Privacy Policy
Last updated 05th May 2025
This Privacy Policy describes how TRADEE Technology Sdn Bhd, its respective subsidiaries, affiliates and/or associated companies (collectively “TRADEE”, “we”, “us” or “our”) manages Personal Data (as defined) which is subject to the Malaysia Personal Data Protection Act 2010 (“the Act”).
By accessing and using TRADEE’s mobile applications, websites, platforms and/or its related software (collectively, “TRADEE Sites”), as well as services provided by TRADEE, Seller and/or third party providers (“Third Party Provider”) (collectively, “Services”), you agree and consent to TRADEE, as well as its representatives and/or agents collecting, using, processing, and disclosing your Personal Data, and disclosing such Personal Data to our Third Party Provider and relevant third parties in the manner set forth in this Privacy Policy.
This Privacy Policy applies to our users, clients, agents, vendors, partners, contractors and/or any other service providers (collectively “you”, “your” or “yours”).
By (1) clicking “Yes” or providing your acceptance on our Policy pop-up or any web form referring to this Privacy Policy on TRADEE Sites, (2) submitting your Personal Data to us when signing up for an account on TRADEE Sites, (3) browsing our TRADEE Sites, (4) ordering any of products and Services via TRADEE Sites, or (5) submitting your Personal Data to us when participating in any activities hosted on TRADEE Sites, you acknowledge you are agreeing to the terms of this Privacy Policy. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS TRADEE SITES. We may update this Privacy Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. The effective date will be displayed at the beginning of this Privacy Policy. You agree to be bound by the prevailing terms of the Policy as updated from time to time.
This Policy shall apply in conjunction with any other applicable notices, contractual provisions, or consent clauses relating to the collection, storage, use, disclosure, and/or processing of your personal data by us, and is not intended to supersede or override such notices or clauses unless expressly stated otherwise.
This Policy applies to both buyers and sellers who utilize the Services, except where expressly indicated otherwise.
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PERSONAL DATA
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“Personal Data” is any information which can be used to identify you or from which you are identifiable.
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The Personal Data that TRADEE may collect includes but is not limited to:
your name;
nationality;
telephone number;
billing and/or delivery address;
gender;
bank account and payment information;
email address;
government issued identification or other information required, including, but not limited to national registration identification card number (NRIC) for our due diligence, know your customer, identity verification, and/or fraud prevention purposes;
passport number;
postal address;
telephone number;
mobile number;
biometric data;
race;
date of birth;
marital status;
information associated with or sent by the device(s) used to access our Services or TRADEE Sites;
information about your network, including your contact list when you share permissions on your device, and the people and accounts you interact with;
photographs or audio or video recordings;
marketing and communications data, such as your preferences in receiving marketing from us and third parties, your communication preferences and history of communications with us, our service providers, and other third parties;
usage and transaction data, including details about your searches, orders, the advertising and content you interact with on the TRADEE Sites, and other products and Services related to you;
location data;
any other information about the User when the User signs up to use our Services or TRADEE Sites, and when the User uses the Services or TRADEE Sites, as well as information related to how the User uses our Services or TRADEE Sites; and
aggregate data on content the User engages with.
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You agree not to submit any information to us that is inaccurate, misleading, or incomplete, and you further agree to promptly inform us of any inaccuracies or changes to such information. We reserve the right, at our sole discretion, to request and obtain additional documentation or evidence to verify the accuracy of any information you have provided.
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COLLECTION OF PERSONAL DATA
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We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession.
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Generally, we collect Personal Data in the following ways:
when you submit any form, including, but not limited to, user profile, application form, registration forms or other forms (including but not limited to your name, contact information and other identification information where needed), whether online or in physical format;
when you provide information to assess your eligibility as a Seller (including but not limited to information related to your license, permit and/or approval as well as due diligence check results (as legally permissible);
when you enter into any agreement or provide other documentation or information in respect of your interactions with us and/or when you use our Services and/or through operation of TRADEE Sites;
when you verify your identity through various means;
when you interact with us, such as via TRADEE Sites, telephone calls (which may be recorded), online chat, letters, fax, face-to-face meetings, social media platforms, emails and/or participate in events organised by us (including but not limited to the pictures, audio files, or videos you may submit, which may include images of yourself), including when you interact with our customer service agents;
when you use our electronic services, or interact with us via our application or use Services on TRADEE Sites. This includes, without limitation, through cookies which we may deploy when you interact with our application or website;
when you grant permissions on your device to share information with our application or TRADEE Sites;
when you link your TRADEE account with your social media or other external account or use other social media features, in accordance with the provider’s policies;
when you carry out transactions through our Services;
when you provide us with feedback or complaints;
when you register for a contest;
when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend our events; and/or
when you submit your Personal Data to us for any other reasons.
