Last modified on 20th April, 2022.
Otomate Me Sdn Bhd (“KWActivate”, “we” or “us”) recognizes the importance of privacy for our customers and users. We want to be transparent about how we collect and use information in connection with the website www.kwactivate.com (the “Site”) and any service offered by the company, provided in connection with the Site or otherwise (the “Services”). Thus, we developed a privacy policy (the “Privacy Policy”) that applies to the Site and Services, and this is incorporated by reference into the Site Terms of Use.
In this Privacy Policy, we’ll often refer to “Personal Information”. This is information that identifies (directly or indirectly) a particular individual. Personal Information may include (without limitation) your first name, last name, email address, and phone number, and you may provide Personal Information to us in many ways including on our forms, surveys, applications or during account creation.
In this Privacy Policy, when we refer to “you” or “your,” we mean any person accessing the Site. If the person accessing this Site acts on behalf of another person or entity, “you” or “your” also means that other person or entity. By submitting Personal Information through the Site or Services, you are providing your permission and consent for the collection, use, retention and disclosure of Personal Information as set forth in this Privacy Policy.
The Privacy Policy describes the following:
- How we collect information (including Personal Information) and what types of information we collect
- How we use and safeguard Personal Information
- Your rights and choices regarding how Personal Information may be used and disclosed.
Before we discuss the types of information we collect, please note that use of our Site and Services is strictly limited to persons who have attained the age of majority in the jurisdiction in which they reside; you must be at least eighteen (18) years old to use our Site and Services in any jurisdiction. KWActivate does not knowingly collect or store any Personal Information or any information from any persons under the age of 13. If KWActivate discovers that Personal Information of persons under 13 years of age has been collected or stored, KWActivate will take the appropriate steps to delete this information from our systems.
I. Information We Collect
Information You Provide Voluntarily to Us
We collect Personal Information from you directly. For example, we may obtain Personal Information when you request information, products or services from or otherwise interact with the Site or Services, or fill out a Registration Form.
We may also collect Personal Information through your access to your account(s) online, as well as your asking questions through our “Contact Us” link, such as your name, address, e-mail address and other contact information. We may also collect data resulting from your activity on the Site, such as transaction information.
Information We Collect Automatically
We collect navigational information about where visitors go on our Site and information about the technical efficiencies of our Site and Services. In the process of gathering navigational information, anonymous information may be collected which will provide information to us regarding use of our Site. Anonymous information is information that does not directly or indirectly identify, or cannot reasonably be used to identify, a particular individual. Examples of anonymous information may include information about your Internet browser, domain type, usage statistics, and service provider, collected through tracking technologies and aggregated or de-identified data.
We may also collect anonymized location information or your IP address for analytics purposes, and we may authorize third parties to do so. This information may be collected from your mobile device’s location-aware features when you request certain services that are dependent on your physical location.
Cookies and Other Tracking Mechanisms
Depending on how you access and use our Site and Services, you may use a browser feature known as a "cookie." A cookie is a piece of data stored on the computer that runs an Internet browser and is commonly used to store information about a user’s online activities, including information such as the content or advertisements that a user views or the pages a user visits within a particular website. A cookie can contain information about you, your computer, your browser, your session, the websites you visit and other information about you or others who use, or have used, the computer or browser you use to access the Internet. Cookies are used for record-keeping purposes: the stored information can be retrieved by our website server when you return to the website. This allows us to personalize or regulate the use of this Site, and it also permits us to automate the access and data entry functions of this Site (e.g., login information), and to tailor the appearance or presentation of this Site to your preferences or interests.
We use cookies as a convenience feature to save you time, to understand how our Site is used, and to improve the content and offerings on our Site. For example, we may use cookies to personalize your experience at our web pages or recall your specific information on subsequent visits (e.g., to recognize you by name when you return to our Site). We may also use cookies to offer you or inform you of products, programs or services and targeted advertising. You can opt to have your browser reject cookies.
Most or all browsers permit you to disable or reject cookies. You can do this by adjusting your preferences in the browser.
