Savvy Mart Privacy Policy

1. INTRODUCTION

1.1 We extend a warm welcome to the Savvy Mart platform, managed by Insure Savvy Sdn Bhd and its affiliates. (individually and collectively, “Savvy Mart”, “we”, “us” or “our”). At Savvy Mart, we prioritise our responsibilities in accordance with relevant privacy laws and regulations (“Privacy Laws”) seriously and is committed to respecting the privacy rights and concerns of all Users of our Savvy Mart’s website and mobile application (the “Platform”) (we refer to the Platform and the services we provide as described on our Platform collectively as the “Services”). Users refers to a user who registers for an account with us for use of the Services, including both buyers and sellers (individually and collectively, “Users”, “you” or “your”). We value the personal data you entrust to us and are committed to its proper management, protection, and processing. This Privacy Policy (“Privacy Policy” or “Policy”) aims to help you comprehend how we collect, use, disclose, and process the personal data you provide to us or that we possess about you, both now and in the future. It also assists you in making informed decisions before sharing any of your personal data with us.

1.2 “Personal Data” refers to information, whether accurate or not, that pertains to an individual and allows for their identification. It can include details such as a person’s name, identification number, and contact information.”

1.3 By utilising the Services, creating an account, visiting our Platform, or interacting with the Services, you acknowledge and agree to adhere to the practices, requirements, and policies outlined in this Privacy Policy. Furthermore, you provide your consent for us to collect, use, disclose, and process your personal data as described herein. If you do not agree to the processing of your personal data as outlined in this Privacy Policy, we kindly request that you refrain from using our services or accessing our platform. Your privacy and choices are important to us.

If there are any modifications to our Privacy Policy, we will notify you by posting those changes or the updated Privacy Policy on our Platform. We retain the right to amend this Privacy Policy at any time. By continuing to use the Services or Platform, including placing orders, you acknowledge and accept the alterations made to this Privacy Policy

1.4 This Policy operates alongside other relevant notices, contractual clauses, and consent provisions related to the collection, storage, use, disclosure, and processing of your personal data. It is not intended to supersede those notices or clauses unless expressly stated otherwise.

1.5 This Policy is applicable to both buyers and sellers who utilise the Services, unless expressly stated otherwise.

2. WHEN WILL SAVVY MART GET YOUR PERSONAL DATA?

2.1 We will/may get personal data about you:

When you register for our Services, use our Platform, or open an account with us.
When you submit any form related to our products and services (whether online or physical).
When you enter into agreements or provide documentation during your interactions with us.
When you communicate with us via telephone calls, letters, fax, face-to-face meetings, social media platforms, or emails (including interactions with our customer service agents).
When you use our electronic services or interact with us through our application or Platform (including interactions facilitated by cookies on our application or website).
When you grant permissions on your device to share information with our application or Platform.
When you link your Savvy Mart account with your social media or other external accounts, following the provider’s policies.
When you conduct transactions using our Services.
When you provide feedback or file complaints.
When you register for contests.
When you voluntarily submit your personal data to us for any reason.

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

2.2 Savvy Mart may gather personal data about you from various sources, including yourself, our affiliates, third parties, business partners (such as logistics or payment service providers), credit bureaus, marketing services providers, referral or loyalty programs, other users of our Services, and publicly available or governmental sources of data.

2.3 If you share personal data of other individuals with us—such as family members, friends, or contacts—you must ensure that you have obtained their consent for their data to be processed in accordance with this Policy. Transparency and consent are crucial when handling personal information.

3. WHAT TYPES OF PERSONAL DATA WILL SAVVY MART COLLECT?

3.1 Savvy Mart’s collection of personal data encompasses, but is not restricted to:

Name
Email address
Date of birth
Billing and/or delivery address
Bank account and payment information
Telephone number
Gender
Device-related information associated with accessing our Services or Platform
Details about your network, including contact lists when permissions are shared on your device, and interactions with people and accounts
Photographs, audio, or video recordings
Government-issued identification or other data required for due diligence, identity verification, and fraud prevention
Marketing and communications preferences, communication history, and interactions with service providers and third parties
Usage and transaction data, including search details, orders, and interactions with advertising and content
Location data
Additional information related to your use of our Services or Platform
Aggregate data on content engagement

3.2 By agreeing not to submit inaccurate or misleading information and promptly informing us of any inaccuracies or changes, you demonstrate your commitment to maintaining accurate records. Additionally, we retain the right, at our sole discretion, to request additional documentation for verification purposes.

3.3 If you choose to sign up for our Platform using your social media account or link your Savvy Mart account to your Social Media Account, we may access information that you voluntarily provided to your Social Media Account provider. We will handle and utilise this personal data in accordance with our Privacy Policy.

3.4 If you wish to prevent us from collecting the mentioned information or personal data, you can opt out by notifying our Data Protection Officer in writing. Detailed instructions on opting out can be submitted at clientcare@insuresavvy.com.my. However, please be aware that opting out or withdrawing your consent may impact your use of the Services and the Platform. For instance, opting out of location information collection will disable location-based features.

4. COLLECTION OF OTHER DATA

4.1 When you browse our Platform, your device sends information that may be logged by a web server. This typically includes your device’s Internet Protocol (IP) address, operating system, browser type, mobile device details (such as UDID or MEID), the address of any referring website, the pages you visit, and timestamps. Occasionally, a “cookie” (which can be disabled in your browser preferences) helps the site remember your last visit. If you’re logged in, this information is associated with your personal account. We also use anonymous statistics to understand how visitors use our site.

4.2 Our mobile applications utilise technologies such as GPS and Wi-Fi to collect precise information about your mobile device’s location. We process this data for various purposes, including location-based services that you request, delivering relevant content based on your location, and enabling you to share your location with other users. If you wish to withdraw permission for us to access your location information, you can typically adjust this setting in your mobile device’s preferences. For specific instructions on disabling location services, please consult your mobile device service provider or the device manufacturer.

4.3 When you interact with our website or mobile application, watch content, view advertisements, or access other software through our Platform or Services, your device provides us with information. This includes details like your IP address, operating system, and the specific content, advertisements, or software you engage with, along with timestamps.

5. COOKIES

5.1 Our authorised service providers and advertising partners may occasionally use “cookies” or other features to facilitate the collection or sharing of information related to your use of our Services or Platform. These features contribute to enhancing our Platform, introducing new services and features, and ensuring more relevant content delivery—such as through remarketing efforts. “Cookies” serve as identifiers stored on your computer or mobile device. They record data about device usage, including when and how the Services or Platform are accessed, the number of users, and other activities within our Platform. We may link cookie information to personal data. Additionally, cookies provide insights into your selected items for purchase and web pages viewed. This data helps us manage shopping carts, deliver personalised content, and enables third-party advertising partners to display ads across the internet. Furthermore, we utilize this information for data analysis and monitoring Service usage.

5.2 If you choose to decline the use of cookies by adjusting your browser or device settings, please be aware that this action may limit your ability to fully utilise all features of our Platform or Services.

6. HOW SAVVY MART USES THE INFORMATION YOU PROVIDE?

6.1 We might gather, utilise, reveal, and/or handle your personal information for any of the subsequent objectives:

Application/Transaction Processing: We collect and process your data to consider and handle your applications, transactions, and communications with us or third parties through our services.
Service Management: Your data is used to manage, operate, provide, and administer your use of our services and platform. This includes remembering your preferences and maintaining your user account.
Transaction Fulfillment: We process your data to respond to your requests, complete transactions, and notify you of service issues or unusual account activity.
Enforcement: Data may be used to enforce our terms of service and applicable license agreements.
Safety and Protection: We collect data to protect personal safety and the rights, property, or safety of others.
Verification and Due Diligence: Your data is used for identification, verification, due diligence, and know-your-customer purposes.
Credit and Risk Evaluation: We evaluate your credit and risk profile to determine eligibility for lending, pay-later, or credit products (where applicable).
Software Maintenance: Data helps maintain and administer software updates and support for smooth service operation.
Customer Service: We use data to facilitate customer service, respond to inquiries, and carry out your instructions.
Communication: We may contact you via voice calls, text messages, emails, or postal mail to manage your relationship with us and provide administrative information related to our services.
User Interaction: Your data allows other users to connect with you, view your activities, and receive notifications about private messages or comments.
Research and Development: We analyze your usage patterns to improve our services, recommend relevant products, and enhance your overall experience.
Audits and Surveys: Data helps validate our target audience size and understand user experiences.
Marketing and Advertising: We use various communication channels to share marketing materials related to our products and services, including collaborations with third parties. You can unsubscribe anytime.
Loyalty Programs: We offer loyalty and bonus programs in collaboration with partners.
Legal Compliance: Data may be disclosed as required by applicable laws or regulations, including displaying your details.
Statistics and Research: We generate internal and statutory reports based on aggregated data.
Due Diligence and Screening: Data is used for risk management and legal obligations.
Auditing: We audit our services and business operations.
Security and Investigations: Data helps prevent and investigate violations, fraud, and misconduct.
Legal Claims: Data is used to respond to claims against Savvy Mart or any content that allegedly violates third-party rights.
Storage and Backup: We store, host, and back up your personal data, whether within or outside your jurisdiction, for purposes like disaster recovery.
Business Asset Transactions: Data may be used in business asset transactions involving Savvy Mart, related corporations, affiliates, and other third-party organisations. These transactions include purchases, sales, leases, mergers, and financing.
Other Notified Purposes: We may use your data for other purposes, which we will inform you of when obtaining your consent.

(collectively, the “Purposes”).

6.2 You acknowledge, consent, and agree that Savvy Mart may access, preserve, and disclose your account information and content if required by law, pursuant to a court order, or at the request of any governmental or regulatory authority with jurisdiction over Savvy Mart. This access, preservation, or disclosure may be necessary to: (a) comply with legal processes; (b) enforce the Savvy Mart Terms of Service or this Privacy Policy; (c) respond to claims against Savvy Mart or allegations that content violates third-party rights; (d) address customer service requests; or (e) protect the rights, property, or personal safety of Savvy Mart, its users, and the public.

6.3 As the purposes for which we collect, use, disclose, or process your personal data depend on the specific circumstances, additional purposes may not be listed above. However, we will inform you of any other purposes at the time of obtaining your consent, unless processing the relevant data without your consent is allowed by privacy laws.

7. HOW DOES SAVVY MART PROTECT AND KEEP CUSTOMER INFORMATION?

7.1 We employ various security measures to safeguard your personal data within our systems. User information is stored behind secure networks and accessible only to a limited number of authorised employees. However, it’s important to note that absolute security cannot be guaranteed.

7.2 We retain personal data in accordance with privacy laws. When we determine that the purpose for collecting personal data is no longer served, we either destroy or anonymise it. If you stop using the platform or your permission is terminated, we may continue storing, using, or disclosing your data as outlined in our Privacy Policy. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

8.1 As part of our business operations, we may need to use, process, disclose, or transfer your personal data to third-party service providers, agents, affiliates, or related corporations. These parties, whether located in Malaysia or elsewhere, would handle your personal data for the Purposes mentioned above. We take measures to ensure that these third parties and our affiliates maintain the security of your data, protecting it from unauthorised access, collection, use, disclosure, or processing. Additionally, they retain your personal data only as long as necessary for the specified Purposes:

Our subsidiaries, affiliates, and related corporations.
Buyers or sellers you have transacted with or interacted with on the Platform or in connection with your use of the services for the stated Purposes.
Other users of our platform for one or more of the Purposes mentioned.
Contractors, agents, service providers, and other third parties we engage to support our business. These may include mailing houses, logistics providers, financial services partners, advertising agencies, telecommunication companies, information technology firms, and data centers.
Governmental or regulatory authorities with jurisdiction over Savvy Mart or as permitted under Section 6.2.
A buyer or successor in the event of a merger, divestiture, restructuring, dissolution, or other sale or transfer of Savvy Mart’s assets. Personal data held by Savvy Mart about our service users would be among the transferred assets.
Third parties to whom we disclose information for one or more of the specified Purposes, and these third parties would also collect and process your personal data for those Purposes.

8.2 We may share user information, including statistical and demographic data, with advertising partners and third-party suppliers of advertisements, remarketing, and other programming.

8.3 In cases where privacy laws or other applicable regulations allow an organisation like ours to collect, use, or disclose your personal data without your explicit consent, that legal permission remains in effect. We may use your personal data based on recognised legal grounds, including compliance with legal obligations, performance of contractual agreements, legitimate interests (where the benefits outweigh any impact on your data protection rights), or when necessary for legal claims.

8.4 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site. Additionally, technology malfunctions or unauthorised access could occur. While we deploy reasonable security measures as required by privacy laws, absolute security cannot be guaranteed. For instance, malicious hacking by external actors is beyond our control.

8.5 As outlined in Savvy Mart’s Terms of Service, users (including employees, agents, and representatives) who possess another user’s personal data through the platform agree to the following: (a) comply with applicable privacy laws regarding data collection, processing, storage, and transfer. (b) allow Savvy Mart or the user whose data was collected (the “Disclosing Party”) to remove their data from the recipient’s database. (c) permit Savvy Mart or the Disclosing Party to review the information collected about them by the recipient, in accordance with relevant laws.

8.6 Sellers (including employees, agents, and representatives) must comply with applicable privacy laws. Regarding buyer’s personal data received from Savvy Mart: (a) they can only use such data reasonably for responding to buyer inquiries and completing transactions, with prior consent. (b) sellers should not contact buyers outside the Savvy Mart platform using this information. (c) unauthorised third-party disclosure is prohibited without consent. (d) sellers must employ security measures, retain data as needed, and delete or return it upon request. (e) in case of data breach, they should inform Savvy Mart’s Personal Data Protection Officer at clientcare@insuresavvy.com.my.

9. INFORMATION ON CHILDREN

9.1 Savvy Mart’s Services are not intended for children under the age of 13. We do not knowingly collect or maintain personal data or non-personally-identifiable information from anyone under 13 years old. Our Platform and other Services are not directed at children under 13. As a parent or legal guardian, please ensure that children under your care do not submit personal data to Savvy Mart. If personal data of a child under 18 in your care is disclosed to Savvy Mart, you consent to the processing of the child’s personal data and accept responsibility on behalf of the child. We will close any accounts used exclusively by such children and remove any personal data submitted without parental consent by any child under 18.

10. INFORMATION COLLECTED BY THIRD PARTIES

10.1 Our Platform uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyse how Users use the Platform. The information generated by the cookie about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Platform, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

10.2 We, and third parties, may from time to time make software applications downloads available for your use via the Platform or through the Services. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your device’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by Savvy Mart. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.

11. DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES

11.1 We do not guarantee the security of personal data and other information you provide on third-party sites. However, we take several security measures to protect your personal data within our possession or control. Your information is stored behind secured networks and is accessible only to a limited number of authorized individuals who are bound by confidentiality requirements. When you place orders or access your personal data, we utilize secure servers. All sensitive information you provide is encrypted in our databases and accessed only as described above.

11.2 Savvy Mart may link to third-party websites and frame them within the platform. These linked sites have separate privacy policies and security arrangements. Even if a third party is affiliated with Savvy Mart, the company has no control over these linked sites. Each linked site operates independently with its own privacy practices. Data collected by co-brand partners or third-party websites (even if offered through Savvy Mart’s platform) may not be received by Savvy Mart.

11.3 We do not assume responsibility or liability for the content, security arrangements (or lack thereof), and activities of these linked sites. While these sites are provided for your convenience, accessing them is at your own risk. However, we strive to maintain the integrity of our platform and its associated links. If you encounter any issues with specific links, we welcome your feedback.

12. WILL SAVVY MART TRANSFER YOUR INFORMATION OVERSEAS?

12.1 Your personal data and information may be transferred, stored, or processed outside of your country for various purposes. In most cases, we process your personal data overseas, where our servers are located. Savvy Mart will only transfer your information overseas in compliance with Privacy Laws.

13.1 Withdrawing Consent

13.1.1 If you wish to withdraw your consent for the collection, use, or disclosure of your personal data, you can send an email to our Personal Data Protection Officer at clientcare@insuresavvy.com.my. We will process your request in accordance with our Privacy Policy and legal obligations under the Privacy Laws. However, it’s important to note that withdrawing consent may impact our ability to continue providing services to you, and we may need to terminate your existing relationship or contract with us.

13.2 Requesting Access to or Correction of Personal Data

13.2.1 If you have an account with us, you can personally access and correct your personal data through the user account setting page on our platform. However, if you don’t have an account, you can still request access or corrections by submitting a written request. To do so, please email our Personal Data Protection Officer at clientcare@insuresavvy.com.my. Be sure to provide enough information to verify your identity and specify the nature of your request. We will handle your request promptly and in accordance with our Privacy Policy and legal obligations.

13.2.2 If we decide to charge a reasonable fee for handling and processing your access requests, we will provide you with a written estimate of the fee. It’s important to note that we’re not obligated to respond to or address your access request unless you agree to pay the fee.

13.2.3 As outlined in the Privacy Laws, organisations have the right to refuse to correct personal data under specific circumstances.

14. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US

14.1 If you have any questions or concerns about our privacy practices, feel free to reach out to us via email at clientcare@insuresavvy.com.my.

Privacy Policy