Snowball Capital Partners Sdn Bhd, under the business name of PENANG360 (“PENANG360”), respects and is committed to protecting your personal information and privacy. In this Privacy Policy, “we,” “us,” and “our” refer to PENANG360, its agents and partners, and “you” and “your” includes third parties whose personal data you have provided to PENANG360.

Our Privacy Policy describes how and what data we collect from you and how and why we use your data via penang360.my, e-newsletter, digital advertising, applications, or social media platforms, collectively referred to here as our Website(s) by the Malaysian Personal Data Protection Act 2010. The agents are back-end providers of services that support our Websites, analytics providers, and the various services that we offer. This policy also describes choices we provide for you to access, update or otherwise take control of the personal data that we process. We collect, process, and analyze the data to provide you with the services available via our Websites and to provide other information or services, including valuable information, offers, and services to travelers, meeting planners, the travel trade, or those interested in travel to Penang and in related travel, event, leisure, cultural, accommodation, and entertainment or services available through our partners. Please note that we may amend this Privacy Policy at any time without prior notice and will publish the amended or revised Privacy Policy on our website.

If you have questions about this policy, our data use, or any of your rights, you may contact our Compliance Officer and our dedicated team at privacy@penang360.my. This inbox is actively monitored and managed so that we can deliver an experience that you can confidently trust.

1 Personal information

1.1) Type of information

Information that we collect includes information that you may give us by using our Website(s), filling out forms on our Website(s); corresponding with us by phone, email, online, or otherwise; downloading an application, or registering on one of our Websites; interacting with our Website(s) by subscribing to a service, e-newsletter, entering a competition; sharing information from one of our social media platforms or reporting a problem with our Websites. Personal information means any information related to you or any other third party that was collected or provided to us for the purposes stated in Section 2 below.

We process your personally identifiable information, which may include your name, NRIC number, contact details, financial and banking account details, information regarding your family, relatives, or third party that you provide to us, and your preferences about products and services you purchase from us, and location tracking/GPS information.

In addition, we may automatically collect the following information from your visits to our Websites:

(i) technical information such as the IP address used to access the Websites that identifies the mobile or other devices you use, the operating system, settings, network, and browser information used to access the Websites

(ii) the domain or URL method used to and from our Websites which may include the date, time, and sites that you used to navigate to or from our Websites, pages viewed, information searched, length of visit, the time required to load, and error messaging, clicks, mouse-overs, scrolling, and browsing methods

(iii) information stored on your mobile device, including photos, contacts, login, or other

(iv) digital content details on how you use and visit any of our Websites, including traffic dating, weblogs, communication data

(v) GPS technology in some apps to determine your location, which may be disabled by changing the settings on your mobile device

(vi) when installing or uninstalling an app with a unique application number or when an application searches for an update, information about the use of the app, and download

1.2) Source of information

(i) Customer or potential customer: we collect your personal information directly from you or indirectly from your legal representatives, agents, and/or employer when you, your legal representatives, agents, and/or employers send us a completed inquiry, application, and/or registration forms via various means, including online and physical hardcopies at public venues. Your personal information may also be collected from cookies through our website.

(ii) Vendor, supplier, or service provider: we collect your personal information directly from you or indirectly from your employer or agencies when you send us completed inquiries and/or application forms via various means, including online and physical hardcopies. Your personal information may also be collected from cookies through our website.

1.3) Obligatory information

All information requested in the relevant forms is obligatory to be provided by you unless stated otherwise.

Should you fail to provide the required information, we will be unable to process your request and/or provide you with relevant services.

