Privacy

Introduction

Welcome to https://www.alcealibrary.com and Alcea Digital’s (‘Alcea’) privacy notice.

You acknowledge that this privacy notice is in addition to and subject to Alcea’s website Terms and Conditions along with all other terms and conditions and policies issued hereunder (collectively, “Alcea Digital Terms and Conditions”). You must carefully read, accept and acknowledge the Alcea Digital Terms and Conditions.

Alcea respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. DEACTIVATED OR TERMINATED ACCOUNTS

11. OPTING OUT

10. GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Alcea collects and processes your personal data through your use of this website, including any data you may provide through this website when you send us a message through an email you can find on the website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Alcea (referred to as "we", "us" or "our" in this privacy notice) is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Alcea Digital Sdn Bhd.

For the attention of the Data Privacy Manager

Name: Yusseri bin Md Yusoff

Email address: yusseri@alceadigital.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version of the privacy notice was published on 17/3/2021.It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together without limitation as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes email addresses and other contact information if you provide it.
Financial Data includes financial information you may provide.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your interests, preferences, feedback and responses to our requests for further information.
Usage Data includes information about how you use our website and services.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cease to deal with you, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by the Contact Form, post, phone, email or otherwise. This includes personal data you provide when you:
send us a message and other information using the Contact Form;
request information about us to be sent to you; or
give us some feedback or otherwise communicate with us using our contact email address.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:

analytics providers such as Google based inside or outside the EU; and
search information providers such as Google, Firefox and Safari based inside or outside the EU.

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform a contract or a transaction we may enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Please refer to the table below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Communications | (a) Performance of a contract or transactions with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated)
| To enable you to register as a user or subscribe to our website | (a) Identity (b) Contact (c) Profile (d) Password creation (e) Communications | (a) Performance of a contract or transactions with you (b) Necessary for our legitimate interests
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
| To deliver relevant website content to you and measure or understand the effectiveness of the information we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Communications (f) Technical | Necessary for our legitimate interests (to study how our website is used and to grow our business and to inform our business strategy)
| To use data analytics to improve our website and user relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of users of our website, to keep our website updated and relevant, to develop our business and to inform our business strategy)
| For marketing purposes | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop and grow our business)

Cookies and our Cookie policy

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Cookie technology can provide you with tailored information while visiting a Web site. Cookies are data elements that a Web site can send to your browser and are stored on your system. Some Web site pages use cookies to better serve you when you return to our Site. The Site cookie sent to your address contains what country location you have selected and if you have selected on-line settings for visiting the Site. The Site does not store individual names, email addresses, street addresses, credit card numbers, or phone numbers in cookies placed on your computer. However, the Site does collect non-identifiable information from visits to our Site to help us provide better customer service. For example, we track the domains people visit on the Site and we measure visitor activity on the Site, but we do so in ways that keep personal information non-identifiable. Alcea uses this data to analyse trends and statistics and to help us provide better customer service.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

During a new registration you would have the choice to opt out of having individual identifying information provided in the registration process used for any purpose unrelated to the purpose set forth in paragraph 4 above.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
You should be aware that our service may from time to time contain links to third-party sites, products or services. We are not responsible for the privacy practices or the content of such sites or services. If you are concerned about the privacy policy of a certain third party, you should read the privacy policy of the site or service to which you link before you submit any personal information.
We may also use Google remarketing services, which allow third parties, including Google, to serve advertisements to you on our behalf based on your activity on our Service. This involves placing in certain areas of our service a small piece of code provided by Google. This code enables third parties, including Google, to place a cookie on your computer that tells them about your use of our service and allows them to recognize you and display relevant advertisements when you visit other websites within the Google Display Network. We may also use similar remarketing services from other companies. If you would like to opt-out of Google Analytics collecting data from your browser when you visit websites, you can download and install the Google Analytics Opt-out Browser Add-on here: https://tools.google.com/dlpage/gaoptout/

6. International transfers

We share your personal data within the Alcea Digital Sdn Bhd (Company Number: 1334968-V) (ALCEA Group). This will involve transferring your data outside the European Economic Area (EEA).

Whenever we transfer your personal data out of the EEA, including to any member of ALCEA Group situated outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
We may use specific contract terms approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US with whom we do not use specific contract terms approved by the European Commission, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, auditing, compliance, data retention policy or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about companies in which we invest (including Contact, Identity, Financial and Transaction Data) for six years after we cease being shareholders or lenders for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

[Request access to your personal data].
[Request correction of your personal data].
[Request erasure of your personal data].
[Object to processing of your personal data].
[Request restriction of processing your personal data].
[Request transfer of your personal data].
[Right to withdraw consent].

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Deactivated or Terminated Accounts

A request to delete and/or terminate your account will not result in the removal of information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed without undue burden to us. We are not able nor are we obligated to remove any of your information from a third-party provider or platform. Moreover, please be aware that even after you delete your account or your account is terminated, your information may not be deleted in its entirety from our servers and servers of the third party with whom such information have been shared.

11. Opting Out

If at any time you wish to opt out of receiving information from us (via e-mail or postal mail) about new products, services, or promotions, you can do so by adjusting your account settings or contacting us.

12. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best response and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or a company you represent are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the ALCEA Group which are based in Malaysia which provide IT, system and administration services and undertake leadership reporting.

External Third Parties

Service providers acting as processors based in Malaysia States who provide payment and data storage services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in Malaysia who provide consultancy, banking, legal, insurance and accounting services.
Any third-party sites, products or services for the purpose of promotion of the sites or for the purpose of advertisement to be published by the site.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you or a company you represent.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to interact with you. We will advise you if this is the case at the time you withdraw your consent.