PRIVACY POLICY

Update Version: February 4, 2025

This Privacy Policy is designed to explain and elaborate upon some of our policies and principles pertaining to the privacy of your personal information, all of which we have adopted as a sign of our commitment to respecting, maintaining, protecting and safeguarding the privacy of your personal information.

Trambellir will only collect, record, hold, use, disclose and store (i.e., "process") your personal information in accordance with such laws (including the Personal Data Protection Act 2010 and other applicable data protection or privacy laws/regulations). By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

This Privacy Policy explains:

1. the type of personal information we collect and how we collect it;
2. how we use your personal information;
3. the parties that we disclose the personal information to; and
4. the choices we offer, including how to access and update your personal information.

1. If you are below the age of eighteen (18), you are responsible to obtain consent from your parent, guardian or person who has parental responsibility, prior to disclosing your personal details to Trambellir. Trambellir shall not be liable for any loss or inconvenience to you for failing to obtain consent.
2. In order to enable us to perform our services, offer our products to you, deal with your inquiries, facilitate membership onboarding for you and/or to fulfil partly or all of the services requested by you, we may need to and/or be required to process personal information and data about you, including but not limited to:
   1. personal information typically collected on application forms, which include but not limited to, your name, address details, date of birth, telephone number, mobile phone number or email addresses;
   2. personal information that pertains to you obtained indirectly through other sources (if any), in respect of which you have given your consent to them disclosing information relating to you and/or where they are not otherwise restricted;
   3. personal information that you provide when you apply for any of our products and services, including your views or opinions made known to us via feedback or surveys;
   4. information which we may collect from written communication when you provide us complaints or issue of inconveniences while using our service and we may use it for the purposes of communicating with you and to efficiently manage your requests and to resolve any other issues you may face;
   5. information regarding customer activities on our websites and from our other products and services, which are aggregated and used to help us provide more useful information to our customers and to understand which parts of our websites, products and services are of most interest; and/or
   6. other electronic data or information relating to you such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of our products and services or as part of their supply or delivery to you.
3. We may obtain this information from yourself and from a variety of sources, including but not limited to:
   1. through your relationship with us, for example information provided by you in application forms online through our website, when taking part in customer surveys, promotions, when providing feedback or making complaints;
   2. through your verbal and written communications with us and/or our authorised agents via phone or mobile device, email, fax, mail, websites or browsers, social media and/or any other appropriate communication channels;
   3. from an analysis of the way you use and manage your membership account(s) with us, from the transactions you make from your account(s) and use of our products and services;
   4. information received from refund, settlement or reconciliation claims or other documents; and/or
   5. from any information that is supplied and/or collected when you visit our websites and/or download our mobile device applications which may include your device's IP address or from data that is collected via cookies.

1. We use cookies (or equivalent technologies) for a number of purposes, including to store your preference for certain types of information or products, further analysis for the purpose of providing products and services to you, to improve our products and/or to personalise our products and services to you. Cookies are small text files that collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another web site) and how they navigate within the web site or mobile application.
2. Trambellir may use third parties to track its advertising across the web. The information Trambellir or these third parties collect does not include any personal information but is merely for the purpose of identifying the general effectiveness of such online advertising.
3. You may adjust settings on your browser and/or mobile device so that you will be notified when you receive a cookie or other similar tracking tools. Please refer to your browser documentation to check if the tracking tools have been enabled on your computer and/or mobile device or to request not to receive cookies or to disable cookies if you do not wish to have information collected via the use of cookies. However, do note that if you enable blocking or disabling of cookies, it may limit certain features and functions in your use of our web or mobile sites and that some personalised products and services on our websites may not be available if you choose to disable cookies.

1. Other than as stated above, we may use your personal information for one or more of the following purposes:
   1. from any information that is supplied and/or collected when you visit our websites and/or download our mobile device applications which may include your device's IP address or from data that is collected via cookies.
   2. to provide you with a better personalized experience on our websites;
   3. to process refunds;
   4. to manage and maintain your membership account(s) with us;
   5. to better manage our business and your relationship with us;
   6. to understand your current and future products, services and advertising needs;
   7. to market and to provide you with information on Trambellir and selected third parties products, services and/or offers which may be of interest to you (in respect of which we may or may not be remunerated) including but not limited to payment and related services and products, and services and products offered by our co-branding partners (the names of such partners will be provided on the website for relevant services and products, as the case may be) and in this respect, to contact you via short message service (“SMS”), phone or mobile device, email, fax, mail, websites or browsers, social media or messaging, in person and/or any other appropriate communication channels;
   8. to improve our products and services and to test, research, analyse and develop new features of products and services;
   9. to notify you about benefits and changes to the features of products and services;
   10. to administer offers and promotions;
   11. to provide customer service, assess your interest in Trambellir’s products and services, market research purposes and to conduct customer research or satisfaction surveys;
   12. to provide you with products and services administered by our agents, affiliates, service providers, contractors (including sub-contractors), merchant and business partners as part of the products and services and benefits granted by us;
   13. to respond to your enquiries and complaints and to generally resolve disputes;
   14. to protect our rights or property of Trambellir, or the rights of others including our business partners, suppliers, clients, or others when we have reasonable grounds to believe that such rights or property have been or could be affected, or to comply with a judicial proceeding, court order, or legal process;
   15. to update, consolidate and improve the accuracy of our records;
   16. to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
   17. to conduct research for analytical purposes including but not limited to information processing, management and enhancement of data, data mining and analysis of your transactions with us;
   18. to meet the disclosure requirements of any law binding on Trambellir;
   19. to create and maintain risk related models relating to audit, compliance and risk management purposes or functions;
   20. to transfer or assign our rights, interests and obligations under any of your agreements with us;
   21. to protect or enforce our rights to recover any debt owing to us;
   22. to conduct anti-money laundering checks;
   23. for crime detection, investigation, prevention and prosecution;
   24. to comply with any sanction or law enforcement requirements;
   25. to enforce and/or defend any of our rights; and/or
   26. for any other purpose that is required or permitted by any law, regulations, guidelines and/or the order of any court and/or relevant regulatory authorities.
2. Please be assured that we will ask for your consent before using your personal information for a purpose other than those that are set out in this Privacy Policy and in the privacy terms in your agreement(s) with Trambellir.

1. companies and/or persons that act as our agents, affiliates, service providers, contractors, merchants, business partners, lawyers, and/or professional advisers (including the employees, directors, sub-contractors, service providers, agents and professional advisors of all the aforesaid companies and/or persons);
2. companies, banks, financial institutions and/or organisations that assist us in processing and/or otherwise fulfilling transactions that you have requested;
3. companies and/or organisations that assist us in providing value added products and services;
4. companies and/or organisations that provide products and services to us in delivering or communicating information about our products and services to you;
5. any other person under a duty of confidentiality to us which has undertaken to keep such information confidential;
6. your advisers (including but not limited to accountants, auditors, lawyers, financial advisers or other professional advisers) where authorised by you;
7. any other person notified by you as authorised to give instructions or to use the account(s) or products or services on your behalf;
8. any party we may deem necessary to facilitate any investigation related to fraud and/or illegal activities;

1. The information you provide to Trambellir, as well as information we collected about you indirectly, may be used by Trambellir for marketing purposes. Trambellir may extract, disclose and release the information in the possession of Trambellir relating to you as mentioned in this Privacy Notice.
2. Additionally, the individual entities within Trambellir, may contact you about products, services and offers, which we believe may be of interest to you or benefit you.
3. Further, please also be informed that we will only disclose your personal information to third parties such as our affiliates and strategic partners for marketing and promotional purposes where your express prior consent has been obtained and subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to Trambellir.
4. You may inform us at any time if you do not wish to receive direct marketing communications from us by notifying us. Your latest written instructions to us will prevail.
5. We will treat your personal information as private and confidential and will not disclose your information to anyone outside of Trambellir except:
   1. where you have given your express consent as set out in our application form (s) and/ or pursuant to your consent and authorisation as contained in this Privacy Notice and/or in the terms and conditions governing the products and services which you have with us and/or under any of your agreements with us and/or our affiliates;
   2. where we are required or permitted to do so by law;
   3. where required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over Trambellir;
   4. where we may transfer rights and obligations pursuant to our agreement(s) with you; and/or
   5. where we are required to meet our obligations to any relevant regulatory authority (whether in or outside Malaysia).

1. Information is our asset and therefore Trambellir places great importance on ensuring the security of your personal information. Trambellir takes precautions including administrative, technical and physical measures to safeguard your personal information against loss, theft and misuse, as well as against unauthorised access, disclosure, alteration and destruction.
2. Furthermore, we intend to protect your personal information and to maintain its accuracy. Trambellir implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. We regularly review and implement up-to-date technical and organisational security measures when processing your personal information.
3. Employees of Trambellir are trained to handle the personal information securely and with utmost respect, failing which they may be subject to disciplinary action.

1. We can assist you to access and correct your personal information held by us.
2. Where you wish to have access to your personal information in Trambellir’s possession, or where you are of the opinion that such personal information held by us is inaccurate, incomplete, misleading or not up-to-date, you may make a request to us via submitting requests to enquiry@trambellir.com.
3. We will use reasonable efforts to comply with your request to access or correct your personal information within 21 days of receiving your request.
4. Please note that Trambellir may have to withhold access to your personal information in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.
5. Please also note that Trambellir may use its discretion in allowing the corrections requested and/or may require further documentary evidence of the new information to avoid fraud and inaccuracy.
6. Please ensure your personal information (such as your mailing address(es), e-mail address(es) and telephone number(s) recorded with us are current, complete and accurate. Please notify us of any change in your personal particulars via the channels made available by us to ensure that all correspondence and/or communication reach you in a timely manner and to enable us to serve you better.
7. If you wish to request that we no longer use your personal data or limit the usage of your personal data in anyway whatsoever, you may submit a request to enquiry@trambellir.com. However, please note that Trambellir may not be able to proceed with the provision of the relevant products and services and you may not be able to use such products and services thereafter.
8. The personal data requested by Trambellir are mandatory for the relevant products and services which you must provide and agree to the processing of such personal data. Should you decide not to provide any or all of the personal data, Trambellir may not be able to proceed with the provision of the relevant products or services and you may not be able to use such products and services thereafter.