Privacy Policy
Dear all,
Please read this privacy policy carefully. by clicking or checking “sign up”, “I hereby agree to
G Lucky’s privacy policy”, “I agree and consent to the collection, use, disclosure, storage,
transfer and/or processing of my personal data for the purpose stated in, and under the terms
of, G Lucky’s privacy policy” or similar statements available at the G Lucky registration page
or in the course of providing you with the services or access to the platform, you acknowledge
that you have read and understood the terms of this privacy policy and that you have agreed and
consented to the collection, use, disclosure, storage, transfer and/or processing of your
personal data as described and under the terms herein.
- Introduction to this Privacy Policy
- G Lucky Sdn Bhd (Registration No.: 202201039076 (1484773-V), a company
incorporated in Malaysia and having its registered address at Suite 2 No. 3A-B,
Jalan Desa Aman Puri, 52100 Kuala Lumpur, WP KL and its
affiliates (collectively or individually, "G Lucky", "we" or "us" take your privacy
seriously.
- In the course of providing you with the Services or access to the Platform (as
defined in the Terms of Use), we will be collecting, using, disclosing, storing
and/or processing data, including your personal data. In this Privacy Policy,
Platform shall also refer to the relevant seller platform(s).
- This Privacy Policy exists to keep you in the know about how we collect, use,
disclose, store and/or process the data we collect and receive during the course of
providing the Services or access to the Platform to you, our user, whether you are
using our Platform as a buyer or a seller. We will only collect, use, disclose,
store and/or process your personal data in accordance with this Privacy Policy.
- It is important that you read this Privacy Policy together with any other applicable
notices we may provide on specific occasions when we are collecting, using,
disclosing and/or processing personal data about you, so that you are fully aware of
how and why we are using your personal data.
- We may update this Privacy Policy from time to time. Any changes we make to this
Privacy Policy in the future will be reflected on this page and material changes
will be notified to you. Where permissible under local laws, your continued use of
the Services, access to the Platform or use of the Services, including placing
Orders (as defined in the Terms of Use) on the Platform, or express consent thereto,
shall constitute your acknowledgment and acceptance of the changes we make to this
Privacy Policy. You agree that it is your responsibility to check back frequently to
see any updates or changes to this Privacy Policy.
- This Privacy Policy applies in conjunction with other notices, contractual clauses
and consent clauses that apply in relation to the collection, storage, use,
disclosure and/or processing of your personal data by us and is not intended to
override them unless we state expressly otherwise.
- All of these terms apply to G Lucky's users, whether buyers or sellers, unless
stated specifically to apply only to buyers or only to sellers.
- The Personal Data We Collect From You
-
Personal data means any information about an individual, whether recorded in a
material form or not and whether true or not, who can be identified from that data
(whether directly or indirectly), or from that data and other data to which we have
or are likely to have access.
- During the course of your use of the Platform and the provision of the Services, we
may collect personal data about you, as follows:
- Where you are a buyer:
- Identity data, such as your name, gender, profile picture, and date
of birth;
- Contact data, such as billing address, delivery address, email
address and phone numbers;
- Biometric data, such as voice files when you use our voice search
function, and facial and other bodily features and voice of yourself
and/or another person featured in your video when you upload videos
onto the Platform;
- Account data, such as bank account details, bank statements, credit
card details and payment details (such account data may also be
collected directly by our affiliates and/or third party payment
service providers);
- Transaction data, such as details about orders and payments, and
other details of products and Services related to you;
- Technical data, such as Internet protocol (IP) address, your login
data, browser type and version, time zone setting and location,
browser plug-in types and versions, operating system and platform,
international mobile equipment identity, device identifier, IMEI,
MAC address, cookies (where applicable) and other information and
technology on the devices you use to access the Platform;
- Profile data, such as your username and password, orders related to
you, your interests, preferences, feedback and survey responses;
- Usage data, such as information on how you use the Platform,
products and Services or view any content on the Platform, including
the time spent on the Platform, items and data searched for on the
Platform, access times and dates, as well as websites you were
visiting before you came to the Platform and other similar
statistics;
- Location data, such as when you capture and share your location with
us in the form of photographs or videos and upload such content to
the Platform;
- Marketing and communications data, such as your preferences in
receiving marketing from us and our third parties, your
communication preferences and your chat, email or call history on
the Platform or with third party customer service providers; and
- Additional information we may request you to submit for due
diligence checks as required for identity verification (such as
copies of government issued identification, e.g. passport, ID cards,
etc.) or if we believe you are violating our Privacy Policy or our
Terms of Use.
