FAMILYMART'S LOYALTY PROGRAMME PRIVACY POLICY

Version 1.2 - 10 June 2019

How we reward loyalty matters to us. At FamilyMart, we are working hard to serve shoppers a little better every day. Looking after the personal data you share with us is an immensely important part of this. We want you to be confident that your data is safe and secure with us, and understand how we use it to offer you a better and more personalised shopping experience. This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we will store and handle that data, and keep it safe. This Privacy Notice applies if you interact with us through our stores, over the phone, online, through our mobile applications or otherwise by using our websites or interacting with us on social media (our "Services").


1.

WHO ARE WE

1.1

When we say 'we' or 'us' in this policy, we are referring to QL Maxincome Sdn Bhd ("Maxincome") the company carrying on the FamilyMart business, Maxincome's related corporations, and affiliates (collectively referred to as the "FamilyMart Group")

2.

WHAT TYPE OF INFORMATION DO WE COLLECT?

2.1

Your personal details in order to process your loyalty program application. These details may include your name, e-mail address, postal address and mobile phone number. This list is not exhaustive and may include other relevant personal details. It is important to note that all information requested is obligatory to be provided by you unless we indicate otherwise. Should you fail to provide the obligatory information we may be unable to process your application.

2.2

Your account login details such as your mobile number and for security, an encrypted record of your login password.

2.3

Details of your interactions with us through in store, online or by using our app.

2.3.1

For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, voucher redemptions, and how and when you contact us.

2.4

Details of your shopping preferences.

2.4.1

For example, which of our shops you prefer to visit and where you redeem your vouchers.

2.5

Details of your visits to our websites or apps, and which site you came from to ours.

2.6

Information gathered by the use of cookies. Learn more about how we use cookies and similar technologies in the Cookies section below.

2.7

Personal details which help us to recommend items of interest. We will only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us.

2.8

Your comments and product reviews.

2.9

Your image may be recorded on CCTV when you visit a shop.

2.10

When you contact us or we contact you or you take part in promotions, competitions, surveys or reviews about our Services, we may collect.

2.11

Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

3.

HOW AND WHY DO WE USE YOUR PERSONAL DATA?

3.1

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.

3.2

We then use this to offer you promotions, products and services that are most likely to interest you. We will also offer you relevant rewards.

3.3

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. Of course, if you wish to change how we use your data, you'll find details in the 'Your Rights?' section below.

3.4

Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we may be unable to process your application for our loyalty program.

3.5

We may use your information in the following ways:

3.5.1

Make our Services and Membership rewards benefit available to you - Manage your loyalty program account you hold with us. Including but not limited to providing you with your loyalty program, points, vouchers and/or coupons you earned while being our loyal customer.

3.5.2

To personalise your shopping experience - we try to understand our customers so we can provide you with a great shopping experience, relevant marketing, personalised offers, shopping ideas and online advertising. Understanding how you use our Apps, how you interact with us, where you shop, the products and services you buy and how you use and browse our websites helps us to do this.

3.5.3

For safety and security - we use your personal information to help provide safe and secure environments for our colleagues to work in, our customers to shop in and for our businesses to be conducted. To enable this we use CCTV, monitor online behaviour and carry out checks to help us ensure that our customers are genuine to prevent fraud and to help customers use our services appropriately.

3.5.4

Analytics and profiling - we use your personal information for statistical analysis and to help us understand more about our customers. That includes understanding the products and services you buy, the manner in which you consume them. This helps us to serve you better and to find ways to improve our services, stores, apps and websites. These profiles help us to send you offers that are more relevant to you.

3.5.5

Contacting you - we use your personal information to contact you: either to conduct market research or to contact you about products and services from us and other companies. We may also contact you in relation to any questions you have raised with us or to discuss the status of your account with us.

4.

WHO MIGHT WE SHARE YOUR PERSONAL DATA WITH?

4.1

The FamilyMart Group - we will share your personal information in certain circumstances with the other companies within the FamilyMart Group so that we can provide you with a high quality, personalised and tailored service (including relevant marketing) across our FamilyMart Group.

4.2

Our authorised service providers - we work with partners, suppliers, insurers, aggregators and agencies so that they can help us provide the products and services you require from us. These third parties process your personal information on our behalf and are required to meet our high standards of security before doing so. We only share information that allows them to provide their services to us or to facilitate them providing their services to you. These third parties include:

4.2.1

Advertising companies, who help us place FamilyMart's Group adverts online;

4.2.2

Market research partners, who help us to analyse customer behaviour;

4.2.3

Social media providers - such as Facebook, Instagram and Twitter - where we interact with you on social media;

4.2.4

Third party vendors who help us to manage and maintain the Group IT infrastructure;

4.2.5

Providers of temporary staff, who need access to certain personal information to carry out their role within the business;

4.2.6

Where relevant, our professional advisors, such as lawyers and consultants;

4.2.7

Companies that provide insights and analytics services for us so we can stock the right products, send the right marketing campaigns and understand our business and customers better;

4.2.8

Security and fraud prevention companies to ensure the safety and security of our customers, colleagues and business;

4.2.9

Companies who assess faults and repair products on our behalf;

4.2.10

Companies administer competitions for us so they run smoothly; and

4.2.11

Companies that enable us to collect your reviews and comments, both online and offline.

4.3

Other organisations and individuals - we may share your personal information in certain scenarios. For example:

4.3.1

If we're discussing selling or transferring part or all of a FamilyMart's Group business, we may share information about you to prospective purchasers and their advisers - but only so they can evaluate the relevant business; or

4.3.2

If we are reorganised or sold to another organisation, we may transfer information we hold about you to them so they can continue to provide our Services to you.

