Privacy Policy

1.1. CDC International Sdn Bhd (hereinafter may also be referred to as "CDCi" or "we" or "us") or Speed2u and its related sites (hereinafter may also be referred to as "SPEED Site" or "Platform") take our privacy policy in accordance with the Malaysian Personal Data and Protection Act 2010 seriously.

1.2. In the course of providing the users with the access to the Platform, we will be collecting, using, disclosing, storing and/or processing data, including your personal data. In this Privacy Policy, Platform shall also refer to and/or the relevant seller platform(s).

1.3. This Privacy Policy exists to keep the users in the know about how we collect, use, disclose, store and/or process the data we collect and receive during the course of providing SPEED Site's services or access to the Platform to the users. We will only collect, use, disclose, store and/or process your personal data in accordance with this Privacy Policy.

1.4. It is important the users to read this Privacy Policy together with any other applicable notices we may provide on specific occasions when we are collecting, using, disclosing and/or processing the users' personal data , so that the users are fully aware of how and why we are using the users' personal data.

1.5. We may update this Privacy Policy from time to time. Any changes we make to this Privacy Policy in the future will be reflected on this page and material changes will be notified to the users. Where permissible under local laws, the users' continued use of the SPEED Site services or access to the Platform or express consent thereto, shall constitute its acknowledgment and acceptance of the changes we make to this Privacy Policy. Users agree that it is their respective responsibility to check back frequently to see any updates or changes to this Privacy Policy.

1.6. This Privacy Policy applies in conjunction with other notices, contractual clauses and consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of the users' personal data by us and is not intended to override them unless we state expressly otherwise.

1.7. All of these terms shall apply to all SPEED Site's users.

2.1. Personal data means any information about an individual, whether recorded in a material form or not and whether true or not, who can be identified from that data (whether directly or indirectly), or from that data and other data to which we have or are likely to have access.

2.2. During the course of the use of the Platform and the provision of the SPEED Site services, we may collect personal data about the users, as follows:

(i) Identity data, such as user name, gender, profile picture, and date of birth;

(ii) Contact data, such as billing address, delivery address, email address and phone numbers;

(iii) Biometric data, such as voice files when using our voice search function, and facial and other bodily features and voice of the user and/or another person featured in the users' video upon uploading such videos onto the Platform;

(iv) Account data, such as bank account details, bank statements, credit card details and payment details (such account data may also be collected directly by our affiliates and/or third party payment service providers);

(v) Transaction data, such as details about orders and payments, and other details of products and services related to such user;

(vi) Technical data, such as Internet protocol (IP) address, user login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, international mobile equipment identity, device identifier, IMEI, MAC address, cookies (where applicable) and other information and technology on the devices used to access the Platform;

(vii) Profile data, such as the username and password, orders related to the user, users' interests, preferences, feedback and survey responses;

(viii) Usage data, such as information on how the user use the Platform, products and services or view any content on the Platform, including the time spent on the Platform, items and data searched for on the Platform, access times and dates, as well as websites the users were visiting before the Platform and other similar statistics;

(ix) Location data, upon sharing of users' location with us in the form of photographs or videos and upload such content to the Platform;

(x) Marketing and communications data, such as the users' preferences in receiving marketing from us and our third parties, communication preferences and chat, email or call history on the Platform or with third party service providers; and
(xi) Additional information we may request for the users to submit for due diligence checks as required for identity verification (such as copies of government issued identification, e.g. passport, ID cards, etc.) or if we believe that such user is violating our Privacy Policy or our Terms of Conditions.