Do Not Track
KWActivate does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to “Do Not Track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information about an individual consumer's online activities over time and across third-party Web sites or online services. Accordingly, your selection of the “Do Not Track” option provided by your browser may not have any effect on our analytics or tracking tools. Use the “Help” feature of your browser to obtain more information about refusing cookies. If you set the browser you use to reject cookies, you may not be able to access the Site or use the full functionality of the Site, or it may take additional time to utilize such functionality. If you opt to reject cookies, you may need to re- register with us every time you visit our Site. Your continued use of our Site reflects your consent to allow additional cookies to be placed on your computer to help you navigate the Site.
Pixel Tags, Web Beacons and Similar Technologies
These are typically small pieces of data that are embedded in images on the Site, our applications or certain e-mail communications. They may involve the transmission of information directly to us, to another party on our behalf or to another party in accordance with its privacy policy. We may use these technologies to compile information we collect about you.
Clickstream Data
As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can identify the type of computer and browsing software you use and the address of the website from which you linked to the Site. We may use clickstream data as a form of non-Personal Information to anonymously determine how much time visitors spend on each page of the Site, how visitors navigate throughout the Site and how we may tailor our web pages to better meet the needs of visitors.
Log Files
KWActivate or our hosting provider may collect traffic information from visitors for statistical analysis and Site improvement. When you access the Site, we (or our hosting provider) may collect information about your visit in a log file on a server. Log file information may include, but is not limited to, internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/ exit pages, platform type, date/time stamp, and number of clicks. We (or our hosting provider) use this information to analyze trends, administer sites, track users’ movements in the aggregate, and gather demographic information for aggregate use. We (or our hosting provider) may review this information to better understand overall trends and to determine what kinds of content are popular with and useful to users.
Information Other Websites Collect from You
Our Site may contain links to other websites operated by other parties whose practices may be different than ours. When you click on such links and visit such other websites, you need to be aware that we may not control such other websites or such other websites’ business practices, and that this Privacy Policy does not apply to such other websites. Consequently, the operators of such other websites may collect different kinds of information about you and may use and disclose that information in different ways than we would if it were collected on the Site.
II. How We Use Information
We may use your Personal Information to help us improve our product and service offerings, improve the Site’s functionality process queries on the Site, to contact you when necessary in connection with products or services you accessed or inquired about via the Site (i.e. troubleshooting your account), to provide you with account login credentials, and to send you information, offers and other promotional materials from us and selected third parties. We may also use your information for analytics purposes to assist us in understanding how you use the Site or Services and to improve our Site or Services. Below is how we use specific categories of Personal Information.
E-mail Address
We may use your e-mail address and phone number to provide customer service information or answer your questions and requests. We may also occasionally send you our e-mail and WhatsApp updates, notifications or other information about our products and services or about the products and services of our affiliated companies.
Financial Information
By engaging in any kind of activity on the Site that uses financial information, you consent to our using your financial information, including credit card information, or providing your financial information to our service providers and to such third parties as we determine is necessary, to process your transactions. These third parties may include banking institutions used to process these transactions. Any of these various third parties are authorized to use your financial information in accordance with our contractual arrangements with such third parties and in accordance with their own privacy policies, over which we have no control.
Demographic Information
We may use demographic information to tailor the Site and communications to the interests of our users. We may share anonymous, aggregated (grouped) demographic information with our advertisers and other third parties so that they can tailor their advertisements and communications to the appropriate audience. If you consent to have us share, or we are otherwise allowed to share, your Personal Information, as described herein, then the demographic information that we provide to third parties may be linked to your Personal Information so that such third parties will be able to know about your demographic information on a non-anonymous basis.
Third-Party Email Account Syncing
KWActivate allows you to connect our Services to your company and personal email addresses for the purpose of accessing your dedicated KWActivate Google Sheet. We require a small set of permissions on your third-party email account to be able to do this and will only use it for the purpose of providing you with our Services or for diagnosing issues related to your KWActivate account. KWActivate will not use your email account information for any purpose other than providing the Services to you. KWActivate is not responsible for any issues related to your third- party email account.
III. Disclosure of Information
Except as described in this Privacy Policy, we do not disclose information about your individual visits to our site, or Personal Information that you provide to any outside parties, except when we believe, in good faith, that such release is reasonably necessary to (i) comply with any law, or (ii) protect the rights, property or safety of KWActivate, our users or third parties.
Disclosure to Agents
We may provide information about you (including your Personal Information) that you have provided to us through the Site to third parties (“Agents”) that provide services to help us with our business activities such as to host or maintain our Site; for data processing services; to provide website or data security; to provide operational, analytical or reporting services; or to provide technical support. In connection with providing those services to KWActivate, an Agent may have access to your Personal Information, but such Personal Information will be disclosed to Agents in a manner consistent with our Data Security processes, will not be used for any purpose other than as KWActivate authorizes, and it will not be disclosed by the Agents to any third party.
Disclosure to Legal Authorities
KWActivate may disclose your Personal Information when required by subpoena, court order or other legal process, or if it has a good-faith belief that disclosure is necessary to (a) comply with any applicable federal, state or local law or regulation, (b) assist government enforcement agencies, (c) investigate, prevent or take action in connection with suspected or actual illegal activities, (d) investigate suspected or actual violations of Otomate Me rights, (e) protect the rights, property or safety of Otomate Me and its customers or employees, or others, (f) investigate and defend against any third-party claims brought against Otomate Me or (g) protect the security and integrity of our Site.
Disclosure for Corporate Transactions
We consider the information that you provide to us to be a business asset. Accordingly, Otomate Me may disclose Personal Information and other information about you to a third party in connection with the sale, assignment or transfer of some or all of the assets of Otomate Me or as the result of a change in control of Otomate Me, in which case we will require any such third party to treat any such Personal Information in accordance with this Privacy Policy. Any such third party to whom Otomate Me sells, assigns or transfers Otomate Me assets will have the right to use the Personal Information and other information that you have provided to us.
Disclosure of Anonymized Information
Otomate Me reserves the right to use and disclose anonymized information, aggregated information or publicly available information that has not been combined with nonpublic Personal Information for any purposes including without limitation KWActivate’s internal use and research.
However, Otomate Me will not disclose information, even in anonymized, aggregate, or derivative forms, that is made available by our connection to providers such as Google in accordance with the Additional Requirements for Restricted Scopes as specified by Google. When connecting to KWActivate, Otomate Me will only make use of the information necessary to render our service so that we can display our user interface and perform requested actions on your account.
Promotional Materials
We may contact you for promotional purposes via email, phone, and WhatsApp. We recommend that users who no longer wish to receive promotional materials or have their information provided to third parties modify their account settings, as you may have chosen to receive promotional materials in the account registration process. If you are still receiving promotional materials 30 days after modifying your account settings to no longer receive such emails, you may contact us directly using the information below and we will use commercially reasonable efforts to comply with changes you request. Note that our compliance with such requests in certain cases may involve batch processing and other processes that take 30 days or longer. If you require an immediate change to your Personal Information and are unable to make such a change using the available Site resources, please contact us. If you opt not to receive such communications or to allow us to share your information and then you give your Personal Information to us again by using the Site or under other circumstances that permit us to use your information, we will regard your opt-out as having been rescinded. Also, please note that users may not necessarily opt out of receiving all communications from us or opt out of sharing certain information with third parties, as specified as being necessary in various portions of this Privacy Policy.
You may additionally opt out of receiving email and phone communications by using the opt-out instructions included in an email you may receive from us.
Please note that changing or deleting your information through the Site, or otherwise opting out of receipt of email communications from us and third parties, will only change or delete the data in our database for purposes of transacting future business on or relating to the Site and for managing future communications from us and third parties. These changes and deletions will not change or delete information collected or submitted pursuant to any customer agreement, or information already collected as part of a product or service purchase in our transactions database which may be shared with our third-party service providers regardless of your preferences.
Disclosure To Authorized Third Parties
There are links on our Site that direct users to third-party websites. If you follow any such links and you enroll in the respective services, your name and other requested information will be transferred to the operators of the respective third-party website. If you choose to use these third-party services, please review the third-party website’s terms of use and privacy policy prior to any transfer of your personal, or other, information. KWActivate is not affiliated with such third-party websites, and you therefore acknowledge and agree that your use of such third-party websites is at your own risk, and Otomate Me will not be responsible for the operation of such third-party websites or your access and use thereof.