- Where you are a seller:
- Identity and contact data, such as your name, date of birth or
incorporation, company name, address, email address, phone number
and other business-related information (e.g. company registration
number, business licence, tax information, shareholder and director
information, etc.);
- Account data, such as bank account details, bank statements, credit
card details and payment details (such account data may also be
collected directly by our affiliates and/or third party payment
service providers);
- Transaction data, such as details about orders and payments, and
other details of products and Services related to you;
- Technical data, such as Internet protocol (IP) address, your login
data, browser type and version, time zone setting and location,
browser plug-in types and versions, operating system and platform,
international mobile equipment identity, device identifier, IMEI,
MAC address, cookies (where applicable) and other information and
technology on the devices you use to access the Platform;
- Profile data, such as your username and password, orders related to
you, your interests, preferences, feedback and survey responses;
- Usage data, such as information on how you use the Platform,
products and Services or view any content on the Platform, including
the time spent on the Platform, items and data searched for on the
Platform, access times and dates, as well as websites you were
visiting before you came to the Platform and other similar
statistics;
- Location data, such as when you capture and share your location with
us in the form of photographs or videos and upload such content to
the Platform;
- Marketing and communications data, such as your preferences in
receiving marketing from us and our third parties and your
communication preferences and your chat, email or call history on
the Platform or with our third party seller service providers; and
- Additional information we may request you to submit for
authentication (such as copies of government issued identification,
e.g. passport, ID cards, etc.) or if we believe you are violating
our Privacy Policy or our Terms of Use.
- How we receive your personal data
- During the course of your use of the Platform and our provision of
the Services, we may receive personal data from you in the
situations, as follows:
- When you browse our website (both mobile and web
versions);
- When you create an account with us (as buyer or seller);
- When, as a seller, you list products and/or services for
sale on the Platform and conduct transactions with buyers in
respect of the sale and purchase of those products and/or
services through the Platform;
- When you apply for, subscribe to or otherwise use any of the
Services;
- When you make a transaction regarding the products available
on the Platform;
- When you activate or use any payment-related functions
available on the Platform or provided by our third party
service providers;
- When you use any of the features, functions, mini-apps or
mobile games available on the Platform or Services;
- When you record any user-generated content which is uploaded
on the Platform;
- When you use the chat function on the Platform;
- When you use the chat function on the Platform;
- When you enter a competition, promotion or survey;
- When you participate in any activity or campaign on the
Platform;
- When you log in to your account on the Platform or otherwise
interact with us via an external service or application,
such as Facebook or Google;
- When any other user of the Platform posts any comments on
the content you have uploaded on the Platform or when you
post any comments on other users’ content uploaded to the
Platform;
- When a third party lodges a complaint against you or the
content you have posted on the Platform; and
- When you interact with us offline, including when you
interact with our outsourced customer service agents.
- We may collect personal data from you, third parties (including but
not limited to agents, vendors, contractors, partners and any others
who provide services to us, who collect your personal information
and/or perform functions on our behalf, or with whom we collaborate,
including but not limited to payment service providers, government
sources of data, financial providers, credit bureaus, delivery,
marketing and other service partners), our affiliates, or such data
may be collected automatically when you use the Platform or the
Services, as set out in this section. See also section 10 below on
the collection of computer data.
- Where we collect personal data from third parties and/or our
affiliates, we will only collect your personal data, where permitted
by law, for or in connection with the purposes for which those third
parties or our affiliates are engaged, for the purposes of our
collaboration with the third parties or affiliates, or for the
requirement to carry out verification or due diligence checks.
