Captiv8 Sdn Bhd (“Operator”) respects the privacy of individuals with regard to personal data and is committed to protecting the privacy of our users, and strives to provide a safe, secure user experience. This privacy policy is formulated in accordance with the Personal Data Protection Act 2010 (“Act”), which describes how your information is collected and used and your choices with respect to your Personal Data. The following discloses our information gathering and dissemination practices for this website, TsemRinpoche.com.

1. Information collected by TsemRinpoche.com

Our Web servers do not automatically recognise specific information about individual users on our site. In addition, our servers do not automatically record information regarding a user’s email address unless the user supplies it.

We collect information about users during the registration process for certain parts of our site; through their participation in certain activities, including discussions, subscription services, contests, and polls; and through the use of cookies. When you request pages from our server, it automatically collects some information about your preferences, including your IP address. We use this to help diagnose problems with our server, and to administer our site.

The user-supplied information collected through the registration process, discussions, subscription services, contest entry forms, polls or other similar vehicles is used by the Operator of TsemRinpoche.com and its affiliates to improve the content of our site, or used for our marketing purposes. It is not shared with other organisations for commercial purposes unless specifically stated.

2. Purpose of Personal Data collected

Personal Data that you provide to us voluntarily on our website and its other related channels will be processed for the following purposes (“Purposes”):

• to complete transactions with you, manage and verify your membership with us where applicable;
• to direct market to you;
• to understand and analyse our readership, and your needs and preferences;
• to develop, enhance, market and provide content and services to meet your needs;
• to enable you to participate in promotions and contests;
• to improve our services; and,
• to respond to requests or complaints.

Although the precise details of the Personal Data collected will vary according to the specific purpose (such as contests, polls, subscription services, etc) whether via online or otherwise, we may typically collect the following Personal Data from or in relation to you:

• Name;
• Address;
• Phone number(s);
• Date of birth;
• Email address;
• Gender;
• Identity card number or passport number

3. Use and Disclosure

We may disclose your Personal Data to other subsidiaries within our group. These subsidiaries will treat your Personal Data as confidential, in accordance with this Privacy Policy and with all applicable Data Protection legislation and will process such Personal Data only for the Purposes and within the terms set out herein.

We are responsible for the Personal Data under our control, including Personal Data disclosed by us to a Vendor (often referred to as the data processor). “Vendor” in this Privacy Policy means in relation to Personal Data any person or entity (other than the Operator of TsemRinpoche.com, its employees and its affiliates) who processes the Personal Data on behalf of us. “Processing”, in relation to Personal Data means for example obtaining, recording, holding or using the Personal Data in carrying out any operation or set of operations on the Personal Data including organisation, compilation, retrieval disclosure of the Personal Data for verification Purposes.

We take every measure to provide a comparable level of protection for Personal Data should the information be Processed by a Vendor.

We use and disclose aggregated non-personally identifying information collected through this Website as part of our organisation’s process of constantly improving this Website and/or business.

4. Impact of Non Provision of Personal Data

Please note that in the event that sufficient Personal Data is not supplied, or is not satisfactory to us, then your application or request to us for any of the above purposes may not be accepted or acted upon or your request to browse some information on this Website may be denied or we will not be able to provide the full range of services through this Website.

5. Storage and Retention of Personal Data

Your Personal Data shall be stored either in hard copies in our offices or stored in our servers operated by us or our service providers.

Any Personal Data supplied by you will be retained by our organisation as long as necessary for the fulfilment of the purposes stated in (2) above or is required to satisfy legal regulatory, accounting requirements or to protect our interests.

We do not offer any online facilities for you to delete your Personal Data held by us.

6. How Email and ‘Contact Us’ messages are being handled

We may preserve the content of any email or “Contact Us” or other electronic message that we receive.

Any personal data contained in those messages will only be used or disclosed in ways set out in this Privacy Policy.