2 Purposes of collecting and further processing (including disclosing) your personal information

(i) Customer or potential customer: Your personal information is collected and further processed by us as required or permitted by law and to give effect to your requested commercial transaction, including the following:

• to process your requested products and services;

• to facilitate your participation in any contests, giveaways, or events;

• to administer and communicate with you about our services and/or events;

• to process any payments related to your requested service;

• for insurance purposes;

• to operate our premises in a manner that is physically safe, secure, and betting of health and safety requirements;

• for internal investigations, audits, or security purposes;

• to conduct and support internal marketing analysis and analysis of customer patterns, choices, and engagement with our related companies, subsidiaries, holding companies, and affiliate companies;

• to be collected and stored in a central repository that is accessible by our related companies, subsidiaries, holding companies, and affiliate companies;

• to create and deliver personalized products and services that are unique to you to enhance your customer experience;

• to provide you with a more seamless customer experience;

• to support research and innovation of our products and services;

• to store and carry out data analytics processes;

• to improve our products and services;

• for matching of points provided by a third party/business partner to advertise and market products and services to you;

• for purposes of collaboration with a business partner to advertise and market products and services to you;

• to comply with our legal and regulatory obligations in the conduct of its business;

• to contact you regarding products, services, upcoming events, promotions, advertising, marketing, and commercial materials that we may feel interested you;

• to send you season greetings, particular occasion messages, or other similar communications;

• to allow third parties to contact you for advertising, promotional, or marketing campaigns conducted by any third party entities;

• to ensure that the content from our website is presented most effectively for you and your computer and/or device; and

• for our internal records management, customer relations events, activities, and customer reward program.

(ii) Vendor, supplier, or service provider: Your personal information is collected and further processed by us as required or permitted by law and to give effect to your requested commercial transaction, including the following:

• to process your account application;

• to assess your creditworthiness;

• to administer and give effect to your commercial transaction;

• to process any payments related to your commercial transaction;

• for insurance purposes;

• for internal investigations audits or security purposes;

• to comply with our legal and regulatory obligations in the conduct of its business;

• to contact you regarding products, services, upcoming events, promotions, advertising, marketing, and commercial materials that we may feel interested you;

• to ensure that the content from our website is presented most effectively for you and your computer and/or device; and

• for our internal records management, customer relations events, activities, and customer reward program.

* Where you have indicated your consent to receiving marketing or promotional updates from us, you may opt out from receiving such marketing or promotional material at any time. You may select the “unsubscribe” option in our email marketing or contact us at the details provided in Section (6) below.

Data Analytics Processing:

We want to share and consolidate your data into a single platform to be shared across our ecosystem services. We will use and share your data for analytics and measurement purposes to understand how our products and services are used, to help improve the products and services we offer, to provide you with more personalized products and services, and provide a more seamless customer experience.

For example, we analyze data about your choice and preferences about the products and services you purchase from us to send you targeted advertisements and promotional materials. We also process data about the ads you interact with to help us and advertisers understand the performance of various ad campaigns.

3 Disclosure of personal information

3.1) Entities within PENANG360

Your personal information provided to us is processed by and disclosed to entities (in or outside of Malaysia) within PENANG360 (including related companies, subsidiaries, holding companies, associated companies, and outsourcing partners) for the purposes stated in Section 2 (Purposes of collecting and further processing (including disclosing) your personal information) above.

We will ensure that:

(i) access to your personal information is restricted to staff who are contractually required to process your data by their job requirements.

3.2) Classes of third parties

Your personal information may be disclosed to relevant third parties (in or outside of Malaysia) as required under law, under relevant contractual or business relationships, our service providers, or for the purposes stated in Section 2 (Purposes of collecting and further processing (including disclosing)your personal information) above (or directly related to those purposes).

3.3) Advertisers, business partners, or other third-party entities.

We may occasionally provide your contact information to our partners and affiliates, who may, in turn, send you information by, for example, email about their products and services. On occasion, we may offer a special promotion (such as a giveaway, contest, or a free subscription to goods and services) on the website in conjunction with a third-party service provider, sponsor, or promotional partner, and share your information with that third-party service provider, sponsor or promotional partner so that it can send you other special promotions it offers. In those instances, we will inform you of the identity of the third-party partner.

We sometimes use third-party agents to run our Website(s), publish our newsletter, and provide you with helpful information about offers and services to travelers or those interested in travel to Penang and in related travel, event, leisure, cultural, accommodation, and entertainment or services available through our partners or to make or fulfill offers you receive from us. Our agents and partners include web services providers, contest fulfillment providers, event organizers, airlines, hotels and accommodation providers, and sightseeing and entertainment venues. We may share the information you provide with our agents or partners to provide you with services and information and to analyze data about our websites' use and the effectiveness of our advertisements. We require our agents and partners to keep your information private, not share it with anyone else, and if they want to contact you directly, obtain your permission to do that.

