FWD Takaful Berhad

1. INTRODUCTION

1.1. This privacy policy (“Policy”) represents an agreement between you, as the user of the

mobile game known as “Komuniti Kita” (“Mobile Game”) and FWD Takaful Berhad (“we”,

“our”, “us” or “FWD”).

1.2. In compliance with the Personal Data Protection Act 2010 (“the Act”) and its regulations,

this policy is issued to all who downloaded and signed up for our Mobile Game. We are

dedicated to protecting your information and providing you with a safe, efficient, and

customized experience. As such, this Policy will inform you of your rights to your

Personal Data (as defined in Clause 2) that has been and/or will be collected and

processed by us.

2. COLLECTION OF PERSONAL DATA

2.1. FWD may in accordance with this Policy collect information and/or personal data,

including but not limited to:

a) Name;

b) Identity Card No. / Passport No.;

c) Gender;

d) Email address;

e) Mobile phone no.;

f) IP address;

g) Images (still or recording);

h) Sensitive personal data; and

i) Any Personally Identifiable Information (PII) defined by international laws or

standards.

2.2. We may also collect the following information:

2.2.1. Technical or other details about any device which you use to download and

access the Mobile Game, including but not limited to;

a) Internet and/or network connection, including your IP address, Media

Access Control (MAC);

b) Operating system, browser type, or other software;

c) Hardware, including computer hardware or mobile model;

d) Mobile device details, including your mobile device type and number,

mobile carrier details, and unique mobile device ID; or

e) Other technical details;

2.2.2. Details of your use of the Mobile Game, including but not limited to traffic data,

location/geographical data, the Mobile Game resources that you access, the

time you spend on the Mobile Game, crash reports, and reasons for

connections drops;

2.2.3. Data that you provide to us via any third party application which you use to

access the Mobile Game or which you make publicly available on such a

platform by data stored in log files, or by contacting us; and

2.2.4. Information provided when you report a problem with the Mobile Game.

(items under clauses 2.1 and 2.2 hereinafter collectively referred to as

“Personal Data”)

2.3. Your Personal Data enables us to achieve the Purposes (as defined in Clause 3 below)

that is in connection with our business.

2.4. By accessing or using the Mobile Game, you are authorizing us to collect, store, use

your Personal Data. You can control the amount of Personal Data you are authorizing

us to collect, store, and use by altering your privacy settings on the mobile device or

platform through which you access the Mobile Game. You can find out more about these

settings, and how to control them, on the mobile device or platform which you access

the Mobile Game from.

2.5. We may collect, store and use in accordance with this Privacy Policy certain Personal

Data where you provide such Personal Data either directly to us or through your use of

a third party platform, which may, upon your acceptance, provide this Personal Data to

us through its application programming interface. We may also receive your Personal

Data from our third party service providers. We will have access to any Personal Data

you provide to such third party service providers, and we will use that Personal Data in

correspondence with the Purposes of the Mobile Game and as otherwise set out in this

2.6. By accessing or using the Mobile Game via your mobile phone or other mobile device,

you are authorizing us to collect its identifier and IP address. We may also collect the

name you have associated with your mobile phone or other mobile device, device type,

telephone number, and other information you choose to provide. We may also access

your contacts to enable you to invite friends to join you on the Mobile Game if you

request us to do this on your behalf.

2.7. We receive and store the information that you provide, including your telephone number,

when you sign up to have SMS notifications sent directly to your mobile phone. These

messages notify you of in-game activity within the Mobile Game.

2.8. With your consent, we may send push notifications to your mobile device to provide

updates and other relevant messages. You can manage push notifications within the

settings of your mobile device.

3. PURPOSE FOR COLLECTION OF PERSONAL DATA

3.1. FWD may use your Personal Data for the following purposes:

3.1.1. to ensure content from the Mobile Game is presented in the most effective

manner for you and your mobile device or other device from which you access

the Mobile Game;

3.1.2. to allow you participate in interactive features of the Mobile Game, if you choose;

3.1.3. to monitor game engagement i.e. players’ high scores which will be populated on

the game leaderboard; and

3.1.4. to comply with our own legal obligations.

(hereinafter collectively referred to as “Purposes”)

3.2. For avoidance of doubt, your Personal Data will only be used for the Purposes listed

above and will not be used for marketing purposes by FWD.

