1. TYPES OF PERSONAL DATA WE COLLECT
1.1 Information you provide to us: we collect personal data (including where applicable sensitive personal data) you provide directly to us and/or via our suppliers or business associates and affiliates. This includes:
- Your and/or family’s full name, National Registration Identity Card (NRIC) number (or the equivalent in any other country outside Malaysia), passport and visa information, nationality, gender;
- Your date of birth;
- Your and/or family’s contact information, including address, email address and telephone number;
- Your membership information, account details, profile or password details and profile photo;
- Any information necessary to fulfill special requests based on the use of our services (for example, for travel and accommodation arrangements, and related particular preferences);
- Your reviews, feedback and opinions about our programs and services;
- Videos, audio files or pictures of your trip you upload to the Site; and
- Any other personal data you choose to provide to us.
1.2 Information We Collect Automatically When You Use the Site and/or our Services: when you access or use the Site or our Services, we automatically collect personal data about you, including:
- Information collected through our services, including photos and videos of you from excursions and travels;
- Information collected when you voluntarily complete a customer survey or provide feedback, or when you email us;
- Information collected when you view or use our website via your browser’s cookies;
- Information obtained from third parties through lawful sources including but not limited to the National Registration Department of Malaysia;
- Log Information: we may collect system log information about your use of the Site, including the type of browser you use, access times, pages viewed, your IP address;
- Device Information: we may collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers (such as, IP address, IMEI number, the address of the device’s wireless network interface, or mobile phone number used by the device) and mobile network information;
- Location Information: we may collect information about the location of your device each time you access or use one of our mobile applications or otherwise consent to the collection of this information. You can turn off location services for a device at any time, but this may turn off some useful features. Failure to turn off location services will be rendered as consent for us to collect your location information during your visit to our mobile applications and/or other devices with similar features;
- Information Collected by Cookies and Other Tracking Technologies: we and our service providers use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular and count visits. Web beacons are electronic images that may be used in our services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see our Cookies Policy.
- Facebook Page Information. For example, the list of pages you manage on Facebook and information from those pages granted when you authorize our Facebook application.
- If you or any Connected Persons would like to request for your Facebook Login to be removed from our database, please contact us at email@example.com.
1.4 Data PseudonymizationWe will process your personal data in such a manner that the personal data can no longer be attributed to a specific data subject or to an identified or identifiable natural person by encrypting the data into an ID number, which is only known to the data controller in our system.
We use different types of cookies. In particular, we use the following first party cookies:
- Necessary cookies which allow certain fundamental features of the Site to work. These cookies are essential to enable you to browse our services and use certain features. Disabling them may prevent you from using certain parts of the services. Without these cookies, services like login, booking and paying activity cannot be provided. These cookies also help keep our services safe and secure;
- Functional cookies, which allow us to remember choices you make (e.g. your cookie preference), we use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in;
- Performance cookies, which monitor usage of the Site; and
- Advertising cookies which record the fact that you have visited the Site and then which links you have accessed whilst you use the Site.
- Facebook Analytics, Advertising, & Social Features. We use Facebook technologies to customize content and advertising, to provide social media features, and to analyze traffic to our website.
- You can choose to remove or disable cookies in your browser settings and you may use browser extensions with our site that limit the ability to set third certain types of cookies including those from Google and Facebook.
3. HOW WE USE YOUR PERSONAL DATA
3.1 We may use your personal data for the purposes set out below:
- We use your Personal Information for administrative purposes e.g. processing, confirming, organizing, fulfilling and completing your transactions and requests for our services, and ancillary works in providing the products and/or services (whether by BeED, it’s related or affiliated entities, merchants, partners or third parties and responding to enquiries by you or made on its behalf);
- Fulfill contractual obligations to you, anyone involved in the process of organizing your travel arrangements (e.g. travel agents, group travel organisers, airline operators, hotels, transportation providers, schools and your employer) and vendors (e.g. credit card companies,etc);
- Provide you with access to the content on our Site, and respond to your enquiries and requests for information and services;
- Verifying and assisting with identification of users and to determine appropriate services;
- Sending important notices such as communications about changes to our policies, terms and conditions, and your purchases;
- Monitor your use of our Site and your bookings, and conduct analysis of the use of our Site in order to operate, evaluate and improve our Site and our services, understand your preferences, display customised content to you on our Site which may be of interest to you and troubleshoot any problems;
- Forwarding publicity materials or other information to you from BeED or sending promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided;
- Meeting any legal, governmental or regulatory requirements in Malaysia or any other applicable jurisdiction including disclosure or notification requirements;
- Liaising with any person who is acquiring or participating in any contractual arrangements between BeED and you, to enable the transaction;
- And any other incidental and associated purposes in order for BeED to carry out its business and/or relating to any of the above.
3.2 Data held relating to you will be kept confidential but it may be shared with:
- Any person under a duty of confidentiality to BeED or to entities related to or affiliated to BeED;
- Any relevant agent, contractor, business associate or affiliate, agent, joint venture partner or associate or third party service provider, including who provides administrative, telecommunications, computer, payment, securities clearing, management, audit, insurance, professional or other services to BeED;
- With third-party payment processors, payment service providers, IT and marketing support service providers and other consultants, vendors and service providers who need access to such information to carry out work or provide services on our behalf or who help us to provide the Site to you;
- Anyone involved in the process of the organizing of your travel arrangements (for example, for travel and accommodation arrangements, and related services (e.g. travel agents, group travel organisers, airline operators, hotels, transportation providers, schools and your employer) and vendors (e.g. credit card companies, etc);
- Any person or corporation to whom BeED transfers or proposes to transfer its interests and/or obligations in respect of you or any product or service provided to you;
- Any nominee, trustee, co-trustee, centralised securities depository or registrar, custodian, insurance company, estate agent, lawyer, tax advisor, auditor, other professional advisor or other person who is involved with the provision of services or products by BeED to you;
- Any person by whom BeED is required by applicable legal, governmental or regulatory requirements to make disclosure;
- Or any other person reasonably requiring the same in order for BeED to carry out its business.