If a potential, proposed, or actual sale of the business, disposal, acquisition, merger, or re-organization (“Transaction”), your personal information may be required to be disclosed or transferred to a third party as a result of the Transaction. You hereby acknowledge that such disclosure and transfer may occur and permit us to release your personal information to the other party and its advisers/representatives.

(i) Customer or potential customer: Your personal information may be disclosed to the following classes of third parties:

• Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretary, consultants, contractors, professional advisors, service providers, printing companies, contractors, conference/training/event organizers, other advisers, etc.);

• Our business partners, agents, or affiliates who may jointly provide the service requested for;

‍• Law enforcement agencies, including the local police; and

• Relevant governmental authorities, statutory authorities, local councils, and industry regulators.

(ii) Vendor, supplier, or service provider: Your personal information may be disclosed to the following classes of third parties:

• Third parties appointed by us to provide services to us or on our behalf (such as auditors, lawyers, company secretary, printing companies, contractors, conference/training/event organizers, other advisers, etc.);

• Law enforcement agencies, including the local police, relevant governmental authorities, statutory authorities, local councils, and industry regulators.

Transfer of your data outside Malaysia:

‍It may be necessary for us to transfer your personal information outside of Malaysia if any of the third parties mentioned in section 3 (Disclosure of personal data) above, including our service providers or business partners who are involved in providing any services to us, are located or have processing facilities in countries outside of Malaysia.

You consent to us transferring your personal information outside Malaysia to such third parties and for the purposes set out in section 2 (Purposes of collecting and further processing (including disclosing) your personal information).

We shall take the necessary steps to ensure that any such third parties are contractually bound to protect your personal information and that they can only process your personal information under our instructions.

4 Websites

4.1) Links to other sites

Links to other sites are provided for your convenience and information. These sites may have their privacy statement in place, which we recommend you review if you visit any linked websites. We are not responsible for the content on the linked sites or any site use.

4.2) Location-enabled products or applications

Location-enabled products or applications transmit your location information to us. We do not use the information sent or provided other than to provide the service you request. Location-enabled features are opt-in, and you have control over your participation and can turn these services off at any time or uninstall them.

Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve you through improved products, services, and revisions to the mobile applications. This collected information will not identify you to us. It may, however, let us know anonymously which services and features you use the most within the application, device type and hardware features, country, and language of download.

4.3) Cookies

A cookie may be used in the processing of your information. A cookie is a text file placed into the memory of your computer and/or device by our computers. A copy of this text file is sent by your computer and/or device whenever it communicates with our server. We use cookies to identify you. We may also collect the following information during your visit to our website and/or the fully qualified domain name from which you accessed our site or your IP address:

(i) the date and time you accessed each page on our website;

(ii) the URL of any webpage from which you accessed our site (the referrer); and

(iii) the web browser you use and the pages you accessed.

Some web pages may require you to provide a limited amount of personal information to enjoy certain services on our websites (system login credentials, email address, contact, etc.). This personal information will only be used for intended purposes, i.e., to respond to your message or deliver the requested services.

5 Right to access and correct personal information

You have the right to access and update your data held by us(subject always to certain exemptions). We will make every endeavor to ensure your personal information is accurate and up to date; therefore, we ask that if there are changes to your information, you should notify us directly.

6 Limiting the processing of personal information, further inquiries, and complaints

If:

(i) you would like to obtain further information on how to limit the processing of your personal information;

(ii) you have any further queries; or

(iii) you would like to make a complaint in respect of your personal information, you may contact privacy@penang360.my

For information on all other businesses, please submit your inquiry at https://penang360.my/contact.

By submitting information to us or using our Websites, you consent to its collection and use by us by this Privacy Policy.

This Privacy Policy was last updated on 14 September 2022.