4. SOURCES OF PERSONAL DATA

4.1. FWD may obtain your Personal Data from the registration of account upon launching

the game.

5. DISCLOSURE OF PERSONAL DATA

5.1. Please remember that using the Mobile Game may reveal information relating to you

which is publicly available on the Mobile Game, for example your screen name, your

profile picture and the content of your communications to other users, if any.

5.2. We are not responsible for the activities of other users or other third parties to whom you

choose to provide your personal information whether via the Mobile Game or otherwise.

5.3. If your account is closed, we are obliged to store the Personal Data which is saved in

our database for a period of time to allow us to comply with applicable laws. Please note

that it is not possible to delete your Personal Data prior to the expiry of applicable

statutory retention periods and in order for us to comply with our legal obligations.

5.4. We may disclose your Personal Data, and the contents of all your online communication,

if required to do so by law, or we believe in good faith, that such action is necessary to:

5.4.1. comply with any applicable laws or regulations or any legal process served on

us or the Mobile, or in circumstances where we are under a substantially similar

legal obligation;

5.4.2. protect and defend our rights or property; and

5.4.3. act to protect the personal safety of users of the Mobile Game.

5.5. We may disclose your Personal Data to other entities within FWD Group. These entities

will treat your Personal Data as confidential, in accordance with this Privacy Policy and

with all applicable Data Protection legislation and will process Personal Data only for the

Purposes state above, and within the terms set out herein. We are responsible for the

Personal Data under our control, including Personal Data disclosed by us to a service

provider (often referred to as the “data processor”) (“Service Provider”). We take every

measure to provide a comparable level of protection for Personal Data should the

information be processed by a competent Service Provider. FWD is committed with the

Personal Data Protection Act 2010, in particular, its policies as well as corresponding

guidelines and orders.

5.6. We can share your Personal Data with third party service providers and data processors

with regards to promoting their services. You can contact us any time you want to

withdraw of this promotion services. We will not actively share Your Information with

third party advertisers for their direct marketing purposes unless you give us your

consent. We may, however, share (i) aggregated information (information about you and

other users collectively, but not specifically identifiable to you); (ii) anonymous

information; and (iii) certain technical information to develop and deliver targeted

advertising in the Mobile Game and on the websites of third parties. We may also allow

advertisers to collect these types of information within the Mobile Game by using tracking

technologies like browser cookies and web beacons. Our collection, use, and disclosure

of anonymous or aggregated information are not subject to any of the restrictions in this

6. SECURITY OF PERSONAL DATA

6.1. FWD uses strict procedures and security features to prevent unauthorized access

wherever possible. Upon collection, our Service Provider will use computer systems with

limited access housed-in facilities to store the Personal Data. Data stored in cloud

services is in encrypted form including when we utilize third-party storage. The level of

security of Personal Data which is kept in a non-electronic environment are also treated

with strict procedures and means.

6.2. In order to prevent illegal manipulation by third parties and to identify and prevent any

form of misuse, we record the IP addresses of all mobile device and computers used to

access the line-up on the Mobile Game. In addition, all your Personal Data are protected

from unauthorized access by a firewall (a computer that is fitted with complex security

technology specifically designed to shield our network from the internet). Additionally,

we use reliable internal data protection mechanisms combined with a restrictive security

system. However, no website or internet transmission is completely secure, and we

cannot guarantee that unauthorized access, hacking, data loss, or other breaches will

never occur. We thus urge you to take steps to keep your Personal Data safe, and to

log out of your platform account after use.

7. USE OF COOKIES

7.1. By accessing or using the Mobile Game you authorize us to collect certain technical

information in order to (i) analyses usage of the Mobile Game; (ii) provide a more

personalized experience; and (iii) manage advertising. We, and our third party service

providers, may use server log files or web log files and tracking technologies to collect

and analyses certain types of technical information, including but not limited to, cookies,

IP addresses, device type, device identifiers, browser types, browser language, URLs,

domain names, landing pages, game state, the date and time of usage of the Mobile

Game, and other similar information,

7.2. We may also use other technologies, including but not limited to, web bugs, tracking

pixels and cookies. Web bugs allow us to know if a certain page was visited or whether

an email was opened, while tracking pixels allow us to advertise more efficiently by

excluding current users from certain promotional messages, identifying the source of a

new installation or delivering ads to you on other websites. Cookies allow us to improve

the quality of the Mobile Game and make the Mobile Game easier to use for you. A

cookie is a small text file recorded on your hard drive that identifies you as a unique user

and contains certain information about your particular login session and/or your use of

the Mobile Game.

