H99 PROPERTY Privacy Policy
This Privacy Policy applies to the services provided by H99 PROPERTY SDN.BHD. (hereinafter referred to as “the Company” or “we”) at the domain and subdomains of www.h99property.com (hereinafter referred to as “the Website”). By browsing and using our website, you agree to our collection, use, disclosure, and other processing of your personal data during the use of this website, and you also agree to be bound by the terms and conditions of this Privacy Policy.
If you disagree, please refrain from using or accessing the services we provide. You agree that the Company may amend this Privacy Policy from time to time to comply with changes in laws and regulations, updates in personal data collection and usage policies, website functionality changes, or technological updates.
If any changes affect the way we collect or use personal data, all updates will be posted on this Privacy Policy page. Therefore, you should regularly review the Privacy Policy to stay informed about our latest policies and practices. If you do not agree with any changes or amendments to this Privacy Policy, please discontinue using this website. Continued use of the Website after the amendment’s effective date will be deemed as acceptance of the revised terms. Your personal data may be disclosed to third parties and used by us and such third parties. By accepting this Privacy Policy and the Member Agreement/Terms of Service during registration, you expressly consent to our use and disclosure of your personal data. This Privacy Policy is also part of the Member Agreement/Terms of Service.
■ Information We Collect
1. The main purpose of collecting your personal data is to provide you with smooth, efficient, and customized services on the Website. This allows us to offer services and features tailored to your needs, making your experience more seamless. We collect the personal data you provide when using the Website, which may include your name, gender, birth date, address, contact phone number, emergency contact information, personal photos, credit card information, email address, and issuance date, type, and location, professional certificates, employment information (including company name, work area, job responsibilities, job title), property ownership documents, copies of identification, and other details as required in relevant application or contract forms. Additionally, we may collect specific data such as IP address, geographic location, password, browser preferences, browser type, operating system, app version, language settings, and pages displayed to you when you use our website. If you use a mobile device, we may collect information identifiable to your device, its settings, and unique features.
2. The collection, processing, and utilization of personal data on this website will strictly adhere to Malaysia’s Personal Data Protection Act.
3. Generally, you can browse and use the services we offer (including but not limited to the Website, instant messaging, notifications, etc.) without disclosing any personal information or identifying yourself to us. However, once you provide personal data, you are no longer anonymous to us. If you choose to use our services, we may ask you to provide contact and identification details, payment information, and other personal data requested in various forms on our website. We will specify which data is mandatory and which is optional. You may choose not to use a particular service or feature if you do not wish to provide the necessary information. In certain cases, such as applying for a free email account or registering for transactions on our website, we may request further financial details, which we will use, including your credit card data, to verify your name, address, and other information.
4. We automatically collect certain information about your behaviour on our website, which we use for internal research on member demographics, interests, and behaviour patterns to understand our users better and improve the services provided to you and our community. This data may include the URL from which you arrived (whether or not it is on our website), the next URL you visit (whether or not it is on our website), the browser you are using, and your IP address.
5. We use data collection tools such as cookies on some web pages to help us analyse web traffic, measure the effectiveness of promotional campaigns, and enhance trust and security. Cookies are small files stored on your computer or mobile device that help us provide specific features. Some features of the Website may only be available through cookies. We also use cookies to reduce the frequency of password input during a session and to provide data aligned with your interests. Most cookies are session cookies, meaning they are automatically deleted from your computer or mobile device at the end of a session. You always have the right to refuse our cookies if your browser allows, though this may prevent you from using certain features on our website or require more frequent password input during a session.
6. Additionally, you may encounter cookies or other similar devices on certain web pages placed by third parties. For example, if you view a web page created by a member, that page may contain a cookie. We do not control the use of cookies by third parties.
7. If you choose to buy or sell items on our website, we will collect information about your buying and selling activity and may also collect feedback from other members in our rating system. To learn more about the details of the data we collect and who has access to it, please refer to the following sections:
■ Notification and Consent for the Collection, Processing, and Use of Personal Data
1. The Company will collect, process, and use personal data based on the services provided for the following specific purposes:
2. The categories of data collected, processed, and used will depend on the specific purpose, and the duration, region, recipients, and methods of use for your personal data are as follows:
Duration: The data will be kept for the duration of the specific purpose. After the personal data is no longer in use or the specific purpose has been fulfilled, the Company will periodically delete the data.
Region: The location of the Company, authorized personnel, or relevant upstream and downstream entities involved in providing transaction services for the specific purpose.
