Privacy Policy
We, DTR Leading Technology Resources SDn Bhd and our affiliate (“DTR”, “Company” or “We”) value your privacy and are committed to safeguarding your personal information and being transparent about the data we collect and how we use it. Our Privacy Policy applies to all interactions you may have with DTR and is intended to help you understand our practices concerning the collection, use, and disclosure of information. We retain the right to amend or update this Privacy Policy at any time. The updated version will be indicated by an updated “Last update” date, and the updated version will take effect immediately as soon as it is accessible. Please note: It is vital to read and understand our Privacy Policy. By engaging in any form of communication with DTR, you acknowledge you have read and understood this Privacy Policy. Should you disagree with our policy, we kindly ask you not to interact with any aspect of our business.
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Your privacy is important to us. We're committed to protecting your data and being transparent about how we handle it. Our Privacy Policy covers all your interactions with us and is designed to help you understand how we collect, use, and share information. When you communicate with us in any way, you acknowledge that you've read and understood this Policy. If you disagree with any part of it, you should not interact with us.
1. Your Global Privacy Rights
1.1. No matter where you live, where you reside, where your citizenship lies, or where your data originates from, your interactions with DTR are governed by this Privacy Policy, and you agree to the data practices described in this policy.
2. Data We Handle
2.1. Scope of Engagements. Information collection and processing occur through various interactions, including but not limited to: (i) Customers using our services via different platforms, e.g., Website, Marketplace, Developer Program, Partner Program, Services API, or any other products or services we offer (collectively referred to as “Services”), or (ii) Non-Customers connecting with us outside service agreements, like (a) Visitor visiting/navigating our online website (website URL) operated by us (“Website”) or otherwise communicating with us through various communication channels in whatever form, including but not limited to social media channels, phone/e-mail, the chat window on our Website, or giving feedback and making inquiries or signing up for our marketing communication or our newsletters, and (b) Participant attending events we host. All these interactions are referred to as “Engagements” within this policy irrespective of the depth or nature of your association with us.
2.2. Roles in Data Handling. This policy applies uniformly to all engagement types, whether you’re just a casual Visitor, a paying Customer, a prospect, or an event Participant. Depending on the Engagements you use, our role in processing your data might be as: (i) a data processor, under an Agreement with you, when you control the information we process, or (ii) a data controller handling Personal Data collected during your interaction with us independently of the Agreement.
2.3. Grounds for Processing. When acting as a data controller, signifying that we have authority over the reasons and methods behind processing your Personal Data, we rely on various legal bases for processing your data. These include: (i) Your request: to fulfill our commitments to you and to respond to your requests, (ii) Legal Compliance: to adhere to our legal obligations, (iii) Your Consent, and (iv) Legitimate Interests: such as providing you with our Engagements functionality (e.g., Website, chat window), supporting their continuous improvement, operational management, understanding its use, maintaining the reliability of our systems and related technologies, and other customer service and support purposes. In such scenarios, we consistently strike a balance between our interests and your privacy rights. As a data processor, our relationship is governed by the Agreement with you, which sets out our respective obligations and rights.
2.4. Sensitive Data Caution. When using our Engagements, avoid sharing (or having us send) any sensitive data (like genetic data, biometric data, or health data, as defined by applicable data protection laws and regulations). You acknowledge that we bear no liability whatsoever for such data you provided to us, whether in connection with a data breach or otherwise.
2.5. Types and Sources of Data. Our Engagements may collect and process your information, including Personal Data, depending on how you interact with us, the choices you make, and the Engagements and features you use. The sources of this information include what you share, our automated systems, and third-party sources and contain both your Personal and Non-Personal data, including, but not limited to:
- Identifiers: Contact information and Account-related details, e.g., your full name, email address, physical address, phone number, IP address, user name, password, and other identifiers you provide.
- Commercial Information: Transactional information, e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories and tendencies, payment data, Account information, and supporting tickets.
- Electronic and Network Activity Information: This includes records of your interactions with our Engagements (e.g., Website, chat window, and chat logs, Website history) and other records, e.g., pages visited, links clicked, referring URL, records on how you reached and used our Engagements, performance metrics, start and end times of your interactions, and other actions taken on our Engagements and details of such actions.
- Device and Geolocation: e.g., IP address, operating system, device type, browser details, country preferences, mobile network information, and device phone number, location, and your geographic region.
- Shared Content: e.g., data you share during events, on social media, community, blogs, via chat window on our Website, survey and feedback forms, etc.
- Inferences: Profiles created based on your data reflecting your interests, characteristics, preferences, and demographics.
Some of this information comes from third-party sources (e.g., cookies, web beacons, and other tracking technologies) to help us serve relevant ads and other services to you, as explained further herein. Note that our Privacy Policy does not apply to any third-party sources, their products, or sites that may be displayed to you, or other sites linked to or from our Engagements. Additionally, our Privacy Policy does not address the practices of other entities who advertise our Engagements, and who may use tracking technologies (like cookies, pixel tags, and other technologies) to provide and personalize ads, and you should refer to their respective privacy policies for more.
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How We Collect Data:
We collect and process information through various interactions, whether you're using our Services, visiting our Website, or attending events. We call these interactions "Engagements" in this policy.
Our Role:
We might handle your data in different ways, depending on how you interact with us. Sometimes, we control your data; other times, we process it based on a contractual relationship with you.
Why We Process Your Data:
We use your data to provide our Services, fulfill a request you've made, comply with the law, follow your instructions, operate with your consent, or use the data in ways that help us provide and improve our Services, all while respecting your privacy.
What Data We Collect:
We collect and process your information, including Personal and Non-Personal data, based on your interactions and choices. Sources include what you share, our systems, and third-party sources. This can include your name, last name, contact details, what you subscribe to, your online activities on our Website, your device details, location, and any opinions or preferences you share.
Data from Other Sources:
We also get data from cookies and similar tech tools, which help us show you relevant ads and improve our Services or your customer experience. Remember, our policy doesn't cover third-party sites or ads.
Be Careful with Sensitive Data:
Please avoid sharing sensitive information while using our Engagements (like health or biometric data) with us. We are not liable for such data.
3. How We Process Your Information
3.1. Processing Purposes. As long as we process your information, including your Personal Data, we will continue to do so for the following purposes:
- Service Delivery and Enhancement: To provide, maintain, operate, and improve the Services, Services API, Partner Program, our Website, chat window, and related technologies including collecting and analyzing statistical information about you and your interactions with our said services. This includes: (i) facilitating effective service delivery, (ii) continuously improving the said services and our related technologies, as well as monitoring their performance, (iii) researching, developing, and innovating new services, products, features and related technologies, (iv) providing testing, training, machine learning capabilities, (v) providing customer support services, resolving issues, and requests for assistance, (vi) enabling Partners and Developers to access Customer Personal Data during its authorized processing, (vii) as otherwise provided in our Agreements with you.
- Safety and Security: To ensure and improve the security of the Engagements and related technologies, preventing fraud and abuses; monitoring the performance of the Engagements, retaining data for backup and disaster recovery purposes, debugging as well as detecting fraudulent, illegal, and malicious activities.
- Compliance and Protection: Meeting legal obligations, including billing, law enforcement, government, court inquiries, investigations, subpoenas, or similar legal processes, or as otherwise required or permitted by applicable laws and regulations, including other public authorities. Protecting your vital interests, safety, and property, and the interests, safety, and property of others.
- User Engagement and Personalization: To personalize your experience, including displaying relevant content and recommendations, improving your user experience, and presenting targeted advertisements and promotions, and enabling participation in interactive features, surveys, and contests.
- Marketing and Communication: To send you information about our products and services, respond to your inquiries, offer promotions, and provide updates and other relevant communication. You may opt-out of receiving such communication via your email settings or device preferences.
- Data Insights: Aggregating and analyzing information to create insights about your interactions with our Engagements for research, development, and statistical purposes.
3.2. Registration Data. When you register for our Services or create an account, we collect the data necessary to provide you with access to your account, including registration and other account details.
3.3. Data Compliance. We process your data in accordance with applicable data protection laws and regulations. Depending on your location, certain additional rights may apply.
3.4. Profiling Activities. We use automated means to create profiles and improve your experience with our Engagements. If you wish to opt-out, please contact us at [email protected].
3.5. Customer Responsibilities. Customers are responsible for ensuring that their use of our Services complies with applicable laws and regulations and obtaining necessary permissions for data processing.
3.6. Access and Managing Your Data. You have the right to access, correct, or delete your data. Please contact us at [email protected] for any requests.
3.7. Deleting Your Data. Upon request, we will delete your data in accordance with our data retention policy and applicable laws. Our standard response time for such requests is 30 days.
3.8. Geo-Location Data. We may collect geo-location data from your device or IP address for service functionality.
3.9. Communication. By engaging with us, you consent to receiving communications about our Services. You may manage your communication preferences via your device settings.
3.10. Customer Logos. Customers grant us the right to use their logos and names for marketing and promotional purposes.
3.11. Data of Agents, Guest-Users, and End-Users. We may process data of your agents, guest-users, and end-users in accordance with our Agreement with you.
3.12. Links and Promotions. Clicking on links or promotions may result in data sharing with us. We are not responsible for third-party privacy practices.
3.13. Children’s Data. We do not knowingly collect data from individuals under 16. If you believe we have collected such data, please contact us.
3.14. Cookies and Tracking Technologies. We use cookies and similar technologies to enhance your experience. Refer to our Cookie Policy for details on managing cookies.
3.15. Mobile Analytics. We use mobile analytics tools to understand app functionality. Information collected may be linked to personal data.
3.16. Social Media Features. Our Site includes social media features which are governed by the privacy policies of the respective social media providers.
3.17. Comment System. To post comments on our blogs, you must use social media logins. Your email address will be used solely for blog notifications.
3.18. Community, Forum, and Testimonials. Information shared in community forums, testimonials, or public areas may be accessed by others. Please be aware of this when sharing information.
3.19. Surveys and Feedback. Participation in surveys and feedback forms is voluntary. Data collected may be used for various purposes, including improving our Services.
3.20. Third-Party Login Services. Using third-party login services may result in data sharing according to the third-party provider's privacy policy.
4. Contact Us
For any questions or concerns regarding this Privacy Policy, please contact us at [email protected].