Caya Academy: Your English Language Partner
1. What this policy covers?
All references in this policy to "our," "us," or "we" refer to Caya Academy Sdn Bhd.
2. What is personal data?
Generally, the terms "personal data" or "personally identifiable information" mean information relating to an identifiable person. In some cases, the terms may include information that identifies a household. An identifiable person is an individual who can be singled out by using information such as their name, address, or telephone number. For example, Ms. Ahmad bin Ali, who lives at 123 Jalan Besar with a telephone number of 012-3456789, is an identifiable person. Ahmad's name, address, telephone number, and even her choice of pronoun are examples of her personal data.
3. What's not covered in this policy?
a) What Personal Data We Collect and How We Collect It
The personal data we collect can be divided into three categories:
i) Personal data you give us directly.
ii) Personal data we collect automatically through our websites, apps, or services.
iii) Personal data we obtain from other sources.
i) Personal data you give us directly may include:
• Full name
• Date of birth
• School Name
• Email address
• Telephone number
• Contact or mailing address
• Preferences, likes, bookmarks, ratings, and feedback
• Banking or payment details
• Image, video, or any other media
You have the opportunity and choice to provide us with this personal data at various times and for various reasons, including:
• Using the online forms provided on our websites and apps to do things such as create an account, request help, provide feedback, take a survey, enter a contest, or apply for a job.
• Registering for or attending in-person or online events hosted by us.
• Contacting us by phone, post, or email.
• Interacting with us on platforms and technologies through which we communicate, such as messaging apps, helpdesk tools, work collaboration tools, and financial management tools, vendor portals, and human resource management tools.
• If you are a supplier or partner, you may give us personal data about you when you are offering or providing services to us.
• Registration form submitted by schools
ii) Personal data we collect automatically may include:
• Information about your device(s).
• Information about the app you are using.
• Information about your Internet browser.
• Your IP address.
• Other online identifiers.
• Location information based on your IP address.
• Usage behavior and history.
• Your image where captured on CCTV at any of our premises.
• Time spent at our premises.
• Some of the technical data listed above is collected when you interact with us online. This could mean using a smartphone or a computer.
iii) Personal data we obtain from other sources may include:
We may receive personal data about you from third parties such as your school, your employer, our sponsors, our suppliers, contractors and consultants, group companies, public websites (such as LinkedIn, Facebook, Instagram and Twitter), and public agencies.
b) Sensitive Categories of Personal Data
In limited circumstances, personal data that you provide to us may fall into sensitive categories such as information about your physical and mental health, sexual orientation, racial or ethnic origin, veteran status, political opinions, philosophical belief, trade union membership, and biometric data. Unless required by law (such as COVID-19 testing or some employment-related information), providing these categories of personal data will always be your choice.
We take extra precautions with personal data in sensitive categories to minimize its collection, limit access to it, protect it, and consider whether and with whom we share it.
c) How We Use Your Personal Data
Like all organizations, we use the personal data we collect in multiple ways. Examples include:
• Allowing you to access our website and apps.
• Receiving and responding to questions from you about our website, apps, or broadcasts.
• Improving, maintaining, and providing technical support for our websites and apps.
• Aiding the security of our websites, apps, and facilities.
• Allowing you to participate in contests or surveys.
• Storing information about your preferences and allowing us to customize our websites and apps according to your individual interests.
• Carrying out the purchases you have requested.
• Allowing us to enter into and comply with contractual arrangements.
• Processing job applications.
• Conforming to the requirements of the law or legal process.
• Protecting or defending your rights, our rights, or the rights of other users.
• Protecting the health and safety of our users, our employees, or the general public.
• Enabling us to purchase, receive, and manage services from you or your employer.
• Paying salaries, administering benefits, and conducting performance reviews for our employees.
We may use your personal data to send you certain mandatory service communications, such as welcome letters, billing reminders, information on technical service issues, security warnings, announcements, and promotional materials such as future competitions and classes from us.
In certain instances, we may provide you with the option to set your preferences for receiving email communications or WhatsApp from us; that is, to agree to some communications but not others. You may choose to stop receiving future commercial email communications or WhatsApp from us by contacting us directly.
d) Legal Basis for Processing Personal Data
Some jurisdictions require that we have a legal basis for collecting and processing your personal data. Where that is required, we consider those legal bases to be:
• To perform our obligations under a contract with you.
• To comply with our legal obligations.
• For our legitimate interests and the legitimate interests of others, which include:
• The running and growing of our business for our shareholders.
• Delivering our content to our viewers via broadcast, our websites, and apps.
• Identifying and selecting qualified suppliers and partners.
• Conducting market research and business development.
• In cases where you choose to provide us with your personal data via one of our websites or apps, we process your personal data, at least in part, based on your consent. You may withdraw this consent at any time by contacting us.
Where we are relying on our (or another person's) legitimate interests, we will always consider the categories or types of personal data in question to balance our use against the possibility of any action that might be counter to your rights. We will never purposefully violate the rights you have in your personal data and ask that you please contact us with any concerns.
e) How We Share Your Personal Data
f) Categories of Organizations We Share Personal Data With
• Our partners and service providers that perform professional services, technical services, or handle transactions on our behalf.
• Government agencies when required.
g) Data Storage, Security, and International Transfers
By visiting and using our websites and apps, the personal data you share with us or that we collect automatically will be collected, stored, processed, or transferred to and within Malaysia, where our technical infrastructure is located and operated. Some of our service providers may have operations in other countries as well.
In addition to the risks listed in the Storage, Risk, and Security Section, the data protection and other laws of Malaysia and other countries where your personal data may be collected, stored, or processed might not be as comprehensive as those in your country.
By using our websites and apps or providing any of your data, you consent to your information being transferred to and stored or processed in our facilities and the facilities of the third parties described in this policy.
You may withdraw your consent at any time by contacting us.
h) Your Rights
Your rights related to your personal data may vary depending on where you live or are located. Your rights may include:
• The right to be informed of what personal data we collect, why we collect it, and whether we transfer or share your personal data.
• The right to access your personal data and correct or update any errors.
• The right to erasure.
• The right to notification.
• The right to restrict the use or sale of personal data.
• The right to object to some forms of processing.
• The right to lodge a complaint with the competent authority.
i) Understanding Your Rights
We encourage you to research and understand your rights relative to your personal data. We will never discriminate against anyone for exercising their rights or inquiring about their personal data.
j) Data Security Risks
The risk to the personal data in our care is that, despite our security precautions, it may be lost, stolen, or misused. Although we take steps to protect the personal data you provide to us, the transmission of information over the internet is never completely secure. We cannot guarantee the security of your personal data while in transit to us. Once we have received your personal data, our security team will use industry-standard procedures and security features to secure it.
k) Data Retention
We keep your personal data for no longer than we need it to meet the 'why' of Why We Collect Personal Data or as long as we have another valid reason to keep it (the Legal Basis discussed above). If you have an account with us, you may delete it or request that it be deleted at any time.
l) Use of Tracking Technology
Our websites and apps use tracking technology to allow us to offer you a more personalized experience. The information collected through this tracking technology may be considered personal data. We never allow interest-based or targeted advertising on our websites or applications. Where we use tracking technology, you may block the technology. To do so, you can activate the setting on your device that allows you to refuse the setting of all or some tracking technology. We have provided some helpful links below for various devices and operating systems. Please be aware that if you use your device settings to block all tracking technology, you may not be able to access all or parts of our websites or apps or use all the available functionality.
m) Managing Communication Preferences
Lastly, if you receive marketing or promotional emails from us that you no longer wish to receive, please click the "Unsubscribe" link in our emails, contact us directly, or for certain services, log into your account and adjust your preferences.
n) Protection of Minors' Data
If you are the parent or guardian of a child and believe that we have somehow collected the personal data of your child without your consent, please contact us.
o) Contact Us
If you would like to contact us with a specific request, please use our contact form located at the Privacy Center link provided on our websites or apps.
Email: [email protected]
Phone: 03-86034277 or 016-2243400