During the course of your use of the Platform and our provision of
the Services, you agree that you have provided your consent (whether
to us, the third party or our affiliates) to the transfer of your
personal data from third parties and/or our affiliates to Affianze
for the purposes set out in this Privacy Policy or any other terms.
- You must only submit personal data which is accurate and not
misleading and you must keep it up to date and inform us of any
changes to the personal data you have provided to us. We shall have
the right to request for documentation and carry out the necessary
checks to verify the personal data provided by you as part of our
user verification processes or as required under law.
- We will only be able to collect certain categories of personal data
if you voluntarily provide the personal data to us or as otherwise
provided for under this Privacy Policy. If you choose not to provide
your personal data to us or subsequently withdraw your consent to
our use of your personal data, we may not
- We will only be able to collect certain categories of personal data
if you voluntarily provide the personal data to us or as otherwise
provided for under this Privacy Policy. If you choose not to provide
your personal data to us or subsequently withdraw your consent to
our use of your personal data, we may not be able to provide you
with certain features or functionality on the Services or access to
the Platform.
- If you provide personal data of any third party to us, you represent
and warrant that you have obtained the necessary consent, license
and permissions from that third party to share and transfer his/her
personal data to us, and for us to collect, store, use and disclose
that data in accordance with this Privacy Policy.
- If you sign up to be a user on our Platform using your social media
account or link your G Lucky account to your social media account
or use certain other G Lucky social media features, we may access
personal data about you which you have voluntarily provided to your
social media provider in accordance with the provider's policies and
we will manage your personal data in accordance with this Privacy
Policy.
- Use and Disclosure of Your Personal Data
Purpose of Use
- The personal data we collect from you or via third
parties may be
used for certain purposes, as follows:
- Where you are a buyer:
- Processing your order for products (whether sold by us or a
third party seller)
- To process orders you submit through the Platform;
- To deliver the products you have purchased through
the Platform. We may pass your personal information
on to a third party (e.g. our logistics partner) or
relevant regulatory authority (e.g. customs) in
order to make delivery of the product to you;
- To update you on the delivery of the products;
- To provide customer support for your orders; and
- To verify and carry out payment transactions
(including any credit card payments, bank transfers,
offline payments, remittances, or e-wallet
transactions) in relation to payments related to you
and/or Services used by you. In order to verify and
carry out such payment transactions, payment
information, which may include personal data, will
be transferred to third parties such as our payment
service providers.
- Providing Services
- To facilitate your use of the Services or access to the
Platform;
- To administer your account (if any) with us;
- To display your name, username or profile on the Platform
(including on any reviews you may post);
- To facilitate the use of the mini-apps available on the
Platform and purchases made via these mini-apps;
- To respond to your queries, feedback, claims or disputes,
whether directly or through our third party service
providers;
- To display on scoreboards on the Platform in relation to
campaigns, mobile games or any other activity;
- To allow other users to identify you (via the "Find my
friends" or any other similar function) as a user of the
Service, to allow you to find other users and to connect
with them on the Platform, and to support the socialising
function of the Services (where applicable);
- To assess your application for loan facilities and/or to
perform credit risk assessments in relation to application
for financing services (where applicable); and
- To facilitate the integration of third party’s loyalty
membership programmes (including those supported by sellers
or brands) with our Platform.
- Marketing and advertising
- To provide you with information we think you may find useful
or which you have requested from us (provided you have opted
to receive such information);
- To send you marketing or promotional information about our
or third-party sellers’ products and services on our
Platform from time to time (provided you have opted to
receive such information);
- To help us conduct marketing and advertising; and
- To promote the Services and use information that you give to
us, such as user-generated content (including video content)
that you can choose to upload or broadcast on our Platform
and will be accessible on the Internet and may be shared by
the public (the latter of which is not within our control),
as part of our advertising and marketing campaigns to
promote the Platform.
