PRIVACY NOTICE

We are pleased to welcome you to our Platforms and thank you for your interest in our company.


This Privacy Notice describes, among other things, how PTTI Group Sdn. Bhd. (“PTTI”) processes your personal data and your rights as a data subject in accordance with the laws of Malaysia. This Privacy Notice governs the manner in which the PTTI collects, uses, maintains and discloses information collected from each users.


I. PRIVACY NOTICE


PTTI values your privacy. In accordance with the passing of the Personal Data Protection Act 2010 and all Regulations made hereunder, PTTI has included this Privacy Notice which is integral and part of the terms of its contract with all of its visitors (where applicable) and users as well as its relationship with its partners, associates and affiliate.


This Privacy Notice (the “Notice”) outlines the collection, use, and disclosure of personal information that may be collected by PTTI when you use this website located at www.ptti.com.my (or any other website address at use at the moment) and mobile applications of PTTI (collectively referred to as the ‘’Website’’).


PTTI has created this Privacy Notice to explain why we collect particular information and how we will protect your personal privacy. It describes the information that we gather from you, how we use and disclose your information, and the steps we take to protect your information. This notice applies to all information received by the Website, both online and offline, on any platforms (including Website, Instagram, social media, apps, electronic, written or oral communications, collectively “Platforms”). By using the Platform, you consent to the privacy practices described in this Privacy Notice.


PTTI reserves the right to modify this Privacy Notice at any time without prior notice. By continuing to access the Platforms after such modifications have been published you signify your agreement to such modified Notice. The Platforms may collect and use users personal identification information for the following purposes:


4.1. To improve customer service

4.2. To personalize user experience


To send periodic emails


Conducting marketing surveys and client profiling


Detecting and preventing crime


Maintaining and updating internal record keeping


Promotional and marketing


Applicable Law of Privacy Notice


By accessing the Platforms, you are bound under the laws of Malaysia, including the privacy and data laws of Malaysia. If you do not agree to this, kindly do not access the Platforms.

Disclosure

The data provided to us will be kept confidential but you hereby consent and authorize us to provide and disclose your data to the following categories:-


6.1 any person to whom we are compelled or required to do so under law;


6.2 any entity within our group;


6.3 payment channels including but not limited to financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to PTTI in connection with your purchase of our services;


6.4 our business partners and affiliates that provide related services or product in connection with our business, for promotional and marketing purposes;


6.5 statutory authorities, government agencies and industry regulators;


6.6 our consultants, accountants, auditors, lawyers or other financial or professional advisers;


6.7 our sub-contractors or third-party service or product providers;


6.8 our service providers for purposes of establishing and maintaining a common database where we have a legitimate common interest.


7. SAFEGUARDS

We shall keep and process your data in a secure manner. We endeavour where practicable, to implement the appropriate administrative and security safeguards and procedures in accordance with the applicable laws and regulations to prevent the unauthorized or unlawful processing of the data and the accidental loss or destruction of, or damage to, the data.

II. GENERAL DATA PROCESSING INFORMATION


1. Extent to which personal data is processed

Every time our Platforms is accessed, our system automatically acquires data and information from the computer system. We only ever collect and use personal data of our users to the extent to which this is necessary to provide a fully functional Platforms and our contents and services.


2. Requirement to provide personal data

The data subject's provision of personal data is often necessary for us to fulfil our contractual obligations. Failure to provide such data may cause us not to be able to fulfil our contractual obligations.


III. PROVISION OF THE WEBSITE AND CREATION OF LOG FILES


Description and the extent of data processing

Every time our website is accessed, our system automatically acquires data and information from the computer system of the calling computer.

The following data is collected:

(1) The user's IP address

(2) Date and time of access

(3) Website visited

(4) Quantity of data sent in bytes

(5) Source/link from which you accessed the website

(6) Browser used

(7) Operating system used

The data is also stored in the log files of our system. This data is not stored with other personal data of the user.


Purpose of data processing

The temporary storage of the IP address by the system is necessary in order to be able to deliver the website to the user's computer. To this end, the user’s IP address must be stored for the duration of the session. The data that has been acquired is used for statistical analyses and to improve the website. Your personal data (IP address) is first anonymised.

Data is stored in log files to ensure that the website functions properly. In addition, the data serves to optimise the website and to guarantee the security of our IT systems. No data evaluation is carried out for marketing purposes in this context.


These purposes are also in our legitimate interests in data processing pursuant to applicable data protection legislation.


3. Right to object and right of elimination

Data acquisition is essential for the provision of the website and the storage of data in log files is essential for operating the website. The user therefore has no right to object.


IV. USE OF COOKIES


1. Description and extent of data processing

Our website makes use of cookies. Cookies are text files stored on the user's computer system in or by the Internet browser. If a user accesses a website, a cookie can be stored on the user's operating system. This cookie contains a characteristic character string that enables the browser to be clearly identified the next time the website is

accessed.

