PRIVACY NOTICE
Last updated February 28, 2022
Thank you for choosing to be part of our community at The University of
Malaya
, doing business as UM ("UM," "we," "us," or
"our"). We are committed to protecting your personal information and your right to privacy.
If you have any questions or concerns about this privacy notice or our practices with regard to your
personal information, please contact us at admin@jomprep.com.
This privacy notice describes how we might use your information if you:
- Download and use our mobile application — JomPrEP
- Engage with us in other related ways ― including any sales, marketing, or events
In this privacy notice, if we refer to:
- "App," we are referring to any application of ours that references or links to this policy,
including any listed above
- "Services," we are referring to our App, and other related services, including any sales,
marketing, or events
The purpose of this privacy notice is to explain to you in the clearest way possible what information we
collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy
notice that you do not agree with, please discontinue use of our Services immediately.
Please read this privacy notice carefully, as it will help you
understand what we do with the information that we collect.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to
us
We collect personal information that you voluntarily provide to us when you
register on the App, express an interest in obtaining information about us or our products and Services,
when you participate in activities on the App or otherwise when you contact us.
The personal information that we collect depends on the context of your
interactions with us and the App, the choices you make and the products and features you use. The personal
information we collect may include the following:
Personal Information Provided by You. We collect names; phone
numbers; email addresses; mailing addresses; usernames; passwords; contact or authentication data; and other
similar information.
All personal information that you provide to us must be true, complete and
accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP)
address and/or browser and device characteristics — is collected automatically when you visit our
App.
We automatically collect certain information when you visit, use or
navigate the App. This information does not reveal your specific identity (like your name or contact
information) but may include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name, country, location,
information about how and when you use our App and other technical information. This information is
primarily needed to maintain the security and operation of our App, and for our internal analytics and
reporting purposes.
Like many businesses, we also collect information through cookies
and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our
servers automatically collect when you access or use our App and which we record in log files. Depending on
how you interact with us, this log data may include your IP address, device information, browser type and
settings and information about your activity in the App (such as the date/time stamps associated with your
usage, pages and files viewed, searches and other actions you take such as which features you use), device
event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware
settings).
- Location Data. We collect location data such as information about your device's location, which can be
either precise or imprecise. How much information we collect depends on the type and settings of the device
you use to access the App. For example, we may use GPS and other technologies to collect geolocation data
that tells us your current location (based on your IP address). You can opt out of allowing us to collect
this information either by refusing access to the information or by disabling your Location setting on your
device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information collected through our App
In Short: We collect information regarding your geolocation, mobile
device, push notifications, when you use our App.
If you use our App, we also collect the following information:
- Geolocation Information. We may request access or permission to and track location-based information from
your mobile device, either continuously or while you are using our App, to provide certain location-based
services. If you wish to change our access or permissions, you may do so in your device's settings.
- Mobile Device Access. We may request access or permission to certain features from your mobile device,
including your mobile device's camera, calendar, reminders, and other features. If you wish to change our
access or permissions, you may do so in your device's settings.
- Push Notifications. We may request to send you push notifications regarding your account or certain features
of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in
your device's settings.
This information is primarily needed to maintain the security and operation
of our App, for troubleshooting and for our internal analytics and reporting purposes.
Information collected from other sources
In Short: We may collect limited data from public databases,
marketing partners, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers and
services to you and update our records, we may obtain information about you from other sources, such as
public databases, joint marketing partners, affiliate programs, data providers, as well as from other third
parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent
data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and
custom profiles, for purposes of targeted advertising and event promotion.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on
legitimate business interests, the fulfillment of our contract with you, compliance with our legal
obligations, and/or your consent.
We use personal information collected via our App for a variety of business
purposes described below. We process your personal information for these purposes in reliance on our
legitimate business interests, in order to enter into or perform a contract with you, with your consent,
and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on
next to each purpose listed below.
We use the information we collect or receive:
- facilitate account creation and logon process. If you choose to link your account with us to a
third-party account (such as your Google or Facebook account), we use the information you allowed us to
collect from those third parties to facilitate account creation and logon process for the performance of
the contract.
- To post testimonials. We post testimonials on our App that may contain personal information.
Prior to posting a testimonial, we will obtain your consent to use your name and the content of the
testimonial. If you wish to update, or delete your testimonial, please contact us at admin@jomprep.com
and be sure to include your name, testimonial location, and contact information.
- Request feedback. We may use your information to request feedback and to contact you about your
use of our App.
- To enable user-to-user communications. We may use your information in order to enable
user-to-user communications with each user's consent.
- To manage user accounts. We may use your information for the purposes of managing our account and
keeping it in working order.
- To send administrative information to you. We may use your personal information to send you
product, service and new feature information and/or information about changes to our terms, conditions,
and policies.
- To protect our Services. We may use your information as part of our efforts to keep our App safe
and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies for business purposes, to comply with legal and
regulatory requirements or in connection with our contract.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request,
we may need to inspect the data we hold to determine how to respond.
- Fulfill and manage your orders. We may use your information to fulfill and manage your orders,
payments, returns, and exchanges made through the App.
- Administer prize draws and competitions. We may use your information to administer prize draws
and competitions when you elect to participate in our competitions.
- To deliver and facilitate delivery of services to the user. We may use your information to
provide you with the requested service.
- To respond to user inquiries/offer support to users. We may use your information to respond to
your inquiries and solve any potential issues you might have with the use of our Services.