4.3.3

If we are required to by law, under any code of practice by which we are bound or where we are asked to do so by a public or regulatory authority such as the police.

4.3.4

If we need to do so in order to exercise or protect our legal rights, users, systems and services; or

4.3.5

In response to requests from individuals (or their representatives) seeking to protect their rights or the rights of others. We will only share your personal information in response to requests which do not override your privacy interests. For example, we will not share your personal information with individuals who are merely curious about you, but we will share your personal information to e.g. insurers, solicitors, employers etc. which have a legitimate interest in your personal information.

4.4

Further, please be informed that if required for any of the foregoing Purposes, your Personal Data may be transferred to locations outside Malaysia.

5.

MARKETING & ADVERTISING CAMPAIGNS

5.1

This section explains our advertising approach and the choices you have when it comes to receiving marketing communications.

5.1.1

We allow advertisers to run ad campaigns on our Services.

5.1.2

The information and advertisements that you see when accessing our Services may be targeted on the basis of your current activity or contextual information based on your current purchases.

5.1.3

In our app, you can manage your preference and opt out from one or all of the different push notifications by selecting or deselecting the relevant options in the Settings Section of your device.

5.2

Please note:

5.2.1

It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable for any loss, damage, cost or expense that you may suffer or incur as a result or in connection thereof.

6.

COOKIES

6.1

Cookies are small text files which are placed on your device via your browser when you visit the website. We currently do not use cookies on our app. Some cookies that we use may collect personal data about you. In our privacy policy, we explain what "personal data" is, what personal data we collect about you and how we use it.

6.2

They are not harmful to your devices (like a virus or malicious code) and allow you to use many of the useful features of our websites (like remembering your favourites).

6.3

Cookies have a lifetime. Some only last until you close your browser or a short time. These are called 'session cookies'. Some last longer though, for example, to enable a website to recognise you when you return to them. These are called 'persistent cookies'.

6.4

Cookies placed directly by a website owner (like us) are known as 'first party cookies' and most modern websites also use technology provided by other people/businesses, for example to provide online advertising. Cookies placed by other parties are known as 'third party cookies'.

6.5

How can you manage cookies?

6.5.1

Cookies do lots of important jobs on the Website. However, you are able to disable cookies used on the Website, if you would like to. If you do so, you may find that certain parts of the Website do not work at all, or do not work correctly.

6.5.2

You can disable and/or delete all types of cookies by using your browser settings. Cookies are generally easy to disable and/or delete but how you do so varies from browser to browser. The "help" function within your browser should tell you how to do it. The best way may be to close your browser and then search for "cookie folder" or "cookie manager" or simply "cookie".

7.

GOOGLE ANALYTICS

7.1

We use the web analytics services Google Analytics. These services use cookies to collect information such as your IP address or other identifiers, browser information, and the content you view for the purpose of analysing how visitors use our app and/or website and for us to gain customer insight and to improve the way our site works. The information generated by the cookies about your use of the app and/or website will be transmitted to and stored by these service providers on servers that may be outside Malaysia. These service providers will use this information on our behalf for the purpose of evaluating the number of users on our app and/or website, the location of our users, the most frequently used parts of our app and/or website, the most commonly used browsers to enhance functionality, and the interests of our users.

7.2

Please note that the IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google and Google Analytics does not collect any personal information.

8.

HOW WE PROTECT YOUR PERSONAL DATA

8.1

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

8.2

We secure access to all transactional areas of our websites and apps using 'https' technology.

8.3

Access to your personal data is password-protected.

8.4

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

9.

HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

9.1

Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. In most cases, our retention period will come to an end 7 years after the end of your relationship with us.

10.

THIRD PARTY SITES

10.1

Our website and app may contain links to other websites and social media sites operated by third parties. Please note that we have no control over how those third parties collect and use your personal data. Those third-party sites may have their own privacy policies. You should always read the privacy policy of each website you visit carefully.

11.

YOUR RIGHTS

11.1

You have a number of rights under data protection legislation which, in certain circumstances, you may be able to exercise in relation to the personal information we process about you

11.2

These include:

11.2.1

the right to correction of inaccurate personal information we hold about you;

11.2.2

the right to restrict our use of your personal information. Please note however that the refusal to consent to the processing of your personal data, the withdrawal of your consent or the restriction of the processing of your personal data may result in the inability to provide you or continue to provide you with our Services and/or process your request; and

11.2.3

the right to access a copy of the personal information we hold about you for a prescribed fee under the law.

11.3

Where we rely on consent as the legal basis on which we process your personal information, you may also withdraw that consent at any time.

11.4

If you are seeking to exercise any of these rights, please contact us using the details in the "Contact Us" section below. Please note that we will need to verify your identity before we can fulfil any of your rights under data protection law. This helps us to protect the personal information belonging to our customer against fraudulent requests.

12.

CONTACT US

12.1

If you would like to exercise one of your rights as set out in the "Your rights" sections above, or you have a question or a complaint about this policy, or the way your personal information is processed, please contact us by one of the following means:

12.1.1

By email: members-familymart@ql.com.my

12.1.2

By post: Data Protection Officer

QL Resources Berhad

16A, Jalan Astaka U8/83

Bukit Jelutong, 40150 Shah Alam,

Selangor Darul Ehsan.

12.2

We reserve the right to change this Policy at any time. If we decide to do so we will post the changes on our website and on the app so please check back regularly to keep informed of updates to this Policy.