- Legal and operational purposes
- To ascertain your identity in connection with fraud
detection purposes;
- To compare information, and verify with third parties in
order to ensure that the information is accurate;
- To process any complaints, feedback, enforcement action and
take-down requests in relation to any content you have
uploaded to the Platform;
- To produce statistics and research for internal and
statutory reporting and/or record-keeping requirements;
- To store, host, back up your personal data;
- To prevent or investigate any actual or suspected violations
of our Terms of Use, Privacy Policy, fraud, unlawful
activity, omission or misconduct, whether relating to your
use of our Services or any other matter arising from your
relationship with us;
- To perform due diligence checks;
- To comply with legal and regulatory requirements (including,
where applicable, the display of your name, contact details
and company details), including any law enforcement
requests, in connection with any legal proceedings, or
otherwise deemed necessary by us; and
- Where necessary to prevent a threat to life, health or
safety.
- Analytics, research, business and development
- To understand your user experience with the Services and the
Platform;
- To improve the layout or content of the pages of the
Platform and customise them for users;
- To identify visitors on the Platform;
- To conduct surveys, including carrying out research on our
users’ demographics and behaviour;
- To improve our current technology (e.g. voice recognition
tech, etc) via machine learning or other means;
- To derive further attributes relating to you based on
personal data provided by you (whether to us or third
parties), in order to provide you with more targeted and/or
relevant information;
- To conduct data analysis, testing and research, monitoring
and analysing usage and activity trends;
- To further develop our products and services; and
- To know our buyers better.
- Other
- Any other purpose to which your consent has been obtained;
and
- To conduct automated decision-making processes in accordance
with any of the above purposes.
- Where you are a seller:
- Providing Services
- To facilitate your use of the Services or access to the
Platform;
- To ship or deliver the products you have listed or sold
through the Platform. We may pass your personal information
on to a third party (e.g. our logistics partners) or
relevant regulatory authority (e.g. customs) in order to
carry out shipping or delivery of the products listed or
sold by you;
- To respond to your queries, feedback, claims or disputes,
whether directly or through our third party service agents;
- To verify your documentation submitted to us facilitate your
onboarding with us as a seller on the Platform, including
the testing of technologies to enable faster and more
efficient onboarding;
- To administer your account (if any) with us;
- To display your name, username or profile on the Platform;
- To verify and carry out financial transactions (including
any credit card payments, bank transfers, offline payments,
remittances, or e-wallet transactions) in relation to
payments related to you and/or Services used by you. In
order to verify and carry out such payment transactions,
payment information, which may include personal data, will
be transferred to third parties such as our payment service
providers;
- To assess your application for loan facilities and/or to
perform credit risk assessments in relation to your
application for seller financing (where applicable);
- To provide you with ancillary logistics services to protect
against risks of failed deliveries or customer returns; and
- To facilitate the return of products to you (which may be
through our logistics partner).
- Marketing and advertising
- To send you marketing or promotional materials about our or
third-party sellers’ products and services on our Platform
from time to time (provided you have opted to receive such
information); and
- To help us conduct marketing and advertising.
- Legal and operational purposes
- To produce statistics and research for internal and
statutory reporting and/or record-keeping requirements;
- To store, host, back up your personal data;
- To prevent or investigate any actual or suspected violations
of our Terms of Use, Privacy Policy, fraud, unlawful
activity, omission or misconduct, whether relating to your
use of our Services or any other matter arising from your
relationship with us;
- To comply with legal and regulatory requirements (including,
where applicable, the display of your name, contact details
and company details), including any law enforcement
requests, in connection with any legal proceedings or
otherwise deemed necessary by us;
- Where necessary to prevent a threat to life, health or
safety;
- To process any complaints, feedback, enforcement action and
take-down requests in relation to any content you have
uploaded to the Platform;
- To compare information, and verify with third parties in
order to ensure that the information is accurate;
- To ascertain your identity in connection with fraud
detection purposes; and
- To facilitate the takedown of prohibited and controlled
items from our Platform.
- Analytics, research, business and development
- To audit the downloading of data from the Platform;
- To understand the user experience with the Services and the
Platform;
- To improve the layout or content of the pages of the
Platform and customise them for users;
- To conduct surveys, including carrying out research on our
users’ demographics and behaviour to improve our current
technology (e.g. voice recognition tech, etc) via machine
learning or other means;
- To derive further attributes relating to you based on
personal data provided by you (whether to us or third
parties), in order to provide you with more targeted and/or
relevant information;
- To conduct data analysis, testing and research, monitoring
and analysing usage and activity trends;
- To further develop our products and services; and
- To know our sellers better.