The above does not purport to be exhaustive and sets out some common instances of when Personal Data about you may be collected.
The Services are not intended for use by children under the age of 13. We do not knowingly collect, use, or maintain any Personal Data or non-personally identifiable information from individuals under the age of 13, nor is any portion of TRADEE Sites or Services directed at children under this age. If you are a parent or legal guardian, you are advised not to permit any child under your care who is under the age of 13 to provide Personal Data to TRADEE. In the event that Personal Data of a child under the age of 18 in your care is disclosed to TRADEE, you hereby provide consent on behalf of such child to the collection, use, and processing of the child’s Personal Data, and you accept and agree to be bound by the terms of this Policy on the child’s behalf. TRADEE reserves the right to terminate any account that is used exclusively by individuals under the age of 13 and to delete or remove any Personal Data that is reasonably believed to have been submitted without the necessary parental or guardian consent by a child under the age of 18.
If you provide us with any Personal Data relating to a third party (including but not limited to information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our inability to provide you with the Services you have requested and/or delays in providing you with Services you have requested.
If you sign up to be a user of our TRADEE Sites using your social media account (“Social Media Account”), link your TRADEE account to your Social Media Account or use any TRADEE social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider’s policies, and we will manage and use any such Personal Data in accordance with this Policy at all times.
For purposes such as detection and prevention of fraud, we may also collect your Personal Data without consent, by relying on exemptions provided by the applicable data privacy laws.
In certain circumstances, you may need to provide your Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstance, may constitute failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.
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COLLECTION OF OTHER DATA
As is common with most websites and mobile applications, your device transmits certain information, potentially including Personal Data, which is logged by a web server when you access TRADEE websites or mobile applications. This information typically includes, without limitation, your device’s Internet Protocol (IP) address, operating system, browser type, mobile device type, device characteristics, unique device identifier (UDID), or mobile equipment identifier (MEID). It may also include the address of the referring website (if applicable), the pages visited within our websites or applications, the time and date of each visit, and potentially a "cookie" (which may be disabled through your browser settings) used to recognize returning visits. If you are logged into your account, this information may be associated with your personal account. Additionally, such data may be included in aggregated, anonymized statistics that help us analyze usage patterns and improve our services.
Our mobile applications may collect precise geolocation data from your mobile device through technologies such as GPS, Wi-Fi, and similar mechanisms. We may collect, use, disclose, and/or process such data for one or more purposes, including, without limitation, providing requested location-based services, delivering location-specific content, or enabling you to share your location with other users as part of our Services. Most mobile devices provide the option to revoke our access to your location data via the device’s settings. For guidance on disabling location services, please contact your mobile service provider or the device manufacturer.
In addition, when you view content, advertisements, or use other software available on TRADEE websites or through our Services, your device may transmit supplementary information to us. This may include, without limitation, your IP address, operating system, and data relating to the content or advertisements viewed, the software accessed, and the timestamp of such activity, in lieu of traditional page view metrics.
