FWD Takaful Berhad
Privacy Policy for Mobile Game: Komuniti Kita
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.
2.1. 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
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
Privacy Policy.
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.
3.1. 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.
4.1. FWD may obtain your Personal Data from the registration of account upon launching
the game.
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
Privacy Policy.
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.
7.1. 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.
8.1. 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.
9.1. 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.
10.1. 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.
11.1. 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.
12.1. 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
13.1. 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
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.
15.1. 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.