We may also contract with some third parties to monitor certain pages of our website for the purpose of reporting website traffic, as well as to provide offers and advertisements that may be of interest to you. Where authorized by us, these third parties may use cookies and/or other monitoring technologies to compile information about our website visitors.
IV. Your Rights and Choices
Account. In order to keep your personal information accurate and complete, you can log in to review and update your account information, including contact and billing information, via your account settings page. You may also contact us to request information about the personal data we have collected from you and to request the correction, modification or deletion of such personal information. We will do our best to honor your requests subject to any legal and contractual obligations. If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at support@otomateme.com or the address set forth at the end of this Privacy Policy. Subject to applicable law, we will retain and use your account information only as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
E-mail and Phone Communication. As described above, if you do not wish to receive promotional emails and phone communications from us, you may opt out at any time by following the opt-out link contained in the email itself. Please note that it may take up to ten (10) days to process your request. Please also note that if you opt out of receiving marketing communications from us, we may continue to send to you service-related emails which are not available for opt-out. If you do not wish to receive any service-related emails from us, you have the option to deactivate your account.
Cookies. You may also refrain from providing, or withdraw, your consent for cookies. Your browser’s help function should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time.
Third Party Analytics Services. Some of the services used provide the ability to opt-out. You may opt-out of Google Analytics’ using Opt-Out Features on their respective websites.
The Google Analytics service is provided by Google Inc. You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool: tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: www.google.com/policies/privacy.
Additional Rights. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
V. Users Outside Malaysia
The KWActivate Site and Services are hosted in Malaysia and Singapore and are governed by Malaysia law. If you access the Site or Services from outside Malaysia, please be advised that the information you provide KW Activate may be transferred to, processed and stored in the Malaysia and Singapore where the Otomate Me servers are located and our central database is operated. You acknowledge and understand that the data protection and other laws of Malaysia might not be as comprehensive as those in your country. By your continued use of the KW Activate Site and Service, you consent to the your personal information being stores in Malaysia and Singapore.
VI. Data Security
Otomate Me takes reasonable precautions to protect Personal Information provided to us through the Site from loss, misuse, unauthorized access, disclosure, alteration and destruction. Otomate Me has put in place reasonable and appropriate physical, electronic and managerial procedures designed to safeguard and secure such Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction. Our security and privacy policies are periodically reviewed and enhanced as necessary. While Otomate Me strives to undertake such reasonable and necessary efforts to secure Personal Information provided to us through the Site, even such security measures do not guarantee the security of all Personal Information, and Otomate Me cannot guarantee that the Personal Information it collects, uses and retains will be protected in all circumstances, including those beyond Otomate Me’s reasonable control.
Particularly sensitive information is encrypted. You can usually tell whether encryption is being used by noting the “locked” or other status indicator on the browser you are using. If the browser you are using does not indicate that the session is secure (e.g., by displaying a lock, a key or a similar icon), you should assume that the connection is not secure and that third parties will receive the information shared by you and us during that part of the session. Your information may be transferred to and maintained on computer networks that may be located outside of the state, province, country or other governmental jurisdiction in which you reside, and the country or jurisdiction in which these computer networks are located may not have privacy laws as protective as the laws in your country or jurisdiction.
Below is a non-exhaustive list of our security procedures: All customer data has at-rest and in-transit encryption
User passwords and other similar user secrets are salted and stored with a one-way hash using the SHA-256 algorithm
Backups of data are stored for a maximum of 45 days
All compute resources that handle customer data are firewalled behind a virtual private cloud (VPC)
Tight security rules are in place to allow only the minimal points of access to our VPC for the purposes of serving and maintaining our products
Full-time technical employees have limited access to customer data based on their role and job function
Otomate Me has no technical contractors at this time and if any are contracted in the future they will get minimal, temporary access to production on a need-to-have basis
We rely on Stripe for all our payment processing: in terms of credit card information, we only have access to the last 4 digits of someone's card our Stripe account
VII. Changes to This Privacy Policy
This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, and if we do we’ll post any changes (material or otherwise) on this page. Please check back periodically, as you agree to any revisions to the Privacy Policy by continued use of the Site or Services.
VIII. Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at support@otomateme.com.
