LAST UPDATED: 12th August 2018
1. C T Software and its affiliates (“CTS”, “we”, “our” or “us”) owns and manages websites, services, products (collectively, "CARAT") and applications (collectively, “Flagship”).
3. By using Flagship, you agree to the collection, use and disclosure of information in accordance with the Policy.
4. This policy is effective from 12th August 2018.
Information Collection and Usage
1. Collection of Information
1.1 We collect and store certain personal information as well as information related to your businesses that has been provided by you or obtained with your consent or as authorised by law. The types of information include details about:
a. Individual’s name;
b. Contact information including email address;
c. Profile picture;
d. Information on taxation, accounting and finance;
e. Other relevant information.
1.2 We may also collect information about other individuals and businesses (such as your employees, customers, suppliers) as you use Flagship. You must ensure that you are authorized to disclose the information to us. We may collect, use and disclose such information for the purposes described in this Policy, without taking additional steps required by privacy or data protection laws.
1.3 You are required to take reasonable steps to ensure that the parties concerned are aware of the Policy, and that they agree to the matters highlighted in it, including their information collected, the purposes, the intended recipients, the party’s right to obtain access to the information.
1.4 It is your responsibility to ensure that the information you provide to us is accurate and up-to-date. You may request access to the information we hold about you, or request that we update or correct any information we hold about you, by setting out your request in writing and sending it to us at email@example.com. We will process your request as soon as reasonably possible, provided we are not prevented from doing so on legal grounds.
2. Usage of Information
2.1 In the course of providing you with the requisite services, we may collect, retain, use, or disclose your information for the general purpose of administering our operations, providing client service, and complying with legal and regulatory requirements.
2.2 We require this information for the following reasons:
a. Internal record keeping;
b. To improve our products and enhance our services;
c. To customise the website according to interest of users;
d. For promotional purposes;
e. For market research purposes;
f. For purposes that we believe to be necessary or appropriate under applicable law and to comply with legal process.
2.3 By using Flagship, you agree to the information being collected, held and used in the ways listed above and for any other use you may authorize. We will only use your information for the purposes described in this Policy or with your explicit permission otherwise.
3. Information Storage
3.1 We have engaged other entities to host electronic data. The information collected is stored on servers hosted by reputable third party data centres located in Malaysia.
3.2 By using Flagship, you consent to that information being hosted on servers located in Malaysia. The information stored with us remains within our control at all times. The hosting provider’s role is limited to providing a hosting and storage service to us, and we ensure that our hosting providers do not have access to, and use the necessary level of protection for, your information with us. We do not disclose information to third parties located overseas.
4. Information Security and Protection
4.1 We are committed to ensuring that your information is secure. We take reasonable precautions to protect your information by putting in place suitable technical, organisational and security procedures to safeguard and secure the information we collect.
4.2 Your information is stored in a manner that reasonably protects it from misuse, loss and from unauthorized access, modification or disclosure. Your personal information is stored on secure facilities with safeguards that have SSL Certificates issued by leading certificate authority COMODO Limited. All sensitive data that is collected via Flagship is protected using industry-standard encryption technology and transmitted in a secure manner.
4.3 To further safeguard client information digitally, we maintain password protected systems, updated anti-virus and anti-spyware software, and encrypted hardware and software firewalls.
4.4 It is to be noted that the Internet is not in itself a secure environment in an absolute sense and we cannot give an absolute assurance that your information will be secure at all times. Transmission of personal information over the Internet is at your own risk.
4.5 We will advise you at the first reasonable opportunity upon discovering or being advised of a security breach where your information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorised persons or in any unauthorised manner.
4.6 It is however your responsibility to keep your security codes safe. You should notify us as soon as possible if you become aware of any misuse of your security codes or if you believe the security has been compromised. You should immediately change your security codes whenever possible.
5. Usage of Cookies
5.1 Like most major websites, we utilize cookies and other tracking technologies in connection with Flagship. Cookies are items of information that are stored on the user’s computer. It is employed to collect information and to assist in delivering specific content. It can tailor its operations to the specific needs of the user by gathering and storing information about the user’s details and preferences.
5.2 We use a combination of cookies on Flagship to monitor site usage. With the information we are able to carry out statistical data analysis about web page traffic and to provide a better website.
5.3 Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. The usage of cookies is in no way connected to any personally identifiable information.
6. Links to other Websites
6.1 Flagship does contain links to other websites. It must be noted that we do not own or have have any control over third party websites. We are not responsible or liable for the protection and privacy of any information which you provide whilst visiting such sites. You are advised to read the privacy statements and policies applicable to any third party.
7. Disclosure of Information
7.1 You should be aware that we may be required to disclose your information without your consent, if we believe in good faith that the circumstances are such that disclosure is required under the law, to cooperate with regulators or law enforcement authorities.
7.2 We reserve the right to disclose information with non-affiliated third parties with whom we have a contractual agreement to jointly offer, endorse or sponsor a financial product or service; and to service and maintain client accounts including effectuating a transaction.
8. Payment Information
8.1 Your credit, debit or charge card information are not stored on our servers and cannot be accessed by our staff.
9. Change of the Policy and Compliance with Law
9.1 This Policy is subject to change in the future. Any amended Policy is effective upon posting a new version that is available on our website. You are advised to make an effort to read this Policy periodically.
9.2 Your continued use of Flagship signifies your consent to abide and be bound by the amended Policy.
9.3 We will continue to take reasonable steps to implement practices and procedures to ensure that it complies with and adheres to all state and federal laws, rules and regulations.
10. Change of Ownership
10.1 If we are acquired or otherwise sell our business, we will transfer all of the information to the successor entity. We may try to notify you of any change in ownership by posting it on our website.
11. Contact Details
11.1 If you have any enquiries, concerns or comments that relate to our Policy, please contact us at firstname.lastname@example.org.