This Privacy Notice and its Addendum(s) (“Privacy Notice”) describe how Referly, a venture of Xideas Sdn Bhd (“Company”) collect, use, process and disclose Personal Data through the use of Referly, as well as features and other services globally, operated by Referly (“Services”).

This Privacy Notice applies to our Members, Ambassador, Founders, partners and service providers (“You”).

“Personal Data” is any information which can be used to identify as our Member. This includes but not limited to your name, nationality, telephone number, bank and credit card details, email address, your image, government-issued identification numbers, date of birth and financial information.

1. Collection of Personal Data

We collect our Members personal data in the ways listed below:

1. Members provide Personal Data

This includes but not limited to when our Members complete their user profile or registration forms, provide information to assess eligibility to provide services as a Referly Member, Gold Member or Founders; verify your identity through various means.

1. When the Program is being used

Personal Data may be collected through the normal use of Referly. Some examples are your location information; feedback, ratings and compliments; transaction information (such as payment method).

• From Other Sources

When we collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources. Such sources include referral programmes; our business partners, marketing services providers and payment providers.

1. Referees & Invitees Personal Data

Some of the Personal Data that we collected may be sensitive in nature. We collect sensitive Personal Data only with your consent and/or in strict compliance with applicable laws.

Members may participate in the Program made available by Referly. In order to refer/ invite them into Referly, they must necessarily submit personal information such as name and e-mail address information, so that Referly can communicate with them via emails & newsletter. The personal information will be collected, processed and used in accordance with Referly’s Privacy Statement, which can be found below. Members understand that, in addition to the initial communications, Referly may also use the personal information for follow-up communications.

 

2. USE OF PERSONAL DATA

Referly may use your Personal Data for the following purposes set out in the list below. (“Purposes”).

1. Providing services and features

Your Personal Data will be used to provide, personalise, maintain and improve our Apps and Services. This includes, but not limited to, using your Personal Data to create, administer and update your account, track the progress of your earnings.

1. Safety and security

This includes, but not limited to verifying your identity when you log in to Referly, monitoring compliance with our terms & conditions and policies.

• User support

Your personal data will be used to provide investigation and address concerns if any, and improve our user support responses.

1. Research and development and security

We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services.

1. Legal purposes

We may use the Personal Data we collect for legal purposes, such as to investigate and resolve claims or disputes as allowed or required by applicable law. We may also use your Personal Data when we are required and advised to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

1. Marketing and Promotions

We may send you marketing & promotion materials relating to customised products or services (that may be of interest or relevance based on your profile)

 

3. DISCLOSURE OF PERSONAL DATA

We may be required to share Personal Data with various parties for the Purposes. These parties include but not limited to the Members of the Program, holding company or subsidiaries of Referly, jointly controlled entities, affiliates of Referly, legal advisors and governmental authorities and etc.

RETENTION OF PERSONAL DATA

We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Privacy Notice, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

4. PROTECTION OF PERSONAL DATA

We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, used or accessed in any unauthorised way. We limit our employees access to your personal data on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to handle your information with confidentiality.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we commit to do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.

5. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

In accordance with applicable laws and regulations, you may be entitled to:

1. inquire about the processing of your Personal Data and be provided with a copy of it;

1. in some cases, request the correction and/or deletion of your Personal Data;
2. in some cases, request the restriction of or object to the processing of your Personal Data;
3. withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
4. request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and
5. report to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment as a result of unlawful processing of your Personal Data.

Where you are given the option to share your Personal Data with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your Personal Data with us, withdrawing your consent to our use of it or to your agreement with our Privacy Notice could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in Section II (Use of Personal Data) or that you are unable to make use of the Apps or the Services.

After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

We will screen and verify all requests beforehand. In order to verify your identity and/or authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

6. AMENDMENTS AND UPDATES

Referly may modify, update or amend the terms in this Privacy Notice at any time. Such amendments shall be notified to you through the Apps and/ or other appropriate means  at least five (5) business days before the effective date. The updated version will be posted on the app. It is your responsibility to review the Privacy Notice regularly. Your continued use of the Apps or continuing to communicate or engage with Referly following the effective date of the modifications to this Privacy Notice , whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.

7. HOW TO CONTACT US

If you have any queries about this Notice or would like to exercise your rights set out in this Notice , please email your enquiry to us at [email protected]

By using our services, you acknowledge that you have read and understood our privacy notice, and you agree to the collection, use, and disclosure of your personal information as described in the notice. You further acknowledge that you are providing your informed and explicit consent to the processing of your personal data in accordance with applicable data protection laws.