- For other business purposes. We may use your information for other business purposes, such as
data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and
to evaluate and improve our App, products, marketing and your experience. We may use and store this
information in aggregated and anonymized form so that it is not associated with individual end users and
does not include personal information.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply
with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal
basis:
- Consent: We may process your data if you have given us specific consent to use your personal
information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our
legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your
personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in
order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal
process, such as in response to a court order or a subpoena (including in response to public authorities
to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to
investigate, prevent, or take action regarding potential violations of our policies, suspected fraud,
situations involving potential threats to the safety of any person and illegal activities, or as
evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal
information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of
our business to another company.
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with
third-party vendors, service providers, contractors or agents who perform services for us or on our
behalf and require access to such information to do that work. Examples include: payment processing,
data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow
selected third parties to use tracking technology on the App, which will enable them to collect data on
our behalf about how you interact with our App over time. This information may be used to, among other
things, analyze and track data, determine the popularity of certain content, pages or features, and
better understand online activity. Unless described in this notice, we do not share, sell, rent or trade
any of your information with third parties for their promotional purposes.
- Offer Wall. Our App may display a third-party hosted "offer wall." Such an offer wall allows
third-party advertisers to offer virtual currency, gifts, or other items to users in return for the
acceptance and completion of an advertisement offer. Such an offer wall may appear in our App and be
displayed to you based on certain data, such as your geographic area or demographic information. When
you click on an offer wall, you will be brought to an external website belonging to other persons and
will leave our App. A unique identifier, such as your user ID, will be shared with the offer wall
provider in order to prevent fraud and properly credit your account with the relevant reward. Please
note that we do not control third-party websites and have no responsibility in relation to the content
of such websites. The inclusion of a link towards a third-party website does not imply an endorsement by
us of such website. Accordingly, we do not make any warranty regarding such third-party websites and we
will not be liable for any loss or damage caused by the use of such websites. In addition, when you
access any third-party website, please understand that your rights while accessing and using those
websites will be governed by the privacy notice and terms of service relating to the use of those
websites.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
In Short: We only share information with the following third
parties.
We only share and disclose your information with the following third
parties. If we have processed your data based on your consent and you wish to revoke your consent, please
contact us using the contact details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?".
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to
collect and store your information.
may use cookies and similar tracking technologies (like web beacons and
pixels) to access or store information. Specific information about how we use such technologies and how you
can refuse certain cookies is set out in our Cookie Notice.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to
fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary
for the purposes set out in this privacy notice, unless a longer retention period is required or permitted
by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us
keeping your personal information for longer than thirty six (36) months past the termination of the user's
account.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a
system of organizational and technical security measures.
We have implemented appropriate technical and organizational security
measures designed to protect the security of any personal information we process. However, despite our
safeguards and efforts to secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and
improperly collect, access, steal, or modify your information. Although we will do our best to protect your
personal information, transmission of personal information to and from our App is at your own risk. You
should only access the App within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to
children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years
of age. By using the App, you represent that you are at least 18 or that you are the parent or guardian of
such a minor and consent to such minor dependent’s use of the App. If we learn that personal information
from users less than 18 years of age has been collected, we will deactivate the account and take reasonable
measures to promptly delete such data from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at admin@jomprep.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any
time.
If you are a resident in the EEA or UK and you believe we are unlawfully
processing your personal information, you also have the right to complain to your local data protection
supervisory authority. You can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data
protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you have questions or comments about your privacy rights, you may email
us at admin@jomprep.com.
Account Information
If you would at any time like to review or change the information in your
account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may retain some information in our files
to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or
comply with applicable legal requirements.
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your
browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this
could affect certain features or services of our App. To opt-out of interest-based advertising by
advertisers on our App visit http://www.aboutads.info/choices/.
Opting out of email marketing:
You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the
emails that we send or by contacting us using the details provided below. You will then be removed from the
marketing email list — however, we may still communicate with you, for example to send you service-related
emails that are necessary for the administration and use of your account, to respond to service requests, or
for other non-marketing purposes. To otherwise opt-out, you may:
- Access your account settings and update your preferences.
- Contact us using the contact information provided.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At this stage no uniform technology
standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently
respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be
tracked online. If a standard for online tracking is adopted that we must follow in the future, we will
inform you about that practice in a revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted
specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light"
law, permits our users who are California residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if any) we disclosed to third parties for
direct marketing purposes and the names and addresses of all third parties with which we shared personal
information in the immediately preceding calendar year. If you are a California resident and would like to
make such a request, please submit your request in writing to us using the contact information provided
below.
If you are under 18 years of age, reside in California, and have a
registered account with the App, you have the right to request removal of unwanted data that you publicly
post on the App. To request removal of such data, please contact us using the contact information provided
below, and include the email address associated with your account and a statement that you reside in
California. We will make sure the data is not publicly displayed on the App, but please be aware that the
data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay
compliant with relevant laws.
We may update this privacy notice from time to time. The updated version
will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy notice, we may notify you either by prominently
posting a notice of such changes or by directly sending you a notification. We encourage you to review this
privacy notice frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
admin@jomprep.com or by post to:
The University of Malaya
Level 17, Wisma R&D. Universiti Malaya, Jalan Pantai Baharu
Kuala Lumpur, KL 59990
Malaysia
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
Based on the applicable laws of your country, you may have the right to
request access to the personal information we collect from you, change that information, or delete it in
some circumstances. To request to review, update, or delete your personal information, please visit: http://www.JomPrEP.com.
