EN | BM
ControlVM Sdn. Bhd. (referred below as “ControlVM“, “we” or “our“), as a ‘data user’, is concerning your privacy seriously. This Privacy Notice outlines how we collect, use, store and dicloses your Personal Information in respect of commercial transactions.
This Privacy Notice is prepared in both English (EN) and Bahasa Malaysia (BM) versions. The English version shall always prevail in case of any discrepancies or inconsistencies between English version and its Bahasa Malaysia translation.
Last Update: 9 September 2022
Effective Date: 16 September 2022
By accessing or using our website or services on or after above effective date, you’re agreed to the revisions.
“Personal Information” in this notice refers to any information in relating to you, as an identified or identifiable natural person who either directly or indirectly identified, by reference to an identifier that may includes but not limited to name, identification number, location data or online identifier.
You shall ensure your Personal Information submitted to us either electronically or manually is always complete and accurate, failing which we reserve the rights to reject / prohibit / discontinued the use of our services.
We will never request personally identifiable information from anyone under the age of 18 without first requesting parental consent. If you are below age of 18 years, you are required to submit parent / legal guardian’s concent prior visit our website, register user account or use our services.
1) What Information We Collect?
We collect your information when you visit our website, register user account with us and/or use any of our services. Such information may store for as long as we believe it is necessary, including but not limited to:
a) Your Information – Name, company/business name and registration number, home and/or business address, date of birth, age, gender, nationality, preferred language, fax number, phone numbers, E-mail address, supporting documents (government issued identification card or passport), billing information such as credit/debit card, bank, e-wallet information; or payment E-mail address.
c) Service Information – Websites that you host on our server or emails that you send and receive throughout the service period; information that you provide upon support request including but not limited to E-mail, support tickets, voice recordings of your call to us, IP addresses, usernames and temporary password.
2) When & How Do We Collect Your Personal Information?
All information that you provide to us are voluntary submissions.Your information may be collected when you:
a) register user account with us and/or subscribe to any of our services
b) when you participate any activities at ControlVM office, or website such as register your interest in information request, contact us via contact form, ticketing system or phone, place order products or services, participate in our forums, contests, polls and surveys or subscribe to our newsletter.
c) when you interact with us via public channel, social media or instant messaging, including but not limited to LinkedIn, Facebook, Twitter, Telegram, WhatsApp or,
d) other third party sources where you have given your consent for the disclosure of Personal Information including but not limited to, debt collection agencies, business directories, Companies Commission, Registrar of Businesses, Insolvency Department, credit reporting agencies or fraud record reporting agencies or, where legally permitted.
3) How We Use The Information?
We collect and use your information for the following purposes, including but not limited to:
a) service provisioning and activation
b) service billing & invoicing
c) keep you informed about our products, services, due invoices and other activities such as notices, events and promotions. Notifications will send to you, this includes SMS, emails, newsletters and other promotional material. If you do not wish to receive our E-mail or newsletter, you can always opt out at any time within the client area. In some occasions, we use third-party services who act as sub-processors for above mentioned purposes.
d) user verification purposes including but limited to verify that you are a legitimate and identifiable natural person.
e) credit status – your information is use for credit checks by sharing information about you with credit reporting agencies.
f) fraud detection and prevention – Before accepting any order from you, your information is use to validated and checked against by sharing your information to online fraud prevention service provider who act as sub-processors.
g) use your Personal Information solely for payment processing and your billing information will pass to third-party payment gateway providers, who act as sub processors to stores your billing information, in which you had given consent and authorization.
h) When you purchase SSL or top level domains (“TLDs”) from us, your information will send to our service provider or registries for service provisioning. Your Personal Information may visible on public WHOIS.