2.3. During the course of the use of the Platform and our provision of the SPEED Site services, we may receive personal data from the users in the situations, as follows:

(a) When the users browse our website (both mobile and web versions);

(b) When the users create an account with us;

(c) When the user lists products and/or services for sale on the Platform and conduct transactions with third parties in respect of the sale and purchase of those products and/or services through the Platform;

(d) When the users apply for, subscribe to or otherwise use any of the SPEED Site' services;

(e) When the users make a transaction regarding any products or services available on the Platform;

(f) When the users activate or use any payment-related functions available on the Platform or provided by our third party service providers;

(g) When the users use any of the features, functions, mini-apps or mobile games available on the Platform or SPEED Site services;

(h) When the users record any user-generated content which is uploaded on the Platform;

(i) When the users use the chat function on the Platform;

(j) When the users subscribe to our publications or marketing collaterals;

(k) When the users enter a competition, promotion or survey;

(l) When the users participate in any activity or campaign on the Platform;

(m) When the users log in to your account on the Platform or otherwise interact with us via an external service or application, such as Facebook or Google;

(n) When the user of the Platform posts any comments on the content the other user/s have uploaded on the Platform or when the users post any comments on other users' content uploaded to the Platform;

(o) When a third party lodges a complaint against any particular user or the content posted by such user on the Platform; and

(p) When the users interact with us offline, including interaction with our customer service agents.

2.4. We may collect personal data from the users, third parties (including but not limited to agents, vendors, contractors, partners and any others who provide services to us, who collect the users' personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial providers, credit bureaus, delivery, marketing and other service partners), our affiliates, or such data may be collected automatically during the use of the Platform or the SPEED Site services, as set out in this section. See also section 10 below on the collection of computer data.

2.5. Where we collect personal data from third parties and/or our affiliates, we will only collect the users' personal data, where permitted by law, for or in connection with the purposes for which those third parties or our affiliates are engaged, for the purposes of our collaboration with the third parties or affiliates, or for the requirement to carry out verification or due diligence checks. During the course of the use of the Platform and our provision of the SPEED Site services, users agree to provide their irrevocable consent (whether to us, the third party or our affiliates) for the transfer of users' personal data from third parties and/or our affiliates to SPEED Site for the purposes set out in this Privacy Policy or any other terms.

2.6. Users must only submit personal data which is accurate and not misleading and shall keep it up to date and inform us of any changes to the personal data which have been provided to us. We shall have the right to request for documentation and carry out the necessary checks to verify the personal data provided by users as part of our user verification processes or as required under law.

2.7. We will only be able to collect certain categories of personal data whenever the users voluntarily provide the personal data to us or as otherwise provided for under this Privacy Policy. If users choose not to provide their personal data to us or subsequently withdraw their consent for our use of such personal data, we may not be able to provide the users with certain features or functionality on the SPEED Site services or access to the Platform.

2.8. If users provide personal data of any third party to us, such user represents and warrants that the necessary consent, license and permissions from that third party to share and transfer his/her personal data to us, and for us to collect, store, use and disclose that data in accordance with this Privacy Policy, have been first obtained by such user.

2.9. Upon signed up to be a user on our Platform using the users' social media account or link the SPEED Site account to users' social media account or use certain other SPEED Site social media features, we may access personal data about such users which have been voluntarily provided to the social media provider in accordance with the provider's policies and we will manage such user personal data in accordance with this Privacy Policy.

Purpose of Use

3.1. The personal data we collect from users or via third parties may be used for certain purposes, as follows:

(a) Providing Services

i. To facilitate the use of the SPEED Site services or access to the Platform;

ii. To respond to users queries, feedback, claims or disputes, whether directly or through our third party service agents;

iii.To verify users documentation submitted to us facilitate your onboarding with us as a user on the Platform, including the testing of technologies to enable faster and more efficient onboarding;

iv. To administer users account (if any) with us;

v. To display users name, username or profile on the Platform;

vi. To verify and carry out financial transactions (including any credit card payments, bank transfers, offline payments, remittances, or e-wallet transactions) in relation to payments related to the SPEED Sit services used by users. In order to verify and carry out such payment transactions, payment information, which may include personal data, will be transferred to third parties such as our payment service providers; and

vii.To assess users' application to perform credit risk assessments in relation to SPEED Site services (where applicable).

(b) Marketing and advertising

i. To send marketing or promotional materials about our or other third parties' products and services on our Platform from time to time (provided users have opted to receive such information); and

ii. To help us conduct marketing and advertising.