- Other
-
Any other purpose to which your consent has been obtained;
and
- To conduct automated decision-making processes in accordance
with any of these purposes.
- Who we disclose your personal data to
- We may share (or permit the sharing of) your personal data with and/or
transfer your personal data to third parties and/or our affiliates for the
above-mentioned purposes. These third parties and affiliates, which may be
located inside or outside your jurisdiction, include but are not limited to:
- Service providers (such as agents, vendors, contractors and
partners) in areas such as payment services, logistics and shipping,
marketing, data analytics, market or consumer research, survey,
social media, customer service, installation services, information
technology and website hosting;
- Their service providers and related companies; and
- Other users of the Platform or Services.
- In disclosing your personal data to them, we endeavour to ensure that the
third parties and our affiliates keep your personal data secure from
unauthorised access, collection, use, disclosure, processing or similar
risks and retain your personal data only for as long as your personal data
is needed to achieve the above-mentioned purposes.
- We may also share personal data in connection with any proposed purchase,
merger or acquisition of any part of our business, provided that we satisfy
the requirements of applicable data protection law when disclosing your
personal data.
- International data transfer
-
We may transfer or permit the transfer of your personal data outside
of your jurisdiction for any of the purposes set out in this Privacy
Policy. However, we will not transfer or permit any of your personal
data to be transferred outside of such jurisdiction unless the
transfer is in compliance with applicable laws.
- Third party services
- We may share your personal data with our third party service
providers or affiliates (e.g. payment service providers) in order
for them to offer services to you other than those related to your
use of the Platform or our Services. Your acceptance and use of the
third party service provider’s or our affiliate’s services shall be
subject to terms and conditions as may be agreed between you and the
third party service provider or our affiliate. Upon your acceptance
of the third party service provider’s or our affiliate’s service
offering, the collection, use, disclosure, storage, transfer and
processing of your data (including your personal data and any data
disclosed by us to such third party service provider or affiliate)
shall be subject to the applicable privacy policy of the third party
service provider or our affiliate, which shall be the data
controller of such data. You agree that any queries or complaints
relating to your acceptance or use of the third party service
provider’s or our affiliate’s services shall be directed to the
party named in the applicable privacy policy.
- Withdrawal of Consent to Continued Use, Disclosure, Storing and/or Processing of Personal
Data
- You may communicate the withdrawal of your consent to the continued use, disclosure,
storing and/or processing of your personal data by contacting us using the contact
details below, subject to the conditions and/or limitations imposed by applicable
laws or regulations.
- Please note that if you communicate your withdrawal of your consent to our use,
disclosure, storing or processing of your personal data for the purposes and in the
manner as stated above or exercise your other rights as available under applicable
local laws, we may not be in a position to continue to provide the Services to you
or perform any contract we have with you, and we will not be liable in the event
that we do not continue to provide the Services to, or perform our contract with
you. Our legal rights and remedies are expressly reserved in such an event.
- Marketing information
- You may unsubscribe from receiving marketing information at any time in our
mobile application settings or by using the unsubscribe function within the
electronic marketing material. We may use your contact information to send
newsletters from us and from our related companies.
- Updating Your Personal Data
- It is important that the personal data you provide to us is accurate and complete
for you to continue using the Platform and for us to provide the Services. You are
responsible for informing us of changes to your personal data, or in the event you
believe that the personal data we have about you is inaccurate, incomplete,
misleading or out of date.
- You can update your personal data anytime by accessing your account on the Platform.
- We take steps to share the updates to your personal data with third parties and our
affiliates with whom we have shared your personal data if your personal data is
still necessary for the above-stated purposes.
- Accessing and Correcting Your Personal Data
- You may request information about your personal data which we have collected, or
enquire about the ways in which your personal data may have been used, disclosed,
stored or processed by us via the personal account information setting on our
Platform or by contacting us using the contact details below. You may also request
correction of any error or omission in your personal data which we have collected in
the same way. In order to facilitate processing of your request, it may be necessary
for us to request further information relating to your request. Where permissible
under law, we may refuse such correction requests if deemed vexatious or
unreasonable.