A sub-processor is a third party data processor engaged by ControlVM, intended for above listed purposes to be carried out. By providing us your Personal Information you consent to such a transfer where it required to provide you the services you have requested. List of sub-processors:
Plivo – https://www.plivo.com/legal/privacy/ (SMS or Call for user verification, service & billing reminder, OTP)
Maxmind – https://www.maxmind.com/en/privacy_policy (Fraud Detection and Prevention)
FraudRecord – https://www.fraudrecord.com/privacy-security-policy/ (Fraud Detection and Prevention)
Paypal – https://www.paypal.com/en/webapps/mpp/ua/privacy-full (Payment Gateway)
Stripe – https://stripe.com/en-my/privacy (Payment Gateway)
WHMCS – https://www.whmcs.com/privacy-policy/ (Domain registration)
MYNIC – https://mynic.my/resources/policies/data-protection-policy/ (Domain registration)
IPServerOne – https://www.ipserverone.com/pdpa-notice/ (Domain registration)
Namecheap – https://www.namecheap.com/legal/general/privacy-policy.aspx (SSL Certificate)
KICA – https://www.daousign.com/cstmrsuprt/indvdlinfprcs/formIndvdlInfPrcs.sg (SSL Certificate)
Mailchimp – https://mailchimp.com/gdpr/ (Email Marketing / Campaign)
4) How We Store and Secure Your Information
ControlVM provide services globally, your Personal Information that we collect during your sign-up or when you interact with our websites, may be transferred to and stored at our servers under our control. Regardless of which country you reside or from where you provide your information to us, by accepting our terms of service, policies and notices you explicitly authorize us and consent to transfer your Personal Information outside Malaysia where it is necessary/required to provide you the services you have requested.
When you register, placing an order or using our client portal systems for billing and support request activities, your input of information is transmitted over 128-bit Secure Sockets Layer (SSL). We DO NOT store your credit/debit card details but redirect you to third-party payment gateway to complete your payment to us. Other security measures include but not limited to employ firewalls to prevent unauthorized access. We will be taking reasonably necessary measures to maintain the safety of your Personal Information and data you store in client area.
5) Update of Personal Information
You may access and update your Personal Information that you have voluntarily provided to us via our client portal or open an ticket for such request. Additional information may further request to confirm your identify.
When your account with ControlVM is cancelled/terminated, all of your personally identifiable information is turn in “inactive” status within our databases BUT does not mean your personally identifiable information has been deleted from our database entirely. We will retain and use your personally identifiable information if necessary in order to resolve disputes or enforce our agreements.
COOKIES & TRACKING
When you browse our website, We may transfer a text file called a “cookie” to your computers storage medium through your Web browser (if you allow) that enables our websites to recognize your browser and capture and remember certain information. We may engage third-party service providers to assist us in better understanding our website visitors, particular Google analytics. You may find more information here:
Cookie itself cannot read data from the user’s storage medium and the cookies use to track user traffic trend, specifically the computer used to access the website. You always can set your browser to warn before the cookie is accepted. However, you’ll need to enable/accept cookies if you wish to participate blog and forums frequently. This information is use for our future improvement by knowing the visitors/customers navigation trend, our server loads, allow us to better customize our content to our visitors.
THIRD PARTY DISCLOSURE
We’ll not sell, rent or lease any of your information to third parties, except ControlVM entities and/or business partners or who assist us in operating our website, fraud and abuse detection, conducting our business, email marketing or servicing you. You are agreeing that ControlVM may transfer certain Personal Information (for the puposes outline at “ How We Use The Information”) to such parties to complete the commercial transactions.
We reserve the right to disclose any and all pertinent Personal Information as we, in our sole discretion, believe necessary or appropriate, where permitted by law, regulations and guidelines:
1) to judicial bodies, law enforcement agencies, government authorities, and/or regulator bodies.
2) in the event of legal challenges, enforcing of our service agreements and/or protect our rights.
THIRD PARTY LINKS
You are responsible to secure your login information, such as usernames and passwords, which allow you to access to your information stored at our client portal, NEVER share it with others. As good practice, you should change your password regularly and NEVER respond to any spoof e-mails that seem from us, making requests for change of password or information request.
You have the rights:
a) to access, update or review your Personal Information that you voluntary submitted to us
b) to withdraw your consent at any time for any data processing
c) to request portability of your Personal Information
d) to opt-out any marketing channels such as newsletter
e) to object processing your Personal Information
To exercise any of these rights, kindly contact us at [email protected], we will respond to you within 30 days. Additional information may require from you for identity verification (particularly proof of citizenship). We will retain and use your personally identifiable information if necessary in order to resolve disputes or enforce our agreements.
We are doing our best to comply to relevant requirements, If you have any concerns/questions related to this policy, please contact us at:
Aw Yeong Chee Hong
ControlVM Sdn Bhd
I-01-05, 5th Floor, Block I, Setiawalk, Persiaran Wawasan,
Pusat Bandar Puchong 47160 Puchong, Selangor, Malaysia.
Email: [email protected]