Personal Data Protection Act (2010) Notice - DriveMark

Updated on January 6, 2020. Version 2.0

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KATSANA HOLDINGS PERSONAL DATA PROTECTION NOTICE

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The Personal Data Protection Act 2010 requires an organisation that processes personal data in a commercial transaction to comply with data protection principles, including to inform data subjects such as yourselves on the manner in which we process your personal data.

KATSANA Holdings Sdn. Bhd. (Company No. 1087257-D) either through itself or through its subsidiaries and/or affiliated entities (“KATSANA Group”, “we”, “us” or “our”), highly value and respect your privacy.

Our mission to create safer roads require us to collect data necessary to improve road safety by scoring your driving behavior and providing you with an engaging social experience at the same time, in hope that you can become a better driver.

This Personal Data Protection Notice (“Notice”) will apply when you provide your personal data in connection with your use of services (“Services”) or redemption of rewards (“Rewards”) offered and/or provided by KATSANA Group via KATSANA’s mobile application (“DriveMark®”) and related applications. Please take a moment to familiarise yourself with the Notice before using our Services. If you have any questions, suggestions and concerns, feel free to email us [email protected].

By accessing or using our Services, you agree to us processing your personal data in the manner stated in this Notice and in accordance to our Terms of Service. If you do not agree to this Notice or our Terms of Service, please do not access or use our Services or provide any personal data to KATSANA Group.

1. Collection of Personal Data:
By using, accessing, registering and interacting with DriveMark®, you consent to KATSANA Group processing the personal data which:

1. You provide when you create a user account, and when you log-in to your account;
2. You provide when you fill up any forms or documents in connection to the use of the Services and/or redemption of the Rewards;
3. You provide when you interact and communicate with KATSANA Group in connection to the use of the Services and/or redemption of the Rewards, through various methods such as emails, social media and newsletters, letters, telephone calls, interviews, and conversations you have with KATSANA Group ;
4. You provide when you interact and communicate with KATSANA Group at/during/after any events or activities that you participated;
5. You provide when you enter contests or challenges organised by KATSANA Group;
6. KATSANA Group collects from your mobile phone via Drivemark®, DriveMark® SDKs, Android SDKs and iOS SDKs;
7. KATSANA Group obtains from any service provider engaged by KATSANA Group; and/or
8. KATSANA Group obtains from public domains and third parties, which include but is not limited to statutory bodies, government agencies or motor insurers.

2. Keeping your information private and secure is incredibly important to us. This section explains what we collect and why we collect your personal data.

	What we collect	Why we collect
2.a.	Your identity such as (but is not limited to) name, address, and date of birth, National Registration Identity Card / passport details, gender, photograph and demographic information	We need this information in order to create your user account, and as part of our identity verification process. We will also create a profile of your identity to improve driver scoring algorithm, to offer you with Services and facilitate your redemption of Rewards from us.
2.b.	Your emergency contact information	In the event of a mishap or emergency, we need this information in order to notify your family and/or friends, to alert them about your safety.We will also contact them to redeem your Rewards on your behalf, in the event we could not contact you.
2.c.	Your email address, phone number and other contact information	This information is required as part of the user account creation process. We will also contact you on any new Service updates, news, or alerting you on policy, service, claim, Reward, award or other matter pertaining to your user account. We may share your contact information to our services providers and insurance partners who need to coordinate related Services with you such as (and not limited to) renewal of motor insurance, renewal of road tax and DriveMark® Personal Accident coverage.
2.d.	Your vehicle and insurance information such as plate number and photographs of the vehicle	We use this information to rank your driving score against other users in DriveMark®. We also use this data to improve DriveMark® scoring algorithm, and to offer you appropriate insurance package based on your driving score and other criteria.
2.e.	Your membership information	We use this information to enable disbursement of Rewards by participating partners. This information is also used to create new Reward programs based on targeted audience and to analyze your usage of the Reward programs.
2.f.	Your payment information	We need this information to complete the transaction between you and KATSANA Group. Note that third-party payment processor(s) will be used, and we will have limited information on your payment transactions. We also do not store this information.
2.g.	Your Facebook or other social account information	This may be your preferred method for account creation. You may use social media to ease the creation of a DriveMark® community, invite new friends to join the community or retrieve information from the social account into DriveMark®.
2.h.	Your contact/address book	For you to use your contact list to create a DriveMark® community and/or invite others to DriveMark®.
2.i.	Your device information such as IP address, app crashes and other system activities	We collect data from your smartphone. We aggregate and anonymize this data to look for statistical patterns that can help us to give you, and all our users, more precise rates, coverage and improved services, as well as to improve performance and experience of our Services.
2.j.	Telematics data such as location and speed data and travel history	We collect this data at all times in effort to precisely measure your driving behavior and to provide scores and/or points. Aggregated and anonymised version data is also analysed to improve road safety and may be shared for education and regulatory purposes. Where this is the case, you will not be identifiable. You are given full autonomy to enable or disable automated location tracking via an option within the app. We may share summary of your driving data to our partners in effort to reward and encourage drivers to drive safe.

