AFLEXI PRIVACY POLICY

Aflexi Sdn Bhd, (“Aflexi”, "us" or "we") respects the privacy of the visitors to our website (the home page (“Site”)) and of our customers and partners. This privacy policy ("Privacy Policy") is to inform you, our visitor, customer, partner and/or user (“User”), of our policies and practices regarding the collection, use and disclosure of any Personal Information (defined below) you submit to us through the Site or through the Aflexi content delivery network platform and application and associated services (including Aflexi’s Marketplace service) (“Aflexi Services”).

"Personal Information" is information about you that is personally identifiable to you such as your name, address, e-mail address, phone number, user name, and any other information that could allow someone to identify you or contact you. Personally identifiable information also includes information about your transactions or relationship with us if you have been a customer or you have provided this type of information to us. If you are a customer, in addition to your name and contact information, Personal Information may also include your billing address, shipping address, account and credit card information.

"Anonymous Information" means information about you that is not associated with or linked to your Personal Information; Anonymous Information does not permit the identification of individual persons.

We collect and use Personal Information and Anonymous Information as described in this Privacy Policy.

User Consent

By submitting Personal Information through the Site or through the Aflexi Services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Information according to this Privacy Policy. Because of its importance and to make it easier for you to find and review it, we have made this Privacy Statement into a separate document on the Site. However, bear in mind it is a part of our agreement with you, and it describes how and when we may make changes to these statements and terms, and how they become binding upon you. We reserve the right to modify this Privacy Policy at any time and without notice. Any changes to the Privacy Policy will be posted on this page. We encourage you to check the page regularly as you will be bound by the changes once posted.

Our Commitment

We are committed to protecting your privacy. Keeping the information you share with us secure and ensuring your understanding of how we collect, use and maintain your information is important to us. We maintain physical, electronic and procedural safeguards to protect your information, and while no data transmission over the Internet is 100% secure from intrusion, we have used and will continue to use commercially reasonable efforts to ensure the protection of your information. It is always possible that third parties may unlawfully intercept or access your transmissions or private communications. Although we allow you to set privacy options that limit access to your account, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you may choose to share your information. We are not responsible for circumvention of any privacy settings or security measures. We continually assess new technology for protecting information and, when appropriate, we upgrade our information security systems.

Personal Information You Provide to Us

When you become our customer, you provide us with Personal Information, such as your name, your email address, your telephone number, and any other personal or preference information that you provide to us. When you register with us, you may set up your personal profile and account and transmit information through various channels. In addition, during the registration process we will also ask you to select (or we may provide) a user ID and password (we will allow you to change your password, as well as any personally identifiable information you have given us in order to keep this information current). Among other things, this information helps us securely identify you as a customer. We collect this information so that we can provide you with our products and services.

The Personal Information we gather from you helps us learn about our members and potential members of our community and the users of the Site and Aflexi Services. The types of Personal Information we collect are:

• When you visit the Site and input information, whether you are registering to be a customer, or in the course of any other exchanges of information, transactions and activities, we will collect all such information.
• When you personalize your profile, we will collect any information you provide, such as your name or address.
• When you enter any information, including Personal Information, into any postings or comments within the Site or through the Aflexi Services, we will collect such information and this information might be available for some, a subgroup of, or even all Site users, depending on how and where this information was posted by you (see Use of Information below).
• When you contact us by sending us an e-mail, we will collect your e-mail address and any information contained in the email you send us.
• When you download an Aflexi application, we will collect information about your geographical location. We may connect such geographical information with Personal Information we have collected from you.
• The profile and account that you create when registering with the Site contains Personal Information such as your username, e-mail address and password. None of that information will be visible to other registered users.
• You can access and modify your profile and account at any time.

Personal Information Collected Via Technology

As you navigate our Site or access the Aflexi Services, certain information may also be collected passively, including your Internet protocol address, browser type, and operating system. When you enter the Site or access the Aflexi Services, we collect your browser type and IP address. In addition, we store certain information from your browser using "cookies." A cookie is a piece of data stored on the user's computer tied to information about the user. We use session ID cookies to confirm that users are logged in. These cookies terminate once the user closes the browser. By default, we use a persistent cookie that stores your login ID (but not your password) to make it easier for you to login when you come back to the Site. You can remove or block this cookie using the settings in your browser if you want to disable this convenience feature. If you choose to disable cookies, some areas of the Site may not work properly.

