GEMSPOT’s Privacy Policy
Overview
This Privacy Notice sets out how GEM Live Sdn. Bhd. (“the Company or GEMSPOT”) and
its wholly owned subsidiaries will handle personal information in accordance with the Personal
Data Protection Act 2010 (“PDPA”) and the laws of Malaysia.
Our Company and our subsidiaries, value the trust of our users and the public. We are
committed to protecting your personal information and ensuring that your personal information
is used only for the purposes stated herein and/or as otherwise provided for in law.
Definition of Personal Information
Personal information refers to any information which relates directly or indirectly to you. This
includes any information that can be used to distinguish, identify or contact you. For the
purposes of this Privacy Notice, personal information encompasses sensitive personal
information which relates to information relating to your health, political opinions, religious
beliefs, etc.
Collection and Use of Personal Information
We collect personal information to personally identify you when you use our application. This
is to ensure a smoother and more efficient user experience. We may also collection
information that personally identifies you if you choose to submit your personal information for
the various purposes made available on our application. This information may include data
not limited to contact information about you such as your name, address(es), telephone
number(s), email address(es) and other contact information, profession, date of birth, country
of residence and gender. We will then serve you with a personal data protection notice
("Notice") to confirm your consent and notify you on our processing of your personal
information. The processing of your personal information will be done in accordance with all
applicable laws. Our Company and/or its subsidiaries may collect personal information from
you in one or more of the following methods:
● Use of any of our services or mobile application
● The filling in of forms, surveys, competitions etc.
● By responding to any marketing materials we send out
● By application and/or registration with any of our subsidiaries
● By providing feedback to us (for example via our application or in hard copy)
Other than personal information obtained from you directly (as laid out above), we may also
obtain your personal information from third parties we deal with and from such other sources
in respect of which you have given your consent to disclose information relating to you and/or
where otherwise lawfully permitted.
The Company and/or its subsidiaries may collect personal information from you or from the
category of third parties identified above which is to be utilised for one or more of the following
purposes:
● To properly identify you
● To assess your application(s) /request(s) for our services and/or products
● To keep in contact with you and provide you with any information you have requested
● To establish and better manage any relationship we may have with you
To process any communications you send us (for example, answering any queries and
dealing with any complaints and feedbacks)
● To improve our services and products and to develop new services and products
● To produce data, reports and statistics which may be used by the Company for commercial
purposes
● To investigate, respond to a defend claims made against, or involving the Company and/or
its subsidiaries
● To conduct marketing activities
● To comply with legal and regulatory requirements
For any other purposes that is required or permitted by any law, regulations, guidelines
and/or relevant regulatory authorities
Incomplete provision of Personal Information
Where indicated (for example in application forms), it is obligatory to provide your personal
information to us to enable us to process your application for our services and/or products.
Should you decline to provide such obligatory personal information, we may not be able to
process your application or provide you with our services or products via our application.
Disclosure of Personal Information
As a part of providing you with our services and/or products and the management and/or
operation of our application, the Company and/or its subsidiaries may be required or need to
disclose information about you to the following third parties:
● Law enforcement and government agencies
The Company and/or its subsidiaries, business partners, clients and relevant business
parties
Companies and/or organisations that act as our agents, contractors, service providers
and/or professional advisers
Companies and/or organisations that assist us in processing and/or otherwise fulfilling
transactions that you have requested
Our business associates and other parties for purposes that are related to the purpose of
collecting your personal information
● Other parties in respect of whom you have given your express or implied consent subjected
at all times to any laws (including regulations, guidelines and/or obligations) applicable to the
Company and/or its subsidiaries.
● Any agent, contractor or third party service provider who provides administrative, marketing
and research, training, distribution, data processing, telecommunications, computer, payment
or other services to the Company and/or its subsidiaries
Any person, who is under a duty of confidentiality who has undertaken the responsibility to
keep such information confidential.
