Privacy Policy

Privacy Policy (Updated - 13 March 2019)

1. Privacy Policy

1.1 This Privacy Policy explains how we collect, use, share and store personal data relating to the Website.

1.2 Personal data ("Information") in this Privacy Policy refers to data that can be used to identify an individual.

1.3 By accessing or using the Website, as a User, you consent to our collection, use, sharing and storing of Information in accordance with this Privacy Policy. In particular, you understand and agree that the Information which we collect from you is necessary for us to provide and operate the Website and to interact and communicate with you. If you do not agree with anything in this Privacy Policy, you should stop using the Website.

1.4 Unless otherwise stated, the capitalised terms in this Privacy Policy are used in the same way as used in our Terms of Use.

1.5 This Privacy Policy applies to all visitors, Users and others who access or use the Website.

1.6 This Privacy Policy contains the following sections:

  • Information we collect
  • How we use your Information
  • Sharing of your Information
  • How we store your Information
  • Children's privacy
  • Other websites and services
  • Contacting us about your Information
  • Changes to this Privacy Policy

2. Information we collect

A. The following is Information which you provide to us directly:

2.1. Registration information

When you register for an Account on the Website, we may collect Information which we ask you to provide, such as your name, password and email address. Such Information must be provided in order to register an Account. You should maintain the secrecy of your Account password at all times.

2.2 Other personal details about yourself

Subsequently, as you interact and communicate with us (e.g. you reply to our service updates or support emails to you, and when you participate in customer surveys or offers etc.), you may also reveal to us other Information about yourself (e.g. your name, address, phone number, gender etc.).

B. Other Information which we receive when operating the Website:

2.3 Analytics information

We use third party analytics tools to help us measure traffic and usage trends for the Website. These tools collect information sent by your device including the web pages you visit, add-ons, and other information that assists us in improving the Website. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

2.4. Cookies and similar technologies

2.4.1 The Website contains "cookies", clear gifs (also known as "web beacons" or "web bugs"), or similar technology. A cookie is a piece of data that is sent to your Internet browser, which will store the cookie on your computer if your browser is enabled to accept cookies. Web beacons assist in the delivery of cookies and the collection of non-personally identifiable information, such as "click path" and other data as described above. We use cookies like traffic log cookies to identify which web pages are being used, and others that are relevant to your use of the Website. Cookies don't give us access to your computer or personal information, only the data you choose to share.

2.4.2 The Website use cookies, clear gifs, frames, server log analysis and other technologies as they are developed to customise your experience with the Website. Most Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or "Help" screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some services and portions of the Website may not function properly. For the exhaustive list of cookies we collect, see the 'List of Cookies We Collect' section.

2.5 Log file information

2.5.1 Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the web page or app is downloaded to your browser or device.

2.5.2 When you use the Website, our servers automatically record certain log file information, including your web request, Internet Protocol address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Website, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then helps us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Website.

2.6 Device identifiers

2.6.1 When you use a mobile device like a tablet or phone to access the Website, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers". Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by us.

2.6.2 A device identifier may deliver information to us or to a third party partner about how you browse and use the Website and may help us or others provide reports or personalised content and ads. Some features of the Website may not function properly if use or availability of device identifiers is impaired or disabled.

3. How we use your Information

3.1 How we use your Information will depend on the nature of your interaction with the Website and with us. We need to have valid grounds to process your Information. Most times, we would seek your consent, like when you register for an Account or subscribe to our mailing list. Other times, when you reasonably expect us to use your Information, we will not ask for your consent, but only when it is legally permissible for us to do so (e.g. it is necessary for our performance of a contract, or for us to comply with a legal obligation etc.). Generally, we collect and use Information for the following purposes and our legal basis for so doing is also set out below:

Purpose Legal Basis
a) to register your Account and verify your identity; consent and performance of contract
b) to process your order for products and to deliver them to you; consent, performance of contract and legal obligation
c) to process your products returns, payments made by you or refunds to you; consent, performance of contract and legal obligation
d) to respond to your requests, feedback or queries, and to otherwise communicate with you; consent, performance of contract, legal obligation or legitimate interest
e) to detect fraud and/or conduct credit checks; legitimate interest
f) to remember Information so that you do not have to re-enter it each time you use the Website; legitimate interest
g) to analyse how you shop and what you shop for, contact you regarding products you have shown interest in and provide to you with personalised online advertisements on products you might be interested in so as to enhance your shopping experience with us; legitimate interest
h) to test, improve, and monitor the Website, including diagnosing and fixing technology problems, and including use as part of our API; legitimate interest
i) to monitor metrics such as site access, downloads, traffic and demographic patterns, and conduct analysis and analytics in order to, improve and ensure security of the Website and provide higher quality service; legitimate interest
j) to prevent or take action against activities that are, or may be in breach of this Privacy Policy or our Terms of Use; and legitimate interest
k) to comply with applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us. legitimate interest

3.2 For clarity, you're granting us permission to collect and use your Information for the above-mentioned purposes (through your use of the Website) not only allows us to provide the Website as it exists today, but also to provide you with new capabilities as we develop the Website in the future.

3.3 Apart from these purposes, we may also notify you of marketing related purposes for which we process your Information and shall seek your consent to such purposes (e.g. when you sign-up to receive our newsletters and other marketing related materials and communications, participate in a survey or market research, enter a competition etc.).

3.4 If you have previously agreed to us using your Information for marketing related purposes, you may change your mind at any time by emailing us at support@sweelee.com.my. Also, you may click on the "Unsubscribe" link in emails from us to indicate that you're no longer interested in receiving further marketing material from us.

4. Sharing of your Information

4.1 We will only share your Information in accordance with this Privacy Policy. We will not rent or sell your Information to third parties without your consent, except as noted in this Privacy Policy.

4.2 We may share your Information with the following parties:

a) Our related entities: These are businesses that are legally part of the same group of companies that we are part of, or that become part of that group.

b) Our service providers: These are our third party contractors. We engage them to assist us in operating and managing aspects of the Website, such as developing the Website's features and functionality, marketing, processing payments, processing data or statistics, hosting content, providing server space, providing push notifications and emails, reviewing content for compliance, and legal advice.

c) Our third party advertisers: We may provide Information to third party advertisers so that they can notify you of events or products which may be of interest to you. For instance, you may be notified of an upcoming concert or product release.

d) Analytics services: We may use third party analytics providers and products to obtain, compile and analyse Information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data), and may provide such Information to these analytics providers for the purpose of obtaining statistics and other information about how Users are using and interacting with the Website.

e) We may remove parts of data that can identify you and share anonymised data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

4.3 We require that all parties to whom we share Information implement adequate levels of protection in order to protect such Information. We also require that these parties only process your Information strictly for purposes which we engage them for and consistent with the purposes that we have described in Section 3 ("How we use your Information") or with other purposes for which your consent has been sought and obtained.

4.4 We may also share your Information with third parties in the following circumstances:

a) Change of control: If the ownership of our business changes or we undertake a reorganisation of our business, we may transfer your Information to the new owners so they can continue to operate the Website. The new owners may subsequently make changes to this Privacy Policy;

b) If permitted or required by law: We may disclose Information if we believe that such disclosure is required or permitted by law (e.g. responding to requests from government authorities, or disclosure pursuant to court orders or other legal demands); and

c) To protect interests: We may disclose Information if we determine it is necessary to enforce or protect our rights or the property or personal safety of the Users of the Website (e.g. to enforce this Privacy Policy or our Terms of Use, or to prevent or take action against illegal activities, suspected fraud, or potential threats or breaches).

5. How we store your Information

5.1 We, our related entities, service providers and other third parties with whom we have shared your Information with, may transfer your Information to other countries in which our and their facilities and/or businesses are located, to be stored or processed. We will ensure that all entities located outside of Malaysia to which we transfer Information observe a standard of data protection which is comparable to that required under the Malaysian Personal Data Protection Act 2010. This includes the entities' making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risk to your Information, and removing the Information as soon as it is reasonable to assume that its retention is no longer necessary.

5.2 Currently, the countries to which Information is transferred for the purpose of storage on cloud servers are listed here. We may update this list periodically to reflect any new locations where your Information may be stored.