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USE OF PERSONAL DATA
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TRADEE may use, disclose, combine, and process your Personal Data for the following purposes (“Purposes”):
to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
to provide you with Services;
to engage you to provide Services;
to create, manage, operate, provide, administer, and/or update your use of and/or access to our Services and TRADEE Sites (including, without limitation, remembering your preference), as well as your relationship and user account with us;
to respond to, process, manage or complete a transaction and/or to fulfill your requests for certain products and services and notify you of service issues and unusual account actions and activities;
to verify your identity and age (where necessary);
to offer, obtain, provide, facilitate, maintain and/or financing solutions;
to protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
to contact or otherwise communicate with you via voice call, text message, fax, email, postal mail, or any other means for the purposes of administering or managing your relationship with us and/or your use of our Services, including but not limited to the conveyance of administration information relating to our Services. You hereby acknowledge and agree that such communications may include the sending of correspondence, documents, or notices, which may result in the disclosure of certain Personal Data necessary for the delivery thereof, including on the external packaging or envelope of such mailings;
to enable other Users to interact or connect with you, or to view certain activities you perform on the TRADEE Sites, including, without limitation, notifying you when other User has sent you a private message, posted a comment directed to you on the TRADEE Sites, or connected with you through TRADEE Sites’ social features;
to respond to, process, and handle queries, feedback, and complaints, as well as carrying out any instructions and/or requests given by you or purported to be given on your behalf;
to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
To facilitate and/or manage business asset transactions or potential business asset transactions involving TRADEE, whether as a sole participant or together with one or more of TRADEE’s related corporations, affiliates, or third-party organisations. Such transactions may include, without limitation, the purchase, sale, lease, merger, amalgamation, financing, or other acquisition or disposal of an organisation, or any portion thereof, or of any business or assets of an organisation.
to store, host, back up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside of your jurisdiction;
to match any Personal Data held which relates to you for any of the purposes listed herein;
to protect personal safety and the rights, property or safety of others;
to conduct due diligence checks, risk assessments or analyses, and other screening activities (including, without limitation, background checks), in compliance with legal or regulatory obligations or pursuant to our internal risk management procedures, whether required by law or implemented by us;
to prevent or investigate any actual or suspected violations of our Terms of Use, fraud, unlawful activity, omissions or misconduct, whether relating to your use of our Services of any other matter arising from your relationship with us;
to enforce our Terms of Use or any applicable end user license agreements;
to respond to or participate in any claims, actions, or legal proceedings (including but not limited to drafting and reviewing documentation, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
to comply with or as required by any applicable laws, regulations, rules, codes of practice, or guidelines issued by any legal, governmental, or regulatory authorities in any relevant jurisdiction (including, without limitation, responding to legal processes and regulatory complaints, making disclosures to regulatory bodies, and conducting audit checks, due diligence, or investigations) or we have a good faith belief that such disclosure is necessary (including, where applicable, the display of your name, contact details and company details);
to respond to any threatened or actual claims asserted against TRADEE or other claim that any content violates the rights of third parties;
taking or filming photographs and videos for corporate publicity or marketing purposes, and featuring your photographs and/or testimonials in our articles and publicity materials;
providing or marketing services and benefits to you, including promotions and/or service upgrades;
organising roadshows and/or campaigns;
matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of Services;
sending you details of Services, products / campaign updates and information, either to our user generally, or which we have identified may be of interest to you;
to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
to conduct research, analysis, and development activities (including, without limitation, market research, data analytics, surveys, profiling, product and service development), to analyse user profiles, behaviour, preferences, and demographics for the purposes of understanding usage patterns and trends, improving our products and services, enhancing the overall user experience, and offering or recommending products, services, promotions, or marketing programmes that may be relevant to your interests and profile; and/or
any other purposes which we notify you of at the time of obtaining your consent or are reasonably related to the aforesaid.
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If you have provided us with your contact details and have indicated your consent to receive marketing or promotional communications, we may use your Personal Data to send you, via various modes and mediums, marketing and promotional information and materials relating to our Services, events, promotions, and products and/or services (including those offered by third parties with whom we may collaborate or partner). Such communications may include alerts, newsletters, updates, mailers, promotional content, special privileges, festive greetings, and invitations to participate in our events or activities. These communications may be sent by us and/or our affiliates or related corporations, and may relate to current or future offerings.
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You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.
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Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the services that you have requested or purchased from TRADEE.
