Privacy Policy and Statement
Commerce Access Sdn Bhd (“ CASB ”) which maintains the Sennego website
(www.sennego.com
) and its related sites (collectively “ Sites ”) respects the privacy of individuals with regard to personal data and views such personal data and privacy seriously.
This personal data and privacy policy and statement is formulated in accordance with the
Personal Data Protection Act 2010 (" Act "). The Act was introduced by the Government to regulate processing of personal data in commercial transactions.
For the purpose of this personal data and privacy policy and statement, "Personal Data" shall have the meaning as ascribed to it in the Act. For the purposes of this Privacy Notice, “we” shall refer to CASB.
A. INFORMATION COLLECTED
1. The Personal Data about you which we may collect includes: a. Information collected when you fill in the registration or subscription forms or updating your information with us, which may include personal data such as your name, age, gender, identity card number, race, and contact details among others.
For companies, this may include company number, address, telephone number, type of business, together with business and product information amongst others; b. The contents of all documents submitted to us; and c. Any messages or comments you submit to us in whatever manner, which may include personal data such as name, email address and telephone number.
2. In addition, we may also from time-to-time request for certain other Personal Data that may be relevant for the fulfillment of our services to you.
3. By registering for the services offered by CASB whether or not through the Sites, you have agreed and accept for your Personal Data to be processed by, when and where required, to be disclosed to identified third parties such as in (C) below.
B. PURPOSE OF COLLECTION OF PERSONAL DATA
1. By providing any of your Personal Data to CASB, you hereby agree that the CASB shall collect, retain and use the Personal Data for the following purposes: a. Processing registration for the usage of the Sites and services of CASB which includes setting up and activating your account; b. Updating your records; c. Carrying out matching procedures according to law; d. Customer Satisfaction Survey Campaign; e. Business Market Survey; f. Product Launching Campaign; g. Products and Services Awareness Program; h. To understand the customer's needs; i. To analyze the suitability of our products or services for the customer; j. To determine the customer's eligibility for our products and services; k. To set up, manage and offer products and services that meet the customer's needs; l. To assist in arrangements with other organisations (such as billing companies) in relation to a product or service if necessary; m. Promotion of new product or service; n. Notification of special offers or new services, updates and promotions; o. Providing ongoing service; p. For all ancillary purposes relating to the provision of facilities including the provision of computer, telecommunications and technology services; q. Performing statistical analysis for various objectives of products and services; r. Designing new products or services;

s. Making disclosures as may be required for any purposes herein by the instrument of law; t. To meet legal and regulatory requirements
.
C. USE AND DISCLOSURE
1. You further agree that CASB may disclose and transfer (whether in Malaysia or abroad) amongst any related or affiliated company and/or to third parties including but not limited
CASB’s agents, consultants, solicitors, auditors, contractors, suppliers, partners, advertisers, any relevant authorities, statutory bodies, regulatory bodies, organisations or any relevant financial institutions, any other persons under a duty of confidentiality to
CASB, service providers for CASB’s operational, administration and development requirements and to organizations who provide archival, auditing, professional advisory, debt collection, insurance, banking, marketing, advertising, delivery, call centre, technology, research, utility and security services to use, disclose, hold, process, retain or transfer such Personal Data for the purposes of (B) above for and on behalf of CASB.
2. CASB uses and discloses aggregated non-personally identifying information collected by us as part of CASB’s process of constantly improving our business.
3. CASB reserves the rights to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely in accordance to this clause.
D. IMPACT OF NON PROVISION OF PERSONAL DATA
1. Please note that in the event that sufficient Personal Data is not supplied, or is not satisfactory to CASB, then your application or request to CASB for any of the above purposes as set out in (B) above may not be accepted or acted upon or CASB will not be able to provide the full range of benefits and/or services.
2. Failure to supply such Personal Data may result in us unable to continue providing our services or ensure compliance with any other relevant laws or guidelines issued by regulatory or other authorities.
E. STORAGE AND RETENTION OF THE PERSONAL DATA
1. Your Personal Data shall be stored either in hard copies in CASB offices or stored in servers located in or outside Malaysia and operated by CASB or its service providers in or outside Malaysia. CASB uses a number of mechanisms in making reasonable efforts to protect the security and integrity of your Personal Data against loss, misuse, modification and alteration.
2. Any Personal Data supplied by you will be retained by CASB as long as necessary for the fulfillment of the purposes stated in (B) above or is required to satisfy legal regulatory, accounting requirements or to protect CASB’s interests.
3. CASB will also keep your Personal Data for the duration of time necessary to carry out the purpose for which your Personal Data was collected and also for the other purposes set out in this Privacy Policy and Statement.
4. CASB reserves the right to access, read, preserve, and disclose any information it reasonably believes is necessary to: a. Satisfy any applicable law, regulation, legal process or governmental request; b. Enforce the terms and conditions of service or other user policies and agreements including potential violations thereof; c. Detect, prevent or otherwise address fraud, security or technical issues.
5. CASB does not offer any online facilities for you to delete your Personal Data held.

F. CONFIDENTIALITY
1. Personal Data held by CASB will be kept confidential in accordance with this Privacy
Policy and Statement pursuant to any applicable law that may from time to time be in force.
2. Any questions, comments, suggestions or information other than Personal Data submitted to us in whatever manner will be deemed voluntarily provided on a nonconfidential and non-proprietary basis. CASB reserves the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely, including passing it to any related or affiliated company, for example, in connection with the development, and marketing of products and services to meet your needs.
G. RIGHT OF ACCESS TO PERSONAL DATA
1. Under the Act, you have the right of access to your Personal Data held by CASB on payment of a prescribed fee and to request correction of the Personal Data that is inaccurate, incomplete, misleading or not up-to-date.
2. If you have any questions regarding this Privacy Policy and Statement or if you wish to request access to your Personal Data or if you wish to correct your Personal Data or if you wish to withdraw your consent to CASB for the processing of your Personal Data for the purposes as set out in (B) above or for the transfer of your Personal Data to the parties stated in (C) above, you may send your request in writing at the following address:
Commerce Access Sdn Bhd
Address : Ground Floor, Wisma Amtek, No. 15 Jalan Tandang, 46050
Petaling Jaya, Selangor Darul Ehsan, Malaysia.
Telephone : 03-78854111
E-mail : info@casb.com.my
Subject : Personal Data Protection
3. In accordance to the Act, CASB has the right to charge a reasonable fee for the processing of any Personal Data access request.
H. CHANGES TO PRIVACY NOTICE
1. CASB reserves the right to amend this Privacy Policy and Statement at any time without prior notice whereby CASB shall place notice of such amendments on the Sites. CASB advises that you check this Privacy Policy and Statement on a regular basis.
2. Nothing herein serves to limit the rights of CASB or you under the Act.
3. Your continued usage of services offered by CASB or the Sites is deemed consent for
CASB to collect, process and store Personal Data in accordance with the above.