Pensonic Sales & Services (M) Sdn Bhd (hereinafter referred to as “Circlez Estore”, "us", "we", or "our") operates the website and benefits of the customers on the following purposes (hereinafter referred to as "our Service"):

• application, survey, registration and/or other similar activities;
• complaint, feedback, enquiries and/or other similar activities;
• posting of any updates pertaining to anything related to Circlez , its business partners and affiliated;
• sale and purchase of any Circlez products;
• warranty cards;
• Accessibility to Circlez website, e-store, Facebook, Live Chat, loyalty programme and/or other similar channels;
• Notifications and communications of any products and/or events / activities organised by Circlez

In compliance with the Personal Data Protection Act 2010 (PDPA), this Privacy Policy sets out how we collect, use and protect your Personal Data which you have provided to us through our Service.

This Privacy Policy notifies you on:

• the purposes of collection of your personal data
• the types of data to be collected
• the method of collection, storage and retention of your personal data
• disclosure of your personal data
• protection of your personal data
• right to access and to correct your personal data
• others

By using our Service and your submission of your personal data to our Service voluntarily, you shall be deemed to have read, understood, agreed and consented to the collection, processing and use of information in accordance with this Privacy Policy.

Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

(i) The Purposes of Personal Data Collection

Circlez App collects your personal data for the purposes as follows:

• To provide, maintain and improve our Service for your easy usage
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer care and support
• To provide analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• For billing, taxation and/ or auditing purposes;
• To provide post-sales services, such as after-sales maintenance / warranties (if any)
• To send you alerts, newsletter, updates, mailers, promotion materials, special privileges, festive greetings by Circlez, its partners or authorised third parties such as sponsors & etc
• To update you on latest products, services, promotions, events and/or launches by our company which we think may interest you
• To notify and invite you to events and/or activities organised by our company, our business
• partners or authorised third parties
• To process your registration to participate in or attend an event or activity and to communicate with you regarding the details of the event or activity
• to share your personal data with our related companies, business partners and sponsors to share with you on their latest products, services, promotions, events and/or launches by their company

(ii) The types of Data Collected

• Personal Data

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While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but not limited to:

• Email address
• First name and last name
• Identification details (NRIC / Passport No.)
• Date of birth
• Phone number
• Address, State, Province, ZIP/Postal code, City

* Any bank card details (such as credit cards / debit cards and etc); only for purposes of purchase and/or any entry of any of Circlez activities which required payments

• Cookies and Usage Data

• Usage Data

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We may also collect information that your browser sends whenever you visit our Service or when you access our Service by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access our Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

(iii) The Method of Collection, Storage and Retention of your Personal Data

(a) We may collect your personal data from a variety of sources such as:

• Application, survey, purchases, registration and/or other similar forms
• Complaint, feedback, enquiries and/or other similar forms
• warranty cards
• Circlez Website, e-store, Facebook, Live Chat, loyalty programme and/or other similar channels
• any events / activities organised by Circlez

(b) Tracking & Cookies Data

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    We use cookies and similar tracking technologies to track the activity on our Service and hold       

    certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.

You can change the setting of your browser to refuse/disable all cookies or to indicate when a cookie is being sent for your acceptance. However, if you do not accept these cookies, you may not be able to enjoy certain advantages of our Service and we are unable to communicate effectively with you.

  Examples of Cookies we use, among others are:

• Session Cookies - we use Session Cookies to operate our Service.
• Preference Cookies - we use Preference Cookies to remember your preferences and various settings.
• Security Cookies - we use Security Cookies for security purposes.

(c) Transfer Of Data
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Your information, including Personal Data, may be transferred to‚ and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Malaysia and choose to provide information to us, please note that we transfer the data, including Personal Data, to Malaysia and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Circlez App will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

(iv) Disclosure of your Personal Data

(a) Legal Requirements
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We may disclose your Personal Data in the good faith belief that such action is necessary to:

*To comply with a legal obligation
*To protect and defend the rights or property of Circlez App
*To prevent or investigate possible wrongdoing in connection with the Service *To protect the personal safety of users of the Service or the public
*To protect against legal liability

(b) Others
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• We may share your personal data to our related companies, business partners, and permitted third party to provide you better service and they are specifically required to observe our confidentiality obligations.
• We may employ third party companies and individuals to facilitate our Service ("Service Providers") to provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

(v) Protection of your Personal Data

(a) Security of Data    
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The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

You shall safeguard your unique User ID, Password, Security Code and your bank details (if applicable) by keeping them private and confidential. If you think that your User ID, Password, Security Code and/or bank details has/have been disclosed to a third party, is/are lost or stolen and unauthorised transactions may have been conducted, you are responsible to inform us immediately.

(b) Links to Other Sites   
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Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

(c) Children's Privacy  
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Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

(vi) Right to Access and to Correct your Personal Data

You may have right to access and amend your personal data from time to time.

You shall ensure that the personal information you provide to us is accurate, complete, not misleading and kept up to date, failing which, we may not be able to process your application or any relevant transaction with Circlez if your personal data provided to us is incorrect or incomplete.

If you wish to withdraw your consent to any use of your personal data, or if you have any questions, complaints relating to your personal data, or you would like to obtain access, update and make corrections to your personal data records, you may send your request/enquiry to customerservice@pensonic.com

(vii) How to delete my account?

Your data privacy is important to us. If you wish to delete your data or remove your account with us, just drop an email to us at customerservice@pensonic.com

(viii) Others

(a) Changes to This Privacy Policy
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We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will try our best endeavours to let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this page.


(b) Contact Us
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If you have any questions about this Privacy Policy, please contact us:
* By email: customerservice@pensonic.com