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DISCLOSURE OF PERSONAL DATA
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TRADEE will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the Purposes listed above (where applicable) to the following entities or parties, without limitation:
buyers or sellers you have transacted with or otherwise interacted on TRADEE Sites or in connection with your use of the Services, for the Purposes stated above;
other users of TRADEE Sites for one or more of the above-stated Purposes;
TRADEE’s subsidiaries, associated companies, jointly controlled entities, and affiliates;
Third Party Providers;
external banks, credit card companies, other financial institutions, and their respective service providers;
contractors, agents, service providers, and other third parties engaged by us to support our business operations. These may include, but are not limited to, parties providing administrative or other support services such as mailing houses, logistics providers, financial service providers, advertising and marketing partners, telecommunications companies, information technology service providers, and data centre operators;
our professional advisers such as consultants, auditors, and lawyers;
a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TRADEE’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings, in which Personal Data held by TRADEE concerning our Service Users forms part of the transferred assets; or to a counterparty in any business asset transaction in which TRADEE, or any of its affiliates or related corporations, is involved;
marketing partners and other service providers or business partners (including but not limited to cloud storage providers, data analytics providers, marketing partners and marketing platform providers, due diligence, and anti-money laundering service providers; service providers who perform identity verification services, research firms, including those performing surveys or research projects in partnership with TRADEE or on TRADEE’s behalf)
relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
any other party to whom you authorise us to disclose your Personal Data to.
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Users (including their employees, agents, representatives, or any other individuals acting on their behalf) who gain access to another User’s Personal Data through their use of the Services (the “Receiving Party”) hereby agree to:
comply with all applicable privacy and data protection laws in relation to such data, including but not limited to its collection, processing, storage, and transfer;
permit TRADEE or the User whose Personal Data has been collected (the “Disclosing Party”) to request the deletion or removal of such data from the Receiving Party’s systems or database, where required by applicable law; and
permit TRADEE or the Disclosing Party to access and review the Personal Data collected about them by the Receiving Party, in each case subject to and in accordance with applicable law.
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Notwithstanding anything to the contrary herein, Sellers (including their employees, agents, representatives, or any other individuals acting on their behalf) shall comply with all applicable privacy and data protection laws and, with respect to any buyer’s Personal Data received from TRADEE:
shall not use such data except as reasonably necessary to respond to the buyer’s inquiries or to carry out, respond to, process, or complete a transaction, unless prior written consent has been obtained from both the buyer and TRADEE;
shall not contact the buyer using such data outside of TRADEE Sites;
shall not disclose the buyer’s Personal Data to any unauthorized third party without the prior written consent of both the buyer and TRADEE;
shall implement adequate security measures to safeguard all Personal Data of TRADEE users in their possession, retain such data only for as long as necessary to fulfill the purposes described above and in accordance with applicable privacy laws, and shall delete or return such data to TRADEE upon TRADEE’s request or as soon as reasonably practicable following completion of the transaction; and
shall promptly notify TRADEE at [email protected] in the event of any actual or suspected data breach or unauthorized disclosure, access, or loss of user data.
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For the avoidance of doubt, where applicable privacy laws or other relevant legislation permit an organization such as ours to collect, use, or disclose your Personal Data without your consent, such statutory permissions shall continue to apply. Consistent with the foregoing and subject to applicable law, we may process your Personal Data based on recognized legal grounds, including compliance with legal obligations, performance of a contract with you, pursuit of legitimate interests where such interests outweigh any prejudice to your data protection rights, or where necessary for the establishment, exercise, or defense of legal claims.
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RETENTION OF PERSONAL DATA
We retain your Personal Data for the period necessary to fulfil the Purposes outlined in this Privacy Policy 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 Policy, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.
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COOKIES AND THIRD PARTY SITES
When you visit or interact with TRADEE Sites and/or use of Services, we and/or third parties may use cookies, web beacons, and other similar technologies for collecting and storing information to help provide you with a better, faster, and safer web experience.
The use of cookies (including but not limited to session cookies and persistent cookies), web beacons, and/or similar technologies (collectively, “Cookies”) by us on TRADEE Sites has different functions. They are either necessary for the functioning of our Service, help us improve our performance, or serve to provide you with extra functionalities. They may also be used to deliver content that is more relevant to you and your interests, or to target advertising to you on or off TRADEE Sites.
Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may also be linked to information concerning items you have selected for purchase and web pages you have viewed. Such information is used to maintain your shopping cart, deliver content tailored to your interests, enable our third-party advertising partners to display advertisements across the internet, perform data analytics, and monitor usage of the Services.
You may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and the cache from your internet browser. However, if you decline cookies or other similar technologies, you may not be able to take advantage of certain site features or services tools. For more information on how you can block, delete, or disable these technologies, please review your browser settings.