We also use cookies and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the information for which you searched and viewed. This type of information is collected to better understand how you use the Aflexi Services and make the Aflexi Services and the Site more useful.

We may use automatically collected information and cookies to:

1. automatically update the Aflexi application on your system;
2. monitor aggregate site usage metrics such as total number of visitors and pages accessed; and
3. track your entries, submissions, and status in any promotions or other activities.

Although we may track the numbers of visitors to inform us on how best to update the Site and enhance the experience for all visitors, personally identifiable information is not extracted in this process. We use tracking information on an aggregated basis to help us operate the site, enhance and improve and update our service, improve the look of the site and display advertising and marketing information.

An "Internet protocol address" or "IP Address" is a number that is automatically assigned to your computer when you use the Internet. In some cases your IP Address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP Address probably varies from session to session. We track IP Addresses solely in conjunction with session cookies to analyze our web page flow.

We may also contract with third parties in order to promote the products and/or services of these third parties by placing ads on the Site. We may use information posted by registered users to tailor the display of ads to the interest of users. Clicking on such ads will direct you to the website of the third party and the third party may also use cookies in connection with these ads. Please be advised that we are not responsible for these other websites or any content on these other websites and that this Privacy Policy does not govern your visit of these other websites.

Personal Information We Receive From Other Sources

We may receive Personal Information about you from other sources like telephone or fax, or from third parties that provide services for us in connection with the Site. We may add this information to the information we have already collected from you via our Site or through the Aflexi Services in order to improve the Site and the Aflexi Services.

Use of Information

In general, Personal Information you submit to us is used by us either to sign you up for Aflexi Services, notify you of events, respond to requests that you make, improve to the Aflexi Services and Site and to better tailor the features, performance and support of the Aflexi Services and Site, offer you additional information, opportunities, and functionality, and invoice you. We may also use your Personal Information to provide you with electronic newsletters or promotional e-mails, should you request to receive such communications from us. We do not sell or market your Personal Information to unaffiliated organizations.

We may use Personal Information and Anonymous Information to track User–generated content and Users to the extent necessary to comply as a service provider with the Digital Millennium Copyright Act.

We may create Anonymous Information records from Personal Information by excluding information (such as your name) that make the information personally identifiable to you. We may use this Anonymous Information to analyze usage patterns so that we may enhance the Aflexi Services and Site. We may share aggregate statistical information gathered from you and other Users with advertisers, business partners, sponsor or other third parties. For example, we may tell an advertiser that X number of visitors visited a certain area on a web site or that Y number of men and Z number of women filled out registration forms. We share such information only on an aggregate and anonymous basis.

We will exchange information about you to PayPal to carry out PayPal transactions necessary for your event registration fees, to prevent fraud and any other activities we may be required to monitor and report under applicable laws and regulations. In such instances, we will make every effort to keep your personally identifiable information complete, up to date, and accurate based on the information you provide us.

We may provide your information to service providers to help us bring you the services we offer. Specifically, we may use third parties to facilitate our business, such as to host and co-locate the Aflexi Services, to invoice you, send out email updates about the Aflexi services, to remove repetitive information from our user lists, to process payments for products or services, to offer an online job application process, or to provide search results or links (including sponsored links). In connection with these offerings and business operations, our service providers may have access to your Personal Information for use for a limited time in connection with these business activities. Where we utilize third parties for the processing of any Personal Information, we implement reasonable contractual and technical protections limiting the use of that information to the Aflexi Service-specified or Site-specified purposes.