Recipients: Authorized personnel or relevant upstream and downstream entities involved in providing transaction services and viewing the Company’s platform pages.
Methods: The Company will collect, process, and use your personal data within the scope of the specific purpose, using reasonable and legal methods such as paper forms, computer systems, electronic files, telephone, email, fax, mail, or through automated or non-automated means in compliance with personal data protection laws.
3. Categories of Personal Data Collected: This includes details such as your name, gender, birth date, address, contact phone number, emergency contact information, personal photo, credit card information, email address, identification number (and issuance date, type, and location), professional certificates, employment information (including company name, work area, job responsibilities, job title), property ownership documents, copies of identification, and other relevant application or contract information.
4. Impact of Not Providing Personal Data: Unless required by law, you may freely choose whether to provide certain personal data and categories of information. However, if you choose not to provide the necessary personal data or categories of information, the Company may not be able to conduct the necessary business reviews or processes, and therefore, we may be unable to provide you with the relevant services or may not be able to offer you the best service. We appreciate your understanding.
5. After being informed of the above matters, you, the individual, or the informed party clearly understand these notifications and agree to provide your personal data to the Company as stated.
■ Use of Your Personal Data
1. We use your data to help provide you with the services you request. We utilize your personal profile data and other information we obtain from your current or past activities on the Website to resolve disputes, troubleshoot issues, and enforce our Member Agreement. Occasionally, we may review multiple member accounts to identify issues or resolve disputes. In particular, we may examine your data to identify members using multiple accounts or pseudonyms.
2. You agree that we may use your personal data to enhance our marketing and promotional efforts, perform statistical analysis on website usage, improve the content and products of the services we provide, and customize the design and services of our website according to customer needs. These improvements help us better tailor the website to your requirements. If requested by judicial or other competent authorities, your personal data and information will be provided.
3. You agree that we may share your personal data with third-party suppliers or other third parties to contact you regarding hosting services, data analytics, marketing, customer services, credit card and payment services, and other relevant services. We are also authorized to disclose your personal data to our affiliated companies (corporate group), including employees of our affiliated companies, trusted intermediaries, and agents, who are permitted access to the aforementioned information with our consent. Those who need to know or access this information to provide the services you request (including customer service) and conduct internal investigations are granted access under our approval. The Company may disclose personal data as required by law in the following cases: to protect us from legal liability; to comply with requests from competent authorities or departments, such as in response to correspondence, legal proceedings, etc.; to investigate fraud or other illegal acts, or when necessary to comply with the law. We may also disclose personal data under applicable laws to enforce or implement the terms and conditions of our services or to protect the rights, property, or safety of the Company, customers, and others.
■ Disclosure of Your Personal Data
1. Due to the current regulatory environment, we cannot ensure that all of your private communications and other personal data will never be disclosed in ways other than as described in this Privacy Policy. For example (but not limited to the following), in certain legal circumstances, we may provide your data to the government or third parties, or third parties may illegally intercept or access transmissions or private communications. Therefore, while we comply with regulations and standards and take appropriate security control measures to protect your privacy, we do not make any guarantees, and you should understand that your personal data or private communications may still be transmitted externally and are subject to potential risks.
2. As a policy, we will never rent, sell, arbitrarily disclose, or provide your personal data to third parties, except as described in the following cases where your personal data may be disclosed.
■ Advertisers
We collect personal data (from all member accounts) and disclose this data to advertisers and other third parties for marketing and advertising purposes in a non-personally identifiable manner. Even in such cases, we do not disclose any information that could be used to identify you personally. Certain information, such as your name, email address, password, credit card number, and bank account details, will never be disclosed to advertisers for marketing purposes. If you right-click on an ad on our website and select “properties,” you will be able to see the advertiser’s URL.
■ Outsourced Vendors or Service Providers
We may use outsourced vendors or service providers to enhance our services (e.g., for search functions, message boards, surveys), and as a result, we may directly provide them with certain personal data. In some cases, the outsourced vendors or service providers may collect data directly from you (e.g., when we request them to conduct a survey on our behalf). In all cases, the use of data we provide to these vendors or service providers is governed by confidentiality agreements. If you provide additional data directly to these outsourced vendors or service providers, their use of your data will be subject to their respective privacy policies.
■ Other Business Entities
This website, the Company, its subsidiaries, or joint ventures may merge with or be acquired by other business entities. In such events, you can expect that the website will transfer all of your data to the other party to ensure continued service. You will be notified of such an event, and we will ensure that the newly merged entity adheres to the practices outlined in this Privacy Policy.