3. In addition to item 2 above, where applicable, KATSANA Group will process your personal data for the following purposes:

1. To facilitate your use of and access to the Services;
2. To monitor and analyse your usage of the Services and other trends;
3. To personalise and improve the Service and your experience with the Services (such as to provide content or features to further match user interest);
4. To request feedback and to otherwise contact you about your use of the Services;
5. To respond to your emails, questions, comments, requests and complaints, and to provide customer service;
6. For research, statistical studies and/or data analysis;
7. To provide to you marketing information and offers relating to our Services;
8. To pool risks profiles for potential insurers for the purpose of offering and/or providing and/or recommending to you any insurance products;
9. To provide to you marketing information and offers based on your profile by our partners and affiliates on any products we deem suitable to you;
10. To facilitate KATSANA Group’s internal administration such as auditing, data analysis and maintaining database records;
11. To facilitate KATSANA Group’s business continuity management and procedures; and/or
12. For all other purposes that is incidental, ancillary and/or in furtherance to the above.

4. The information requested is necessary to us. If you do not provide us with all the information as requested and/or do not allow us to process the information accordingly, we will not be able to keep your complete record of information, thus affecting our ability to accomplish the above stated purposes.

5. Social Sharing Services
Social sharing services may be offered or provided in DriveMark® for your convenience. Your use of the social sharing services may be subject to the privacy policies of the respective social media applications and/or websites. KATSANA Group does not control, recommend or endorse these applications and/or websites and will not be held responsible for these applications and/or websites or their contents. As such, KATSANA Group encourages you to read the privacy policies and terms of usage of these applications and/or websites prior to assessing these applications and/or websites. This Notice applies solely to personal data and information collected by KATSANA Group.

6. Sensitive Personal Data
By signifying your consent to KATSANA Group, you give KATSANA Group your explicit consent to process your sensitive personal data such as your driving record, vehicle ownership record, summonses, participation in other reward programs and past insurance records for the purposes described above or as required by law.

We may also obtain your sensitive personal data from other parties when it is allowed by law.

7. Disclosure of Information
KATSANA Group does not disclose your personal data to unaffiliated third parties without your consent. However, KATSANA Group may disclose your personal data (within and outside Malaysia) in good faith,

1. To comply with requirements of the government, law enforcement agencies, any authorities to whom KATSANA Group is subject to or any orders of the court;
2. As is necessary or relevant in relation to any legal process;
3. If required or authorised by law; and/or
4. As is reasonable necessary or appropriate to protect the rights, property, or safety of KATSANA Group’s related and associated companies and affiliates (whether locally or globally), our users, our employees, copyright owners, third-parties or the public.

8. DriveMark® may, if necessary, disclose your personal data to the following parties (including those within and outside of Malaysia):

1. Agents, vendors, consultants, and other service providers (including but not limited to professional, financial and/or payment service providers) that provide services including data processing services relating to the purposes above;
2. Insurance providers of which you may have or may not have active policy(ies);
3. Marketing research companies and advertisers (if any);
4. Your agents and advisors (including but not limited to professional advisors) and any other person notified and authorised by you;
5. Government agencies/statutory bodies/authorities;
6. Our assignees or potential assignees and successors-in-title;
7. Any person, who is under a duty of confidentiality and who has undertaken the responsibility to keep such data confidential;
8. The general public, through user generated content on the DriveMark® platform;
9. Any person during or in connection with any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company (if any); and/or
10. KATSANA Group’s related and associated companies and affiliated entities (whether locally or globally)

9. Access, corrections, delete and complaints
We welcome any request to access, correct, or delete your personal data which KATSANA Group process, subject to prevailing data protection laws in Malaysia. To do so, you may contact KATSANA Group’s Head of Customer Experience at +603 7733 4474 or at [email protected].

Any request to access and/or correct personal data is subject to a fee which may be waived depending on the extent of the correction or request.

10. Requesting data deletion
You may request for deletion of your user data by contacting KATSANA Group’s Head of Customer Experience at +603 7733 4474 or at [email protected].

Please take note that this action is not recoverable. Any data that is deleted from this exercise will forever be deleted from our systems.

Data that will be deleted is identifiable data that can be used to identify you as an individual, which may include:

Account data (user authentication, verification & login)
User data (name, address, contact information & user submitted forms)
Identifiable vehicle data (vehicle registration, engine number, chassis number)
Social data (Facebook ID, Twitter ID, etc)
App diagnostic data stored on server

Once requested, please allow 3-5 business days for the request to be queued and processed for deletion. Upon successful deletion, you will receive a confirmation from KATSANA Group.

Any request for the deletion of your personal data is free.

11. Variation to this Notice
KATSANA Group may review and update this Notice from time to time to reflect changes in the law, changes in KATSANA Group’s business practices, procedures and structure, and the community’s changing privacy expectations.

11. We will take all reasonable steps to notify you of any variation to this Notice. You may also obtain a copy of the Notice at [link to the Notice] to ensure that you are aware of the most recent version which will apply.

In the event of any inconsistency between the English version and the Bahasa Malaysia version of this notice, the English version shall prevail.

Contact

KATSANA Holdings Sdn Bhd
Lot 2805, Jalan Damansara,
60000 Petaling Jaya,
Selangor, Malaysia.
[email protected]