaviors by using the service, such act and behavior include (but not limited to):
    1. Uploading, transferring or sharing information containing one of the following contents:
      1. Opposing the basic principles determined in the Constitution;
      2. Endangering state safety, disclosing state secret, subverting state power and sabotaging state unity;
      3. Damaging state honor and benefit;
      4. Inciting national hatred and discrimination and sabotaging national unity;
      5. Destroying religious policy of the state and advocating heresy and feudalistic superstition;
      6. Spreading rumors, disturbing social order and destroying social stability;
      7. Spreading obscenity, porn, gambling, violence , murder and terror or abetting a crime;
      8. Insulting or slandering others and infringing on the legal rights and interests of others;
      9. Containing contents of sham, defraudation, harm, threat, infringement to others' privacy, harassment, infringement, slander, coarseness, indecency, or morally repulsive contents;
      10. Containing other contents restricted or forbidden by applicable laws, regulations, rules, provisions and other legal standards.

VII. Private Policy and Data

  1. It is crucial for Prima Niaga Group Sdn. Bhd. to protect your personal information. Prima Niaga Group Sdn. Bhd. prepares Prima Niaga Group Sdn. Bhd. Privacy Policy, in which contents related to ownership and protection of intellectual property, collection, use, share, storage and protection, etc. of your information are disclosed. You are suggested to thoroughly read Prima Niaga Group Sdn. Bhd. Privacy Policy.

VIII. Exception Clauses

  1. Unless otherwise specified in laws and regulations, Prima Niaga Group Sdn. Bhd. will do its best to ensure the security, validity, accuracy and reliability of the licensed software and technologies and information involved, but Prima Niaga Group Sdn. Bhd. is unable to guarantee the same due to restriction by available technologies nowadays.
  2. You understand that Prima Niaga Group Sdn. Bhd. will not assume responsibility for direct or indirect losses caused by force majeure and default of a third party.
  3. You shall be responsible for personnel injury or incidental or indirectly injury caused by or related to one of the following accidents:
    1. A third party uses the licensed software or changes your data without permission;
    2. Expenses and losses produced by using the licensed software;
    3. Your misunderstanding of the licensed software;
    4. Other losses related to licensed software caused by reasons not attributable to Prima Niaga Group Sdn. Bhd.
  4. Any other licensed software-derived software not developed and released by Prima Niaga Group Sdn. Bhd. or the development and release are not granted by Prima Niaga Group Sdn. Bhd. is illegal software. Downloading, installing and using such software may cause unpredictable risks. Prima Niaga Group Sdn. Bhd. shall be free from legal responsibilities and disputes generated therein and Prima Niaga Group Sdn. Bhd. shall have the right to suspend or terminate application license and/or other all services.
  5. You have been informed of that the usage of Prima Niaga Group Sdn. Bhd. and its supplier's smart platform involves in Internet service, which may be affected by unstable factors in all links. Although Prima Niaga Group Sdn. Bhd. has taken safeguard measures, the service may be suspended, terminated, delayed, suffered from application restriction or application failure due to inherent defects of Internet and e-communication as well as factors beyond reasonable control of any party to the Agreement (including but not limited to fire, flood, terrorist attack, pestilence, natural disasters, riot, terminal virus, hacker attack, network fault and terminal fault). You hereby agree to bear foregoing risks and agree that Prima Niaga Group Sdn. Bhd. is free from any responsibility when normal running of services are influenced by the occurrence of foregoing risks.

Agreement Termination and Breach of Agreement

  1. You should understand that you shall use the licensed software according to authorization scope, respect intellectual property of software and contents contained in the software, and perform obligations according to the Agreement when using Prima Niaga Group Sdn. Bhd.'s services. Prima Niaga Group Sdn. Bhd. will terminate the application license if you are in material breach of the Agreement.
  2. Your application of the software relies on supporting services supplied by Prima Niaga Group Sdn. Bhd.'s related companies. Breach of terms, agreements, rules, annunciation and other relevant regulations of Prima Niaga Group Sdn. Bhd. and its related companies may cause failure in normal usage of licensed software, in which case, Prima Niaga Group Sdn. Bhd. shall be entitled to terminate the application license, or take measures to restrain your application license or other rights and interests controlled by Prima Niaga Group Sdn. Bhd. as agreed in the Agreement, including suspension or termination of your application license.
  3. In case of your breach of the Agreement or other agreements signed with Prima Niaga Group Sdn. Bhd., Prima Niaga Group Sdn. Bhd. and its suppliers shall have the right to notify the related companies, requiring them to take restrictive measures to your rights and interests, including requiring related companies to suspend or terminate supplying part or whole services for you, and legally announce your breach of agreement on websites run or actually controlled by them.
  4. The licensed software is downloaded from the downloading platform and you shall abide by stipulations of the download platform, system platform and terminal manufacture on application ways and restrictions of the licensed software. If the above mentioned third party confirms that you are in breach of the agreement and Prima Niaga Group Sdn. Bhd. and its supplier's treatment is required, Prima Niaga Group Sdn. Bhd. may terminate your application license at the third party's request.
  5. When the application license terminates, you shall stop using the licensed software and destroy all copies.
  6. You must bear all compensation responsibilities if Prima Niaga Group Sdn. Bhd and other users suffer from losses caused by your breach of terms in the Agreement.

X. Governing Laws and Severability

  1. Effectiveness, explanation, change, execution and dispute settlement of the Agreement are subject to laws of Prima Niaga Group Sdn. Bhd.. If no relevant laws and regulations are available, reference to general international business practices and (or) industrial practices shall be made.
  2. Dispute arising from or in connection with the Agreement may be settled by you and Prima Niaga Group Sdn. Bhd. through friendly negotiation or submitted to the court with competent jurisdiction of Laws of Malaysia where the Agreement is signed for adjudication.
  3. When any term of the Agreement is judged to be invalid by such court, it will not influence the effectiveness of other terms or any part thereof, and you and Prima Niaga Group Sdn. Bhd. shall perform the valid terms in good faith.