(c) Legal and operational purposes

i. To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;

ii. To store, host, back up users' personal data;

iii.To prevent or investigate any actual or suspected violations of our Terms of Conditions, Privacy Policy, fraud, unlawful activity, omission or misconduct, whether relating to the use of our SPEED Site services or any other matter arising from users relationship with us;

iv. To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcement requests, in connection with any legal proceedings or otherwise deemed necessary by us;

v. Where necessary to prevent a threat to life, health or safety;

vi. To process any complaints, feedback, enforcement action and take-down requests in relation to any content uploaded by the users onto the Platform;

vii.To compare information, and verify with third parties in order to ensure that the information is accurate;

viii.To ascertain users' identity in connection with fraud detection purposes; and

ix. To facilitate the takedown of prohibited and controlled items from our Platform.

(d) Analytics, research, business and development

i. To audit the downloading of data from the Platform;

ii. To understand the user experience with the SPEED Site services and the Platform;

iii.To improve the layout or content of the pages of the Platform and customise them for users;

iv. To conduct surveys, including carrying out research on our users' demographics and behaviour to improve our current technology (e.g. voice recognition tech, etc) via machine learning or other means;

v. To derive further attributes relating to users based on personal data provided (whether to us or third parties), in order to provide users with more targeted and/or relevant information;

vi. To conduct data analysis, testing and research, monitoring and analysing usage and activity trends; vii.To further develop our products and services; and

viii.To know our users better.

(v) Other

i. Any other purpose to which users' consent has been obtained; and

ii. To conduct automated decision-making processes in accordance with any of these purposes.

Who We Disclose the Data to

3.2. We may share (or permit the sharing of) personal data with and/or transfer users personal data to third parties and/or our affiliates for the above-mentioned purposes. These third parties and affiliates, which may be located inside or outside users jurisdiction, include but are not limited to:

(i) Service providers (such as agents, vendors, contractors and partners) in areas such as payment services, logistics and shipping, marketing, data analytics, market or consumer research, survey, social media, customer service, installation services, information technology and website hosting;

(ii) Their service providers and related companies; and

(iii) Other users of the Platform or SPEED Site services.

3.3. In disclosing users personal data to them, we endeavour to ensure that the third parties and our affiliates keep such personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain such personal data only for as long as such personal data is needed to achieve the above-mentioned purposes.

3.4. We may also share personal data in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we satisfy the requirements of applicable data protection law when disclosing users' personal data.

International Data Transfer

3.5. We may transfer or permit the transfer of users' personal data outside of users jurisdiction for any of the purposes set out in this Privacy Policy. However, we will not transfer or permit any of such personal data to be transferred outside of such jurisdiction unless the transfer is in compliance with applicable laws.

Third Party Services

3.6. We may share users' personal data with our third party service providers or affiliates (e.g. payment service providers) in order for them to offer services to users other than those related to the use of the Platform or our SPEED Site services. Users' acceptance and use of the third party service provider's or our affiliate's services shall be subject to terms and conditions as may be agreed between such user and the third party service provider or our affiliate. Upon such acceptance of the third party service provider's or our affiliate's service offering, the collection, use, disclosure, storage, transfer and processing of users data (including personal data and any data disclosed by us to such third party service provider or affiliate) shall be subject to the applicable privacy policy of the third party service provider or our affiliate, which shall be the data controller of such data. You agree that any queries or complaints relating to such acceptance or use of the third party service provider's or our affiliate's services shall be directed to the party named in the applicable privacy policy.

4.1. Users may communicate the withdrawal of their consent to the continued use, disclosure, storing and/or processing of such personal data by contacting us using the contact details below, subject to the conditions and/or limitations imposed by applicable laws or regulations.

4.2. Please note that if users communicate their withdrawal of consent to our use, disclosure, storing or processing of such personal data for the purposes and in the manner as stated above or exercise their other rights as available under applicable local laws, we may not be in a position to continue to provide the SPEED Site services to such user or perform any contract we have with such user, and we will not be liable in the event that we do not continue to provide the SPEED Site services to, or perform our contract with such user. Our legal rights and remedies are expressly reserved in such an event.

Marketing Information

4.3. Users may unsubscribe from receiving marketing information at any time in our mobile application settings or by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies.