- Where permitted by applicable data protection laws, we reserve the right to charge a
reasonable administrative fee for retrieving your personal data records. If so, we
will inform you of the fee before processing your request.
- Security of Your Personal Data
- To safeguard your personal data from unauthorised access, collection, use,
disclosure, processing, copying, modification, disposal, loss, misuse, modification
or similar risks, we have introduced appropriate administrative, physical and
technical measures such as:
- Restricting access to personal data to individuals who require access;
- Maintaining technology products to prevent unauthorised computer access;
- Using 128-bit SSL (secure sockets layer) encryption technology when
processing your financial details; and/or
- implementing other security measures as required by applicable law.
- You should be aware, however, that no method of transmission over the Internet or
method of electronic storage is completely secure. While security cannot be
guaranteed, we strive to protect the security of your information and are constantly
reviewing and enhancing our information security measures.
- Retention of Personal Data
- We will only retain your personal data for as long as we are either required or
permitted to by law or as relevant for the purposes for which it was collected.
- We will cease to retain your personal data, or remove the means by which the data
can be associated with you, as soon as it is reasonable to assume that such
retention no longer serves the purposes for which the personal data was collected,
and is no longer necessary for any legal or business purpose.
- Minors
- G Lucky does not sell products to minors (which is to be determined based on the
applicable law), nor does it intend to provide any of the Services or the use of the
Platform to minors. We do not knowingly collect any personal data relating to
minors.
- You hereby confirm and warrant that you are above the age of minority and you are
capable of understanding and accepting the terms of this Privacy Policy. If you are
a minor, you may use our Platform only with the involvement of a parent or legal
guardian.
- As a parent or legal guardian, please do not allow minors under your care to submit
personal data to Affianze. In the event that such personal data of a minor is
disclosed to Affianze, you hereby consent to the processing of the minor’s personal
data and accept and agree to be bound by this Privacy Policy and take responsibility
for his or her actions.
- We will not be responsible for any unauthorised use of the Services on the Platform
by yourself, users who act on your behalf or any unauthorised users. It is your
responsibility to make your own informed decisions about the use of the Services on
the Platform and take necessary steps to prevent any misuse of the Services on the
Platform.
- Collection of Computer Data
- We or our authorised service providers may use cookies, web beacons, and other
similar technologies in connection with your use of the Services or access of the
Platform.
- When you visit the Platform through your computer, mobile device, or any other
device with Internet connectivity, our company servers will automatically record
data that your browser sends whenever you visit a website, such as the technical
data and usage data outlined in Section 2 above.
- This data is collected for analysis and evaluation in order to help us improve our
website and the services and products we provide, as well as to help us to
personalise the content to match your preferred interests more quickly. The data is
also collected to make the Services and the Platform more convenient and useful to
you, and to provide more relevant advertising related to market products, services
and features to you.
- Cookies are small text files (typically made up of letters and numbers) placed in
the memory of your browser or device when you visit a website or view a message.
They allow us to recognise a particular device or browser. Web beacons are small
graphic images that may be included on our Services and the Platform. They allow us
to count users who have viewed these pages so that we can better understand your
preference and interests.
- You may be able to manage and delete cookies through your browser or device
settings. However, certain cookies are required to enable core functionality (such
as adding items to your shopping basket), so please note that changing and deleting
cookies may affect the functionality available on the Platform or through our
Services.
- Third Party Sites
- The Platform may contain links to other websites operated by other parties, such as
our business affiliates, merchants or payment gateways. We are not responsible for
the privacy practices of websites operated by these other parties. You are advised
to check on the applicable privacy policies of those websites to determine how they
will handle any information they collect from you.
- Questions, Feedback, Concerns, Suggestions or Complaints
- If you have any questions on personal data protection or data privacy, please refer
to our list of frequently asked questions on data protection / privacy.
- If your queries are not covered in our FAQs, or if you have any queries or
complaints about this Privacy Policy or how we handle your personal data, please
feel free to contact us via our online chat service or as follows:
