By using our app, you consent to our collection, use and disclosure of your personal information as outlined in this policy. Your consent is the legal basis for our use of your personal information. You can withdraw your consent at any time. However, if you withdraw your consent to certain uses, we may no longer be able to provide our services to you.
This policy is divided into three general areas: (i) how we process your information; (ii) your rights with respect to your personal data; and (iii) information on cookies, third party sites, security measures and similar issues that may impact personal data. At the end of the policy, we provide you with information on how to contact our headquarter.
Who We Collect Information From
We collect personal information from:
visitors to our mobile applications and website;
individuals who establish a relationship with us by telephone, sign up to receive communications or who sign up for Level Up Hub; and
Our Sites are not intended for children. If we become aware that we have inadvertently received or collected personal information pertaining to a child under the age of consent in the country where the child is located without valid consent, we will delete such information from our records.
What Personal Information We Collect
We may collect personal information which includes:
user account information that you upload on our mobile application and website, such as your picture, name, home address, email address and phone number;
loyalty program account information you register with our mobile app, including your program account numbers, passwords and balances, and details of redemption transactions involving those loyalty programs;
your IP address;
the date and time you accessed our services, the hardware, software or internet browser you used to access our mobile application and website, and information about your computer’s operating system, such as application versions and your language settings;
information about which pages have been shown to you, site and app navigation details and links on our mobile application that you visit;
information you submit to our website and mobile application
Special Categories of Personal Data
We do not process special categories of data, namely, sensitive personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
How We Use Personal Information
We will only collect and use your personal information for the following purposes, except as permitted or required by applicable law:
allowing you to track, manage and access your loyalty points and miles on our mobile application;
processing points allocation and redemption transactions that you have performed at our outlets and displaying your account details and points history to you;
communicating with you and providing you with information on and direct marketing of special offers or promotions that we believe may be of interest to you;
to serve advertisements to you in various marketing channels, including but not limited to social media, search engines, mobile apps, and various websites including our own mobile application and website;
to notify you of offers of featured products and services that may be of interest to you;
for profiling and analytical purposes, including marketing and website analytics, in order to optimize and customize our online platform to your needs, as well as the products and services marketed to you, and to make the Sites easier to use;
to provide customer service;
communicating with you by email, mail and phone;
improving the performance and utility of our services;
generally managing and administering our business;
preventing and prosecuting fraud and/or credit risk;
meeting legal and regulatory requirements; and
any other purpose to which you may consent in the future.
Limited to Disclosed Purposes
We limit the collection, use, and disclosure of personal information to that which is needed to achieve the above noted purposes.
Who We Disclose Personal Information To
We will only disclose your personal information in the following circumstances, except as permitted or required by applicable law:
to third party companies and contractors that provide us with services in the conduct of our business ("service providers"), such as payment processing services, information technology services for our software applications, advertising, marketing and survey services and other essential similar services, but only as necessary for those service providers to provide services to us;
to third parties as we deem necessary or appropriate to prevent, limit or otherwise prosecute fraud;
as necessary to meet legal and regulatory requirements; and
any other circumstance in which you provide consent to disclose.
All Level Up Hub service providers are contractually bound to keep your information secure. Our service providers can use, store and disclose your personal information solely for purposes for which it is disclosed to them (to provide us with services).
Other Data Protection Laws and Privacy Policies Impacting Personal Data
We will retain your personal information for as long as
your account is active;
your personal information is needed to provide you services; or
it is necessary to meet legal, regulatory, insurance and audit requirements.
If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at XXX@email.com.
Accuracy of Your Personal Information
We will use commercially reasonable efforts to ensure that your personal information is correct, complete and up-to-date to the extent we are notified of any changes by you. You can review and update your personal information on our mobile application. You can assist by keeping us informed of any changes, or informing us if you find any errors in our information about you. If we have disclosed inaccurate information about you to a third party that you are aware of, we would be pleased to contact the third party in order to correct the information upon your request.
Your Rights with Respect to Your Personal Information
If you wish to change any of your personal information we have on file in our records, other than that available to you and capable of being modified through the Services, you may contact our Privacy Officer as noted at the bottom of this page. To protect your privacy and security, we may take reasonable steps to verify your identity prior to making corrections.
Please note that we may not be able to provide access to personal information in certain circumstances, such as if the personal information was collected for the purposes of an investigation, if disclosure would reveal the personal information of a third party, or if prohibited by law. To protect your privacy and security, we may take reasonable steps to verify your identity prior to providing such access.
Rights of Malaysia Data Subjects
In addition to rights with respect to your personal data already noted elsewhere in this policy, for those individuals residing in the Malaysia, you have certain additional rights under the General Data Protection Regulation (GDPR):
Restrictions on Further Processing
You have the right, where there is a dispute in relation to the accuracy or basis of processing of your personal data, to request a restriction on further processing by us.
You have the right to erasure of your personal data (“right to be forgotten”) in certain circumstances.
You have the right to request that personal data that you have provided to us be returned to you, in a structured, commonly used and machine-readable format.
You have the right not to be subject to a decision based solely on automated decision-making. In connection with such right, you may have the right to request human intervention with respect to such automated decision-making, as well as express your point of view or contest any such automated decision-making.
Opt-out of Direct Marketing / Profiling
You may elect to “opt out” of direct marketing activities at any time, including any profiling we may conduct for direct marketing purposes. Accordingly, we may rely on your consent permitting us to process your information in accordance with this policy for direct marketing, including profiling for direct marketing, unless you take affirmative action to opt out of such processing.
Lodge Complaints with Our Headquarter
You have the right to lodge a complaint with our headquarter.
Customer Experience Analytical Tools (CXA)
CXA (also known as tracking pixels or web beacons) comes with a unique identifier, similar in function to cookies. They are used to track the online movements of users, only in our website (website Name), (Website URL Hyperlink). In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence.
We use CXA to help us better manage content on our Sites, by informing us what content is effective, and to gauge the effectiveness of certain communications and marketing campaigns. For instance, we use CXA in our HTML-based emails to let us know which emails have been opened by recipients and to allow us to serve you related advertising on the Internet.
List of CXA tools we may be using on our website:
Google Tag Manager
Links to Third Party Sites Under the Same Organization
Sample of website links that maybe directed from our Level Up Hub and leveluphub.my:
Social Media Features
We take reasonable measures, including administrative, physical and technical safeguards, to protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. Personal information uploaded to our Sites is transmitted to us using industry standard encryption, which creates a private conversation between your computer and our Sites. We authenticate our Sites and enable TLS/SSL encryption to protect your sensitive data and transactions.
Nevertheless, Level Up Hub cannot absolutely guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. In the event that your personal information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify you and take other steps in accordance with applicable laws or regulations.
Revision of Policy
This policy may be revised from time to time. We will notify you of material changes prior to such material change being effective, either by e-mail at the address you have provided to us in connection with your registration on our mobile application or by a prominent notice on our mobile application. Your continued use of our mobile application and services or failure to cancel your account on our mobile application following such notification shall constitute your acceptance of the revised policy. We encourage you to periodically review this page for the latest information on our privacy practices.
Disputes and Complaints
This policy is subject to our TERMS & CONDITIONS, including terms regarding the governing law and the resolution of any disputes between you and Level Up Hub.