5.1. It is important that the personal data provided to us is accurate and complete for users to continue using the Platform and for us to provide the SPEED Site services. Users are responsible for informing us of changes to their personal data, or in the event such user believe that the personal data we have is inaccurate, incomplete, misleading or out of date.

5.2. Users can update their personal data anytime by accessing your account on the Platform.

5.3. We take steps to share the updates to users' personal data with third parties and our affiliates with whom we have shared such personal data if such personal data is still necessary for the above-stated purposes.

6.1. Users may request information about their personal data which we have collected, or enquire about the ways in which such personal data may have been used, disclosed, stored or processed by us via the personal account information setting on our Platform or by contacting us using the contact details below. Users may also request correction of any error or omission in such personal data which we have collected in the same way. In order to facilitate processing of such request, it may be necessary for us to request further information relating to such user. Where permissible under law, we may refuse such correction requests if deemed vexatious or unreasonable.

6.2. Where permitted by applicable data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving users' personal data records. If so, we will inform such user of the fee before processing such request.

7.1. To safeguard users' personal data from unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification or similar risks, we have introduced appropriate administrative, physical and technical measures such as:

(a) Restricting access to personal data to individuals who require access;

(b) Maintaining technology products to prevent unauthorised computer access;

(c) Using 128-bit SSL (secure sockets layer) encryption technology when processing users' financial details; and/or

(d) implementing other security measures as required by applicable law.

7.2. Users should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of users' information and are constantly reviewing and enhancing our information security measures.

8.1. We will only retain users' personal data for as long as we are either required or permitted to by law or as relevant for the purposes for which it was collected.

8.2. We will cease to retain such personal data, or remove the means by which the data can be associated with such user, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected, and is no longer necessary for any legal or business purpose.

9.1. We do not provide access to the Platform to minors (which is to be determined based on the applicable law), nor do we intend to provide any of the SPEED Site services or the use of the Platform to minors. We do not knowingly collect any personal data relating to minors.

9.2. Users hereby confirm and warrant that they are above the age of minority and are capable of understanding and accepting the terms of this Privacy Policy. If the user is a minor, such user may use our Platform only with the involvement of a parent or legal guardian.

9.3. As for parents or legal guardians, please do not allow minors under their care to submit personal data to the SPEED Site. In the event that such personal data of a minor is disclosed to the SPEED Site, such parent or legal guardian hereby consent to the processing of the minor's personal data and accept and agree to be bound by this Privacy Policy and take responsibility for their actions.

9.4. We will not be responsible for any unauthorised use of the SPEED Site services on the Platform by users, such user who act on other user behalf or any unauthorised users. It is such user own responsibility to make its own informed decisions about the use of the SPEED Site services on the Platform and take necessary steps to prevent any misuse of the SPEED Site services on the Platform.

10.1. We or our authorised service providers may use cookies, web beacons, and other similar technologies in connection with the use of the SPEED Site services or access of the Platform. 10.2. When users visit the Platform through their computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that their browser sends whenever such user visit a website, such as the technical data and usage data outlined in Section 2 above.

10.3. This data is collected for analysis and evaluation in order to help us improve our website and the services and products we provide, as well as to help us to personalise the content to match users preferred interests more quickly. The data is also collected to make the SPEED Site services and the Platform more convenient and useful to such user, and to provide more relevant advertising related to market products, services and features to such user.

10.4. Cookies are small text files (typically made up of letters and numbers) placed in the memory of users' browser or device when such user visit a website or view a message. They allow us to recognise a particular device or browser. Web beacons are small graphic images that may be included on our SPEED Site services and the Platform. They allow us to count users who have viewed these pages so that we can better understand their preference and interests.

10.5. Users may be able to manage and delete cookies through their browser or device settings. However, certain cookies are required to enable core functionality (such as adding items to your shopping basket), so please note that changing and deleting cookies may affect the functionality available on the Platform or through our SPEED Site services.

The Platform may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. Users are strongly advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.

If users have any questions on how we handle their personal data, please feel free to contact us.