The message content may be monitored by our service providers or employees for purposes including compliance, auditing and maintenance or where email abuse is suspected.

7. Communication or Utilisation Data

Through your use of telecommunications services to access this Website, your communications data (e.g. Internet protocol address) or utilisation data (e.g. information on the beginning, end and extent of each access, and information on the telecommunications services you accessed) are technically generated and could conceivably relate to Personal Data.

To the extent that there is a compelling necessity, the collection, processing and use of your communications or utilisation data will occur and will be performed in accordance with the applicable data privacy protection legal framework.

8. Automatic Collection of Non-Personal Data

When you access this Website, we may automatically (i.e., not by registration) collect nonpersonal data (e.g. type of Internet browser and operating system used, domain name of the website from which you came, number of visits, average time spent on the site, pages viewed).

We may use this data and share it with rest of the Group to monitor the attractiveness of this Website and improve their performance or content.

9. Cookies

When you view this Website, we may store some data on your computer in the form of a “cookie” to automatically recognise your personal computer next time you visit.

Cookies can help us in many ways, for example, by allowing us to tailor a website to better match your interests or to store your password to save you having to re-enter it each time.

If you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer’s hard drive, block all cookies or to receive a warning before a cookie is stored.

10. Public Forums

This site makes information sharing, discussion, feedback, and/or message boards available to its users. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your Personal Data. We request that users treat each other with courtesy and mutual respect.

11. Confidentiality

Personal Data held by us will be kept confidential in accordance with this Privacy Policy pursuant to any applicable law that may from time to time be in force.

Any questions, comments, suggestions or information other than Personal Data sent or posted to this Website, or any part of the this Website by visitors will be deemed voluntarily provided to us on a non-confidential and non-proprietary basis.

We reserve the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely as set out in (3) above.

12. Security

This site has security measures in place to protect the loss, misuse and alteration of the information under our control. When a user is asked to provide his/her credit card information, we provide a secure environment through our partners’ systems (using industry standard SSL or SET protocols) for this purpose.

For the internet, unfortunately, no data transmission over the internet can be guaranteed as completely secure. So while we strive to protect such Personal Data, we cannot ensure or warrant the security of any Personal Data transmitted to us and individuals do so at their own risk. Once any Personal Data comes into our possession, we will take reasonable steps to protect that information from misuse and loss and from unauthorised access, modification or disclosure.

A username and password may be essential for you to use some sections of this Website. For your own protection, we require you to keep these confidential and to change your password regularly (if required).

13. Links

This site contains links to other sites. The Operator of TsemRinpoche.com is not responsible for the privacy practices or the content of such sites. The Operator of TsemRinpoche.com has also established relationships with partners but such relationships are generally technical in nature, or content collaborations. If any partner has access to any information entered by users in our database, this fact shall be disclosed to the user upon initiating the registration process. Users who feel they do not wish their information to be shared by anyone other than the Operator of TsemRinpoche.com may then opt out of completing the registration.

14. Right of Access to Personal Data

Under the Act, you have the right of access to your Personal Data held by us on payment of a prescribed fee and to request correction of the Personal Data that is inaccurate, incomplete, misleading or not up-to-date. If you have any questions regarding this Privacy Policy or if you wish to request access to your Personal Data or if you wish to correct your Personal Data or if you wish to withdraw your consent to us for the processing of your Personal Data for the purposes as set out in (2) above or for the transfer of your Personal Data to the parties stated in (3) above, you may send your request in writing to the following address:

TsemRinpoche.com
c/o Captiv8 Sdn Bhd
Suite # 8-13-6, Mutiara Bangsar
8, Jalan Liku
59100 Kuala Lumpur
Malaysia

Tel: +603 7806 5229
Email: tsemrinpoche.blog@gmail.com

15. Changes to Privacy Policy

We reserve the right to amend this Privacy Policy from time to time without prior notice. We advise that you check this Privacy Policy on a regular basis.

Last updated: 30 December 2015