We use cookies to make our website more user-friendly. Some elements of our website require the accessing browser to be identified if the user changes from one page to another.

The following data is stored and transmitted in the cookies:

The user's IP address

Date and time of access

Login information

Amount of data transferred

Enquiring domain


On our website, we also use cookies which make it possible to analyse the user's surfing habits.

The following data can be transmitted in this way:

(1) Equipment type, model, brand, screen resolution
(2) Operating system, versions, families
(3) Browser, version, configuration, engines, plugins, language,

language code
(4) Location data
(5) Provider details
(6) Pages per visit, number of visits, repeat visits, time of visit, date of

visit
(7) Entry pages, exit pages, page URL, title of page, search items,

downloads
(8) Search machines, search item, websites, social networks
(9) Campaigns, campaign key word


When accessing our website, the user is informed that cookies are used for analysis purposes, and requested to provide his or her consent to the processing of the personal data used in this respect. Information regarding this data privacy statement is also issued in this context.


2. Purpose of data processing

The purpose of using technically necessary cookies is to simplify the use of the website for the user. Some of our website functions cannot be offered without the use of cookies. For these, it is necessary for the browser to be recognised after changing from one page to another.


We need cookies for the following applications:

Login information.


The user data collected by technically necessary cookies are not used to create user profiles.


The analysis cookies are used for the purpose of improving the quality of our website and its contents. Through the analysis cookies, we find out how the website is used, which enables us to constantly improve our services. This enables us to provide optimum user guidance and to present as varied a website as possible, along with new contents, when you when you re-visit the site.


These purposes are also in our legitimate interests in the processing of personal data.


V. RIGHTS OF DATA SUBJECT

If personal data concerning you is processed, you are the data subject, and the analogous provisions pursuant to applicable data protection legislation and have the following rights against the data controller:


1. Right to rectification

You have a right to have the controller correct or complete any personal data concerning you which, having been processed, is either incorrect or incomplete. The data controller must carry out any corrections without undue delay.


2. Right to deletion


Obligation to delete

You can ask the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete this data without delay if one of the following reasons applies:


The personal data concerning you is no longer needed for

the purposes for which it was collected or otherwise processed.

You revoke your consent, which served as the basis for

processing and there is no other legal basis for the processing.

You file an objection to processing, and there are no

overriding legitimate reasons for the processing, or you file an objection to processing and the analogous provisions pursuant to applicable data protection legislation.

The personal data concerning you has been unlawfully

processed.

Deletion of the personal data concerning you is necessary

in order to ensure compliance with a legal obligation

under Malaysian law.

The personal data concerning you has been acquired in

relation to the offer of information society services and the analogous provisions pursuant to applicable data protection legislation.


3. Right to information

If you have exercised your right to have the controller correct or delete the processing of your data, then the controller may inform all recipients to whom the personal data concerning you has been disclosed of such correction or deletion of the data, unless it proves impossible to do so or would involve unreasonable expense and effort.


4. Right to withdraw declaration of consent

You have the right to withdraw your declaration of consent to the processing of personal data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on your consent before its withdrawal.


VI. THIRD PARTY WEBSITE


Users may find advertising or other content in our Platforms that link to the websites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these websites and are not responsible for the practices employed by websites linked to or from PTTI. In addition, these websites or services, including their content and links, may be constantly changing. These websites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Users, is the User to that website's own terms and policies.


We have no access to or control over these cookies that are used by third-party advertisers. You should consult the respective privacy policies of these third-party ad servers for more detailed information on their practices as well as for instructions about how to opt-out of certain practices. Our privacy notice does not apply to, and we cannot control the activities of, such other advertisers or web sites.


VII. CHANGES TO THIS NOTICE


We have the discretion to update this Privacy Notice at any time. We encourage Users to frequently check this page for any changes. You acknowledge and agree that it is your responsibility to review this Privacy Notice periodically and become aware of modifications.


VIII. TRANSFER OF PERSONAL DATA TO OUTSIDE OF MALAYSIA

We may transfer your data to outside of Malaysia and you hereby give us your consent to such a transfer.


IX. DISPUTE RESOLUTION


It is hereby agree that any dispute arising out of or in connection with this Privacy Notice (“Dispute”), shall be resolved in the by the Courts of Malaysia and shall be construed in accordance with the laws of Malaysia.



X. YOUR ACCEPTANCE OF THESE TERMS


By enrolling in the courses or programme offered by the Platforms, you signify your acceptance of this Privacy Notice. If you do not agree to this Privacy Notice, please do not enroll in the courses or programme offered by the Platforms. Your continued enrollment in the courses and

programme following the posting of changes to this Privacy Notice will be deemed your acceptance of those changes.



Version: April 2021