5.3 By registering for an Account and/or using the Website, you acknowledge that the transfer of your Information to countries in which we, our related entities, service providers and other third parties with whom we have shared your Information with, have facilities and/or businesses are necessary for us to provide the Website to you, and that we have provided you with a reasonable summary of how your Information would be protected when it is so transferred. You consent to the transfer of information to such territories as they exists today and to any other country in which we, our related entities, service providers and other third parties with whom we have shared your Information with, maintain facilities and/or businesses in the future, and their processing of Information as described in this Privacy Policy.

6. Children's privacy

6.1 You may only use the Website if you are either 18 years of age or more, or over the applicable age of majority in your jurisdiction. If you are under 18 years old or the applicable age of majority in your jurisdiction, you may use the Website only with the consent and involvement of your parent or guardian. The Parental Consent Form to be submitted to us is accessible here.

6.2 We do not knowingly collect Information from children under the age of 13 without parental consent. If you are a child under 13 years of age, you are not permitted to use the Website and should not send any information about yourself to us through the Website.

6.3 In the event that we become aware that we have collected Information from any child, we will delete that Information. If you are a parent or guardian and you believe that your child under the age of 13 years has provided us with Information without your consent, please contact us at support@sweelee.com.my and we will take reasonable steps to ensure that such Information is deleted from our systems.

7. Other websites and services

7.1 If you use a link to go from the Website to other websites, applications or platforms, this Privacy Policy does not apply to those websites, applications or platforms. They have their own privacy policies and you should familiarise yourself with them before you permit them to access and process your Information.

7.2 We are not responsible for and does not have control over any other third party websites, applications or platforms which you authorise to access or process your Information. If you are using a third party website, application or platform and you allow them to access or process your Information, you do so at your own risk.

8. Contacting us about your Information

8.1 If you have any questions, concerns or feedback regarding this Privacy Policy, you may contact our Data Protection Officer at:

  • Ivan Chen, support@sweelee.com.my

8.2 If you (i) wish to update or correct your Information, (ii) wish to request for information from us on what Information of yours we have and how we have used and shared your Information during the last one year before the date of your request, (iii) wish to restrict or withdraw your consent to our processing of your Information, or (iv) wish us to delete your Information, please contact our Data Protection Officer in writing via email at support@sweelee.com.my.

8.3. If you are a resident of the European Union using the Website, you have the following rights under the General Data Protection Regulations:

a) Right to be informed: This right means that when we ask you to provide us with your Information, we will give you details such as what we are using it for, how and with whom it will be shared, and how you may contact us if you have any queries;

b) Right to access: This right allows you to ask us for details of the Information we hold on you, e.g. what Information is being processed and for what reason, what Information is being transferred and to whom, what rights you have etc.;

c) Right to rectification: This right allows you to ask us to correct anything that you think is wrong with the Information we have about you;

d) Right to erasure also known as the "right to be forgotten": This right means you can ask us to delete your Information from our system;

e) Right to restrict processing: This right allows you to ask us to only process your Information for those certain purposes that you specify;

f) Right to data portability: This is the right to ask us to send you your Information electronically. You may also ask us to transmit such Information to another party;

g) Right to object: This is your right to tell us to stop processing your Information;

h) Right not to be subject to automatic decision-making, including profiling: We sometimes use computers to study and analyse Information. We might do this so we can understand how you, and other visitors, are using the Website. This allows us to improve the Website for better customer experience e.g. by providing personalised content and marketing to you. For situations that may significantly impact you, you have the right to ask us not to do this; and

i) Right to complain, right to judicial remedy: If you feel your rights are breached, these rights allow you to make a complaint to the relevant authorities or to sue us in court.

8.4. European Union residents may exercise their rights above by writing to our Data Protection Officer at support@sweelee.com.my. The parent or guardian of a User resident in the European Union under the age of 16 years old or applicable age of consent can request this on behalf of their child.

9. Changes to this Privacy Policy

We may, at our sole and absolute discretion, change or update portions of this Privacy Policy at any time and without prior notice to you. We will notify you when changes are made via the email address associated with your Account. We also recommend that you review this Privacy Policy from time to time so you are aware of any changes or updates. We will indicate the effective date of the changes or updates. Your continued use of the Website after any modification to this Privacy Policy constitutes your acceptance of such modification and your consent to our processing of Information in accordance with the modified Privacy Policy. If you do not wish to continue using the Website under the modified Privacy Policy, you should terminate your Account and stop using the Website.