We may also use your Personal Information to communicate with you as and when we, at our sole discretion, feel that communications are necessary.
International Users

Please note that your Personal Information may be processed by us in the country where it was collected as well as other countries (including the United States) where laws regarding processing of Personal Information may be less stringent than the laws in your country. For Users using Services or accessing the Site from the European Economic Area or other non–U.S. territories, please note that any data you enter through the Aflexi Services will be transferred outside the European Economic Area or such other non–U.S. territory for use by Aflexi for any of the purposes described herein. In addition, because Aflexi operates globally, we may make information we gather available to worldwide business units and affiliates. By providing any data through the Aflexi Services, you hereby expressly consent to such transfers of your data to the United States or other countries.

Feedback

If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we will not associate such feedback with your Personal Information. We will collect any information contained in such communication and will treat the Personal Information in such communication in accordance with this Privacy Policy.

Disclosure of Personal Information

Except as otherwise stated in this Privacy Policy, we do not trade, rent, or share your Personal Information with third parties unless you ask or authorize us to do so. We may provide your Personal Information to third party service providers who work on behalf of or with us to provide some of the services and features of the Aflexi Services and the Site. However, these service providers do not have any independent right to share this information (expect pursuant to a legal requirement such as a subpoena or warrant). We may share Personal Information:

• When we have retained companies to work with or on behalf of us to provide goods or services that you have requested.
• When we are compelled to do so by a governmental agency, court or other entity (e.g., to respond to subpoenas, court orders or legal process).
• If we believe your actions violate any law, regulation, the Aflexi General Terms and Conditions or the Aflexi Acceptable Use Policy [link] or any of our guidelines or policies, or if you threaten the rights, property or safety of Aflexi, our suppliers, licensors, advertisers, other customers or users, or any other party.

Although we currently do not have a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, "Affiliates"), we may in the future. We may share some or all of your Personal Information with these Affiliates, in which case we will require our Affiliates to honor this Privacy Policy. If our company or our assets are acquired by another company or by a trustee in bankruptcy, that company or trustee will possess the Personal Information collected by us, and it will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on us; or (b) to protect and defend the rights or property of us, Site users, or third parties.

Your Choices Regarding Your Personal Information

We offer you choices regarding the collection, use and sharing of your Personal Information. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail your receive or by contacting us directly (please see contact information below). If you wish to remove your Personal Information, please contact us and your Personal Information will be removed from the database.

Despite your indicated e-mail preferences, we may send you administrative e-mails regarding the Site or notices of any updates to our Terms and Conditions or Privacy Policy.

Regarding Children

We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If you are under 13, please do not attempt to register on the Site or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to or on the Site. If we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.

We recommend that minors over the age of 13 ask their parents for permission before sending any information about themselves to anyone over the Internet.

Other Sites

We may use third parties to display or serve advertising on the Site and through the Aflexi Service. Our provision of such advertising, as well as links to other websites or locations is for your convenience and does not signify our endorsement of such other websites or location or its contents. Links to other websites or locations may also be posted by other Site users. We have no control over, do not review, and cannot be responsible for these outside websites or their content. Often these third party advertising companies employ cookie and web bug technologies to measure advertising effectiveness. You should be aware that different rules may apply to the collection, use or disclosure of your information by third parties in connection with their advertisements, promotions and other web sites you encounter on the Internet. The use of such technology by these third parties is within their control and not ours, and even if we have a relationship with the third party, we do not control those sites or their policies and practices regarding your information and we encourage you to investigate and ask questions directly of them in this regard. Please be aware that the terms of our Privacy Policy do not apply to these outside websites.

Security and Notice

We use reasonable measures to maintain the security of your Personal Information. However, no company, including us, can fully eliminate security risks associated with Personal Information. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Aflexi Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Contact Us

Should you have any questions or concerns regarding this Privacy Policy, please contact us. You may at any time request access to a summary of your Personal Information held by us, and request corrections or updates to that information. We will make reasonable efforts to respond promptly to such requests for information in accordance with local laws. Our response to such requests may be limited to information under our control. You may request to receive and review any of that information, or request corrections to it, by contacting:

Aflexi

1, Jalan Emas 6

Taman Megah Mas, 47301

Petaling Jaya, Selangor, Malaysia

Privacy Policy Updates

This Privacy Policy is subject to occasional revision, and changes will be posted on this page.

This Policy was last updated in March 2009.