7.3. The cookies used by the Mobile Game are solely associated to anonymous users and

their computers and do not provide Personal Data on users. Some cookies are used by

third parties to provide FWD with data on the effectiveness of the its engagements and

promotions. The cookies are used by the Mobile Game does not, in any way, collect

Personal Data that could be used to identify a specific user. In addition, cookies are of

temporary nature, used solely to improve the efficiency of the last transmission. Users

may configure their browser or their phone system to notify them of the reception of

cookies and to prevent their installation on their computer or mobile phone.

8. TRANSFER OF PERSONAL DATA

8.1. We are very serious about providing a comparable level of protection of Personal Data

should the information be processed or used outside Malaysia by our Service Provider

or experts.

9. MARKETING AND PROMOTIONAL PURPOSES

9.1. Upon registering with the Mobile Game, you may be receiving marketing and/or

promotional email or calls from us, which includes game promotions or information on

future events. If you do not wish to receive any promotional news via email, please click

the ‘unsubscribe’ link at the bottom of the email and you will be excluded from our

newsletters and contacts.

10. DATA SUBJECT OBLIGATIONS

10.1. It is necessary for FWD to collect and to retain your Personal Data. Therefore, it is also

obligatory for you to supply Personal Data to us in the most accurate manner. If you do

not provide us with Personal Data, FWD would be unable to, process Personal Data on

your behalf, for the Purposes stated in Clause 3 herein.

11. THE RIGHTS OF DATA SUBJECT

11.1. To request access to Personal Data: You have the right to request for access to Personal

Data processed by us with reasonable notice. Access or requests can be made through

online by sending an email to enquiry@commonextract.com

11.2. To request correction of Personal Data: You have the right to request for correction

and/or update your Personal Data that is inaccurate, incomplete, or outdated. Correction

requests can be made online by sending an email to enquiry@commonextract.com.

11.3. To limit processing of your Personal Data: You are entitled to limit our processing of

Personal Data by withdrawing the consent given previously, in each case, including for

direct marketing purposes, subject to any applicable legal restrictions and within a

reasonable time period.

12. DISCLAIMER

12.1. You expressly agree that the Mobile Game is provided on an "as is" basis without

warranties of any kind. We are not responsible for events beyond our direct control. Due

to the complex and constantly changing nature of our technology and business, we

cannot guarantee, nor do we represent, that there will be an error-free performance

regarding the privacy of your Personal Data, and we will not be liable for any indirect,

incidental, consequential or punitive damages relating to the use or release of your

Personal Data.

12.2. We cannot ensure the protection of any Personal Data that you provide to a third party

websites that links to or from the Mobile Game, since these third party websites are

owned and operated independently of us. Any Personal Data collected by these third

parties is not governed by this Privacy Policy but by the privacy policy, if any, of such

third party. If you have questions about a third party's information practices, please read

its privacy policy. We assume no responsibility or liability whatsoever for the practices,

actions or policies of such third parties, and we are not responsible for the content or

privacy practices of such online sites

13. CHANGES TO PRIVACY POLICY

13.1. We reserve the right to amend this Privacy Policy from time to time without prior notice.

We advise that you check our Mobile Game or our website for this Privacy Policy on a

regular basis. Kindly view our Privacy Policy on the website at

www.fwdkomunitikita.com.

14. ACKNOWLEDGMENT AND CONSENT

14.1. By communicating, engaging with FWD or downloading and using the Mobile Game,

you acknowledge that you have read and understood this Policy and agree and consent

to the use, processing, disclosure, storage, and transfer of your personal data by us as

described in the Policy. Any email we send to you will contain an automated unsubscribe

link so that you can opt-out of the mailing list. You can also withdraw your consent by

written notice or fill in the form on the website.

15. INQUIRIES AND COMPLAINTS

15.1. Should you require further information about the Personal Data we hold or the way in

which your information is being collected or used which are not set out in this Privacy

Policy please contact or write to us at enquiry@commonextract.com.