■ Legal Requirements
This website cooperates with law enforcement and other third parties in enforcing the law, such as intellectual property rights, fraud, and other rights protection. We may provide your data to law enforcement or other government officials as required by law or when authorized by you, and at our discretion when we believe it is necessary or appropriate to do so, in connection with investigations of fraud, intellectual property infringement, or other illegal activities that may expose us or you to legal liability. Furthermore, we may provide member account information, name, address, city, postal code, country, phone number, email address, and company name related to investigations of fraud, intellectual property infringement, piracy, or other illegal activities, to maintain trust, ensure the safety of our community, and enforce our Member Agreement, Privacy Policy, and any policies or rules posted on our website.
■ Your Use of Other Members’ Information
To facilitate active transactions and enhance interactions among all members of the Website community, our services, under the terms of the Website’s Service Agreement, allow you limited access to other members’ contact information. As a member, you may access the transaction counterpart’s member ID, email address, and other details, while the counterpart can access the seller’s member ID, email address, and other contact details. Except as permitted by the Website’s Service Agreement, this Privacy Policy, and any rules or statements now or in the future applicable to all services provided by the Website, you may not disclose another member’s personal data to third parties without sufficient explanation and consent from us and the other member. Please note that law enforcement officers, certified rights holders in the Verified Rights Owners Program, and others granted access to information have different permissions.
■ Password Control
You are responsible for all actions taken under your member account and password, including any associated fees. Therefore, we do not recommend that you disclose your website account or password to any third party. If you choose to share your account and password with a third party who provides additional services to you, you are responsible for all actions taken under your account and password. You should review the third party’s privacy policy. If you lose control of your password, you may lose control of your personal data and be bound by actions taken on your behalf. Therefore, if your password is compromised for any reason, you must immediately follow the customer service instructions or the Website’s guidelines to change your password.
■ Reviewing and Modifying Your Personal Information
We provide you with the ability to log into the Website and enter new data to automatically review and modify the information you have provided us. Typically, we do not modify your data at your request due to the difficulty of verifying your account. By navigating to the Website’s homepage → Login → Member Centre → Personal Information/Password, you can change your gender, email address, contact information, invoice handling details, and password. If there are any changes to your data, you must update it immediately. Once posted, you cannot independently modify or remove any publicly posted content on our website, including message areas or sections on decorations, relocations, and housing questions. In certain cases, we will retain information you requested to be removed, such as for resolving disputes, troubleshooting, and enforcing our Member Agreement/Terms of Service. Due to technical and legal limitations, including access to backup systems, this previous data may not be completely removed from our database. Therefore, you should not expect all of your personal data to be entirely removed from our databases as requested.
■ Third-Party Application Data Control Members have the right to delete third-party application data (e.g., Facebook) that is linked to this website. To delete the Facebook binding, members can apply via “Member Centre – Online Customer Service” or “Member Centre – I Want to Appeal,” where customer service will assist in removing the Facebook binding. Members can also delete the Website’s application by navigating to Facebook’s app settings under [Settings & Privacy – Permissions] and clicking delete.
■ Other Data Collectors
This statement only governs the collection, processing, and use of personal data by us. In cases where you disclose your data to others, whether on our website or across the internet, such as to bidders, buyers, or sellers, those individuals are responsible for the use and disclosure of the data you provide to them. When we use third-party advertisers, they must adhere to their own privacy policies. Since our website cannot control or modify the privacy policies of third parties, you will be subject to the privacy policies of those third parties. We encourage you to ask questions before disclosing personal information to others.
■ Call Recording
When calls are transferred to you through H99, H99 is permitted to record the entire conversation to handle any potential disputes arising from the transaction.
■ Security
This website complies with legal requirements to protect the confidentiality of your personal data. We treat this data as an asset that must be protected from loss and unauthorized access. We implement multiple security measures to safeguard this data from unauthorized access, both internally and externally.
■ Conflicting Terms
Please note that this Privacy Policy is our sole policy governing the protection of your privacy. If there is any inconsistency between the terms and conditions of this Privacy Policy and other privacy statements that may appear on our website (such as privacy tools, easy-to-read summaries, charts, or P3P statements), you agree that the terms and conditions of this Privacy Policy will take precedence.
■ Notifications
We reserve the right to modify this Privacy Policy at any time by posting changes on our website. All modifications will take effect automatically 7 days after their initial posting, provided they are within the scope of the specific purposes for which the data was originally collected.