TRADEE Sites may contain links to other websites operated by third parties. We assume no responsibility or liability for the content, security measures (or the absence thereof), data protection practices or any activities conducted on or through such linked sites. These links are provided solely for your convenience, and your access to and use of them is entirely at your own risk. Notwithstanding the foregoing, we are committed to maintaining the integrity of TRADEE Sites and the links placed therein and therefore welcome any feedback regarding such linked sites, including, without limitation, reports of inoperative or inappropriate links. We encourage you to learn about the data protection practices of such third party websites. Some of these third party websites may be co-branded with our logo or trade mark, even though they are not operated or maintained by us. Once you have left TRADEE Sites, you should check the applicable Privacy Policy of the third party website to determine how they will handle any information they collect from you.
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SECURITY OF PERSONAL DATA
We protect Personal Data against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Data, regardless of the format in which it is held. We use various methods to safeguard Personal Data, including physical measures, technical tools, and/or organizational controls.
Online security is also a priority. TRADEE incorporates security measures such as encryption and authentication tools to protect your Personal Data from unauthorized use. Firewalls are utilized to protect our servers and network from unauthorized users accessing and tampering with files and other information that we store.
We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your Personal Data with confidentiality.
While we implement reasonable security measures in accordance with applicable privacy laws to protect your Personal Data, you acknowledge that no method of transmission over the Internet or method of electronic storage is completely secure. Third parties may unlawfully intercept or access Personal Data transmitted to or stored on TRADEE Sites, technologies may malfunction or fail, or unauthorized access, disclosure, abuse, or misuse may occur through no fault of ours. Although we will take reasonable steps to safeguard your Personal Data, we cannot guarantee absolute security, particularly in the event of malicious and sophisticated cyberattacks by unauthorized parties through no fault of ours.
Your Personal Data and/or information may be transferred to, stored, or processed outside of your country of residence for one or more of the Purposes outlined in this Policy. In most instances, your Personal Data will be processed by us in jurisdictions where our servers or data processing facilities are located. Any such cross-border transfer of Personal Data will be carried out in compliance with applicable privacy and data protection laws, and TRADEE will ensure that appropriate safeguards are in place to protect your data in accordance with those laws.
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YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
ask us about the processing of your Personal Data, including to be provided with a copy of your Personal Data;
request the correction and/or deletion of your Personal Data;
request the restriction of the processing of your Personal Data and/or object to that processing;
withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
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/or
complain to the relevant data privacy authority if your personal data privacy rights are violated, or if you have suffered 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 or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the Purposes or that you are unable to make use of 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.
In accordance with applicable laws and regulations, you may be entitled to:
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AMENDMENTS AND UPDATES
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TRADEE may modify, update, and/or amend the terms in this Privacy Policy at any time. Such amendments shall be posted on the TRADEE Sites. It is your responsibility to review the Privacy Notice regularly. Your continued use of TRADEE Sites and/or Services from TRADEE or continuing to communicate or engage with TRADEE following the modifications, updates, or amendments to this Privacy Policy, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.
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GOVERNING LANGUAGE
By agreeing to this Privacy Policy, the Parties explicitly agree that the Privacy Policy and all related documents, including but not limited to amendments, exhibits, schedules, and attachments (collectively referred to as the "Agreement"), shall be governed by and construed in accordance with the English language.
English language shall be the sole language used in interpreting and construing the terms and conditions of this Agreement, and any ambiguity or uncertainty shall be resolved in favour of the interpretation that best reflects the original English text.
In the event of any inconsistency or discrepancy between the English version of this Agreement and any translation thereof, the English version shall prevail, and any translation or interpretation shall be secondary to the English version.
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CONTACT US
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TRADEE has procedures in place in order to receive and respond to enquiries about our policies and practices relating to its handling of Personal Data. Any complaint or enquiry should be made in writing and addressed as shown below. If there are any questions or concerns regarding this Privacy Policy or the data collection practices outlined herein, please contact us as follows:
TRADEE Data Protection Officer
c/o TRADEE Technology Sdn Bhd
Level 2, Wisma IAV, Jalan Pasar,
55100 Kuala Lumpur.
Attn: [Privacy policy inquiries]
Email: [[email protected]]
You are reminded not to transmit sensitive information (including, without limitation, passwords and credit card details) through unencrypted or unsecured means, such as email.
Please note that if your Personal Data has been provided to us by a third party (including but not limited to your employer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to TRADEE on your behalf.
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