We do not disclose your personal information to unaffiliated third parties without your consent.
However, we may disclose your personal information if required by law or in good faith, if such
action is necessary to comply with any law enforcement agency requirements, court orders or
legal processes.
Right to Access and Correct Personal Information
We can assist you to access and correct your personal information held by us.
Where you wish to have access to your personal information in the Company and/or its
subsidiaries possession, or where you are of the opinion that such personal information held
by us is inaccurate, incomplete, misleading or where relevant, not up-to-date, you may make
a request to by sending us an e-mail at the address detailed at the end of this Privacy Notice.
We will use reasonable efforts to comply with your request to access or correct your personal
information within 21 days of receiving your duly completed Data Access Request Form/Data
Correction Request Form and the relevant processing fee (if any).
Please note that the Company and/or its subsidiaries 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.
Online Dealings and Use of Cookies
The Company and its subsidiaries collect information about your use of our mobile application
from Cookies or other methods. Cookies are packets of information stored in your computer
or personal mobile device which assist your application navigation by customising information
tailored to your needs. Cookies in themselves do not identify the individual user, just the
computer and/or personal mobile device used.
You are not obliged to accept cookies. If you are concerned, you can set your computer and/or
personal mobile device either to accept all cookies, to notify you when a cookie is issued, or
not to receive cookies at any time. However, rejection of cookies may affect your use of the
application as we will be unable to personalise aspects of your use of the application.
Third-Party Links and Direct and Indirect Marketing
In an attempt to provide increased value to our users, the Company and/or its subsidiaries
may use your personal information to provide you with information about our and third party
services and/or products, which may or may not be of interest to or benefit you.
In certain instances, we may disclose your personal information to our preferred merchants
and strategic partners. However, please note that we will only disclose your personal
information to our merchants and strategic partners where your prior consent has been
obtained and subject at all times to any laws (including regulations, guidelines and/or
obligations) applicable to the Company and its subsidiaries.
We take reasonable steps to ensure that our agreements with our merchants and/or strategic
partners include appropriate privacy and confidentiality obligations.
If you do not wish your personal information to be utilised for the purposes of marketing or
should you change your mind in relation to your previous decision, please contact us via e-
mail at the address detailed at the end of this Privacy Notice. Your latest written instructions
to us will prevail.
Please be informed that this Privacy Notice applies solely to our mobile application and/or our
subsidiary’s mobile application and does not apply to any third party websites and/or
applications you may access from our application. To determine how they deal with your
Personal Information, you should ensure that you read their respective privacy policies.
Notification of Changes
If we decide to change our privacy policy, we will post those changes on our application so
the users are always aware of what information we collect, how we use it, and under what
circumstances, if any, we disclose it. If, at any point, we decide to use personally identifiable
information in a manner different from that stated at the time it was collected, we will notify
users by way of an e-mail. Users will have a choice as to whether or not we use their
information in this different manner. We will use information in accordance with the privacy
policy under which the information was collected.
Please check our application on an ongoing basis for information on our most up-to-date
practices.
Deletion of Personal Data
Subject to this Privacy Policy, the Company shall, upon your official written request, delete the
personal data and information after the end of the provision of the services unless applicable
law requires storage of your personal information. In any event to the extent required or
allowed by law, the Company may retain a copy of your personal data or information for
evidence purposes and/or for the establishment, exercise or defence of legal claims and/or to
comply with applicable laws and regulations.
Contact Information
If you wish to access or correct your personal information, or limit our processing of your
personal information, or if you have questions or concerns related to this Privacy Statement,
you may contact us by email at hello@gem.live or by writing to us at:
Attn: Privacy Officer
GEM Live Sdn. Bhd.
Lot 13.2, 13
th
Floor, Menara Lien Hoe,
No.8, Persiaran Tropicana,
Tropicana Golf & Country Resort,
47410 Petaling Jaya, Selangor,
Malaysia
Tel No.: 03-7887 8818