Privacy Policy

1. INTRODUCTION

Polaris Explorer Malaysia Sdn. Bhd. (hereinafter referred to as “we”, “us”, “our” or “the Company”) recognises the importance of protecting personal data and is committed to safeguarding the Personal Data entrusted to us. In compliance with the Personal Data Protection Act 2010 (“the Act”), this Privacy Notice (“the Notice”) sets out how we collect, use, disclose, dispose of and process your Personal Data. To enable the Company to provide its services to you, it is necessary for the Company to collect and process your Personal Data.

By communicating, engaging or dealing with the Company, or by using the Company’s services or Website, you acknowledge that you have read and understood this Notice and consent to the collection, use, processing, disclosure and transfer of your Personal Data in accordance with this Notice and the Act.

2. COLLECTION OF PERSONAL DATA

The Company may collect and process various types of personal data including but not limited to your name, date of birth, nationality, gender, residential and mailing address, telephone number, email address, occupation type, name of employer/ business contact number, company name, passport number, national registration identity card (NRIC) number, mobile phone number, IP address, images, video recordings and such other Personal Data as may be required for the purposes set out in this Notice (hereinafter collectively referred to as “Personal Data”).

The Company will obtain your express consent before processing any Sensitive Personal Data (as defined in the Act) in accordance with provisions of the Act.

3. SOURCES OF PERSONAL DATA

The Company may collect your Personal Data from the following sources, in manual or digital form, including but not limited to:

• Application forms, enquiry forms and other forms submitted to the Company;
• The Company’s Website and online platforms, including information submitted through online forms;
• Business cards and information provided by you in the course of your dealings with the Company;
• Identity cards, passports and other identification documents provided by you;
• Video recordings captured through closed-circuit television (CCTV) systems and other security or surveillance systems;
• Audio recordings, including voice recordings and telephone call recordings;
• Correspondence and communications between you and the Company, whether by email, telephone, in person or through other communication channels; and
• Other sources where you have provided your consent or where the collection is otherwise permitted or required by applicable laws.

4.PURPOSE FOR COLLECTION AND PROCESSING OF PERSONAL DATA

The Company may collect, use and process your Personal Data for the following purposes, including but not limited to:

• carrying out, administering and managing auction-related transactions;
• handling and responding to inquiries or application received from you;
• providing after-sale services and carrying out procedures relating to transactions with you;
• providing information and updates regarding services, programs, campaigns and activities of the Company, its Group or other companies affiliated with the Company;
• conducting marketing, promotional activities, market research and analysis;
• carrying out customer identification and verification;
• preventing and detecting crime, fraudulent, unlawful transactions or activities, monitoring access and investigation of incidents;
• monitoring, maintaining and improving the quality of customer service provided by the Company, including interactions conducted by telephone or in person;
• communicating with you in relation to matters concerning your transactions, enquiries, applications or dealings with the Company;
• complying with applicable laws, regulations and other legal or regulatory requirements;
• establishing, exercising or defending the Company’s legal rights and interests; and
• any other purposes which are reasonably necessary for or directly related to the above purposes or for which your Personal Data was provided.

5. PROCESSING OF PERSONAL DATA

The Company will take reasonable steps to ensure that your Personal Data, including CCTV footage and audio recordings, is processed, stored and retained only to the extent necessary for the purposes set out in Clause 4 of this Notice and/or as permitted or required by applicable laws. Access to such Personal Data shall be restricted to authorised personnel only.

Where the provision of Personal Data is necessary for the purposes stated in Clause 4 of this Notice, your failure to provide such Personal Data may result in the Company being unable to process your application, enquiry, transaction or request, or to provide you with the necessary services.

6. TRANSFER OF PERSONAL DATA

Where the Company discloses or transfers your Personal Data to third parties or entities within the Group, whether within or outside Malaysia, the Company will take reasonable steps to ensure that such Personal Data is handled in accordance with applicable laws, is subject to an adequate level of protection and is used only for the purposes set out in Clause 4 of this Notice.

7. DISCLOSURE OF PERSONAL DATA

The Company may disclose or provide your Personal Data, subject to applicable laws, to:

• the Company’s holding, subsidiary and/or affiliated companies within the Company’s group of companies (“Group”);
• service providers, agents and other third parties engaged by the Company to provide services or support in connection with the Company’s business and operations;
• the Company’s professional advisers, auditors, insurers, financial institutions and other persons where reasonably necessary for the Company’s business operations;
• governmental, regulatory and other appropriate authorities where required or permitted by applicable laws; and
• any other person where such disclosure is authorised, permitted or required by applicable laws.

8. MARKETING AND PROMOTIONAL PURPOSES

The Company may use your Personal Data for direct marketing and promotional purposes. By contacting you by email, messaging applications, telephone and/or other appropriate channels to provide information regarding Company’s services, programs, promotions and campaigns. Where required by applicable laws, the Company will obtain your consent before using your Personal Data for direct marketing purposes.

You may at any time request that the Company cease using your Personal Data for direct marketing purposes by contacting the Data Protection Officer at the contact details set out in Clause 17 of this Notice.

9. SECURITY OF PERSONAL DATA

The Company implements appropriate security measures, policies and procedures to protect Personal Data against unauthorised access, collection, use, disclosure, loss, misuse or destruction in the following manner:

• ensuring that Personal Data is retained, stored and disposed of in accordance with the Act;
• implementing appropriate internal policies and procedures for the handling and protection of Personal Data;
• ensuring that the Company’s employees are aware of and comply with their obligations in handling Personal Data and do not misuse such Personal Data;
• entering into appropriate contractual arrangements with the Company’s system vendors, couriers, service providers and other third parties to ensure the protection of Personal Data;
• conducting periodic reviews and audits of the Company’s data protection practices.

10. RETENTION OF PERSONAL DATA

The Company may retain your Personal Data for as long as is necessary for the purposes set out in this Notice and to comply with applicable laws. Thereafter, your Personal Data will be securely deleted, destroyed or disposed of unless a longer retention period is required or permitted by applicable laws.

11. USE OF COOKIES

The Company’s Website may use cookies to improve the functionality and performance of the Website, to understand how users interact with the Website. Certain cookies may be used by third-party service providers engaged by the Company to assist with website analytics, performance monitoring, marketing and promotional activities. You may configure your web browser to notify you when cookies are being used or to reject or disable cookies. However, disabling or rejecting certain cookies may affect the functionality or performance of the Website.

12. ENGAGEMENT OF THIRD-PARTY SERVICE PROVIDERS

The Company may engage third-party service providers, contractors or agents to collect, process, store or otherwise handle your Personal Data on behalf of the Company for the purposes set out in this Notice. The Company will take reasonable steps to ensure that such third-party service providers have appropriate security measures and procedures in place to protect your Personal Data and comply with applicable laws.

13. CCTV AND AUDIO RECORDING

The Company uses CCTV surveillance systems, which may include audio recording, at designated areas of its premises for security and safety purposes.

Personal Data such as CCTV footage and audio recordings collected may include your image, movements, voice and activities captured within the monitored areas. Such recordings may be used for security monitoring, crime and fraud prevention and investigation of incidents, and other purposes permitted by law. Access to the recordings is limited to authorised personnel only and such Personal Data may be disclosed to relevant third parties where necessary and in accordance with the terms set out in this Notice. The Company will retain such recordings only for as long as necessary and in accordance with the terms set out in this Notice and/or applicable laws.

By entering the Company’s premises, which are monitored by CCTV surveillance systems with audio recording capabilities, you acknowledge and consent to the collection and processing of your Personal Data in accordance with this Notice.

14. YOUR OBLIGATIONS

It is necessary for the Company to collect and retain your Personal Data. You are required to ensure that the Personal Data provided to the Company is accurate and up to date. If you do not provide us with the Personal Data as required, the Company is unable to process the Personal Data on your behalf for the purposes set out in Clause 4 hereinabove, and/or provide any of its services to you.

15. YOUR RIGHTS

Subject to applicable laws, you are entitled to the following rights in relation to your Personal Data held or processed by the Company:

• to request access to your Personal Data;
• to request the correction or updating of your Personal Data where it is inaccurate, incomplete or outdated;
• to withdraw your consent to the processing of your Personal Data, including for direct marketing purposes. In such event, the Company will be unable to process your Personal Data for the purposes set out in Clause 4 hereinabove and/or provide any of its services to you, whereupon any relationship established between you and the Company shall be terminated and cease with immediate effect.

Any request for access, correction, updating or withdrawal of consent may be made by contacting the Company using the contact details set out in Clause 17 hereinbelow. Where permitted by applicable laws, the Company may charge a reasonable fee for processing a request for access to Personal Data or other requests, to cover the administrative and processing costs incurred by the Company.

16. CHANGES TO PRIVACY NOTICE

The Company reserves the right to amend or update this Notice from time to time without prior notice. Any amendments or updates will take effect from the date stated in the updated Notice available on our website, www.allu.my (“Website”), unless otherwise stated.

17. CONTACT US

You can contact us or submit your inquiry and/or complaints in regard to the processing of your Personal Data at: