VLT DATA PROTECTION NOTICE
This VLT Data Protection Notice (“Notice”) describes how VLT Atelier (“VLT”) either itself or through a third party engaged by VLT which may include any service provider, uses your Personal Data.
VLT shall have the right to modify, update or amend the terms of this Notice at any time by placing the updated Notice on the VLT website (“Website”) at the following link: www.vltjewelry.com. By continuing to communicate with VLT or use VLT services following the modifications, updates or amendments to this Notice, such actions shall signify your acceptance of such modifications, updates or amendments.
Collection of Personal Data
2. The provision of certain Personal Data is mandatory in certain circumstances and if you do not provide such Personal Data, VLT will not be able to provide you the products or services you have requested. In most circumstances, the provision of your Personal Data is voluntary but if you do not provide VLT with your Personal Data, VLT may not be able to provide the products or services you have requested or attend to your request in an efficient manner and you may not be able to enjoy the benefit of offers and promotions by VLT.
Sources of Personal Data
3. In addition to the Personal Data you provide to VLT directly, VLT may also collect your Personal Data from a variety of sources, and in various ways such as:-
a. Through your access and use of the Website, social media pages and other online and telephone services, including the customer call centre;
b. During interactions and communications between individuals and VLT representatives and/or third parties;
c. When you complete an application form, enquiry form, purchase order, questionnaire, competition or survey;
d. When you provide feedback regarding VLT products, services or Website;
e. When you participate in VLT offers and promotions;
f. From third parties such as VLT authorized third party service providers.
Purposes of Processing
4. VLT may use and process your Personal Data to provide you the products and/or services you have requested, to perform the contract you have entered into with VLT and for the purposes relating to the business and activities of VLT which shall include, without limitation the following (“the Purposes”):
a. to process, confirm and fulfill your requests regarding VLT products, services or transactions;
b. to contact you regarding your purchases, enquiries and requests;
c. for user identification for login to Website, portals and other online services provided by or on behalf of VLT;
d. to comply with or to enforce the terms and conditions of any contract or agreement entered into by or on behalf of VLT to which VLT is otherwise bound or is obliged to observe;
e. to process payment transactions;
f. for payment gateway;
g. for internal administrative purposes, such as auditing;
h. for internal and external investigations;
i. for purposes of detection, prevention and prosecution of crime;
j. to conduct audit and investigations, and manage risks and crises;
k. to enforce or defend VLT or its affiliates’ legal rights, interests or property and/or to obtain legal advice;
l. for VLT to comply with its obligations under law whether within or outside Malaysia;
and you agree and consent to VLT using and processing your Personal Data in the manner as identified in this Notice.
Marketing and promotional purposes
5. Unless you have indicated otherwise, VLT may also use and process your Personal Data for marketing and advertising purposes such as to send you communication regarding VLT latest offers, promotions, products or services such as newsletters or flyers by way of e-mail, post, phone calls and social media platforms (“Marketing Purposes”).
If you do not consent to VLT processing your Personal Data for the Marketing Purposes, please unsubscribe or make such indication by way of the “opt-out” check box (as the case may be).
Disclosure and Transfer of Personal Data
6. Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than Malaysia, such as in the following circumstances:
a. where VLT administrative functions are being performed outside of Malaysia;
b. where VLT or its service providers’ servers or back-up servers are located outside of Malaysia;
c. where personal information is required to be disclosed to various law enforcement agencies outside of Malaysia;
d. where VLT service providers, contractors, agents or partners are located outside of Malaysia;
and you understand and consent to the transfer of your Personal Data out of Malaysia as described herein.
7. Your Personal Data may be transferred, accessed or disclosed to third parties for the Purposes or for Marketing Purposes. Further, VLT may engage other companies, service providers or individuals to perform functions on VLT’s behalf, and consequently may provide access to or disclose your Personal Data to such service providers or third parties. The third parties referred to in this section include (without limitation):
a. VLT professional advisors, including legal advisors, auditors, accountants and consultants;
b. service providers such as VLT’s information technology (IT) service provider;
c. VLT’s social media agency; and
d. regulatory and governmental authorities within and outside Malaysia, in order to comply with statutory and government requirements.
Your Personal Data may also be shared in connection with a corporate transaction involving VLT, such as an incorporation, sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up or bankruptcy.
Personal Information from Minors and Other Individuals
8. As a parent or legal guardian, please do not allow the minor (individuals under 18 years of age) under your care to submit Personal Data to VLT. In the event that such Personal Data is provided to VLT, you hereby consent to the processing of the minor’s Personal Data as his/her parent or legal guardian and personally accept and agree to be bound by this Notice and take responsibility for his or her actions.
Access & Correction Requests, Inquiries or Complaints
9. Subject to any exceptions under applicable laws, you may request for access to and/or request correction of your Personal Data, request to limit the processing of your Personal Data for the Purposes or for Marketing Purposes and/or make any inquiries or complaints regarding your Personal Data by contacting:-
Customer Service Representative
10. Please note that if you withdraw your consent for VLT to process your Personal Data for the Purposes or for Marketing Purposes, VLT may consequently not be able to transact with you and may be unable to provide you the products or services which you have requested.
11. In respect of your right to access and/or correct your Personal Data, VLT has the right to refuse your requests for reasons permitted under law, such as where VLT is not supplied with such information as is reasonably required to locate the Personal Data to which the data access request relates or ascertain in what way the Personal Data to which the data correction request relates is incorrect.
Acknowledgement and Consent
12. By communicating or engaging with VLT, or using VLT services, you acknowledge that you have read and understood this Notice and agree and consent to the use, processing and transfer of your Personal Data by VLT as described in this Notice.
- This document was last updated on July 1, 2018.