We will jointly use Personal Information as well as cookies for the purposes as described above:
- With any law enforcement, courts, Government or regulatory bodies (in whatever jurisdiction), or otherwise in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, court order or legal process;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company, or any change of management;
- With our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- With any other party at your consent or at your direction; and
- Otherwise as permitted or required by applicable laws and regulations.
We may also disclose aggregate or de-identified data that is not personally identifiable with third parties, including our commercial and strategic partners.
3.3 Besides the parties and entities listed above, we may also share your data with the following entities related to or affiliated with BeED, for operational and administrative purposes;
3.3.1 SchoolOS.eu OÜ (Company Reg No: 14295950) 3.3.2 ACD Development Sdn. Bhd. (Company Reg No: 1160879-K) 3.3.4 eGHL (GHL ePayments Sdn. Bhd.) (Company Reg. No. 1040427-M) 3.3.5 Paypal Malaysia Services Sdn. Bhd. (Company Reg. No. 0901292-X) 3.3.6 Shopify Inc. (Company Reg. No. 5337842) 3.3.7 Tripsmart Consultants Private Limited (Company Reg. No. 003722)
3.4 We do not sell or rent any of your Personal Information on our Website to any other parties. We may share anonymous and/or aggregated information about all our users with third parties.
4. DATA STORAGE
Our Company would like to send you information about products and services of ours that we think you might like, via the entities listed above in Clause 3.3 which are related to or affiliated to BeED. If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop Our Company from contacting you for marketing purposes or giving your data to other members of the Our Company Group. If you no longer wish to be contacted for marketing purposes, please contact our Data Protection Officer at firstname.lastname@example.org to inform us of the same.
4.2 Retention of Personal Data
4.3 Children and Minors
Minors* under 18 years of age for other countries (except European Union where Minor age is below 16 years of age): [Note: * Age of minors for residents in Japan is under 20 years old]. Except where required by local laws, we do not knowingly collect personal data from minors. If you are a minor, you may only use our Site and services with the permission of your parent or guardian. If you are a parent or guardian of someone under 16 years old who has provided us his/her Personal Information without your knowledge and consent, you may request that we remove such information by contacting us at email@example.com. If you are in the EU, our online services are not directed towards children under the age of 13. If you believe we have collected information about a child under the age of 13, please contact us so that we may take appropriate steps to delete such information. If you are at least 13 but under the age of 16, please get the consent of your parent or legal guardian before giving us any personal data about yourself.
We and our partners will strive to secure the storage of your personal Data in compliance with the minimum security measures prescribed the Personal Data Protection Act 2010 of Malaysia, the General Data Protection Regulation (EU) 2016/679, Children’s Online Privacy Protection Act 1998 and all corresponding standards and regulations related thereof.
BeED is committed to ensuring that your data is secure. BeED maintains appropriate administrative, physical and technical safeguards to help protect the security, confidentiality and integrity of data our customers submit to us to prevent loss, unauthorised access, modification or disclosure. We use a multi-layered approach to protect that key information, constantly monitoring and improving our application, systems and processes to meet the growing demands and challenges of security.
BeED’s IT vendors generally do not have a direct relationship with individuals whose personal data is collected and our IT vendors do not collect personal information on our behalf. Our IT vendors do not determine how we use such data. Additionally, BeED’s contracts with our IT vendors generally prohibit our vendors from accessing customer data except under limited circumstances.
6. LINKS TO OTHER WEBSITES
7. EMAIL AND WEBSITE
Any Personal Data contained in the emails and “Contact Us” messages sent via BeED’s Website to BeED shall be used and processed in the manner set out in this Notice.
If you do not wish your Personal Data to be collected via cookies on the Website, please configure your internet browser to delete or deactivate cookies.
BeED’s Website may contain links to other sites and pages. BeED shall not be responsible for any Personal Data or information that you may provide to any other entity via the links.
8. REQUEST FOR ACCESS AND INQUIRIES
You may at any time exercise any of these rights, or if you have any questions or complaints about how we handle your personal data, forward the complaints, request for access to, or request for rectification or correction of your Personal Data or limit the processing of your Personal Data by BeED, as the case may be, however subject to the exceptions and restrictions as may be contained under the applicable laws, rules and regulations as follows: i) Personal Data Protection Act 2010 (Act 709); ii) The General Data Protection Regulation 2016/679; iii) Children’s Online Privacy Protection Act 1998;If you wish to do so, please contact: The Data Protection Officer at firstname.lastname@example.org, or by writing to: “The Data Protection Officer at Beeducation Adventures Sdn. Bhd., D-06-03 & D-06-3A, Sky Park @ One City, Jalan USJ 25/1, 47650 Subang Jaya, Selangor, Malaysia”.
Please note that BeED has the right to refuse your request to access and/or make any correction to your Personal Data, but only to the extent permitted under the applicable laws, rules and regulations. To help BeED to better serve you, please ensure that your personal data such as contact details including your home and office addresses, your telephone numbers (including your mobile telephone number), email address and other details registered with us are correct and up to date.
BeED reserves the right to amend or modify this Notice from time to time.
Updated effective from 26th March 2020.