We appreciate your interest in Shamrock. Shamrock takes the protection of your privacy and your Personal Data very seriously. Therefore, we process your Personal Data only in accordance with applicable data protection laws.
“Personal Data” means personally identifiable information about an individual, such as a name, address, email address, phone number, or other identifier that permits direct or indirect identification of a specific individual, or as otherwise defined by applicable privacy and data security laws.
We collect information about Online Services Users directly from you and automatically through your use of our Online Services.
Online Services Users
In general, you can visit or use our Online Services without identifying yourself or revealing any of your Personal Data. However, you may actively provide us with Personal Data, for example, when you sign up to receive emails from us, open or respond to our emails, participate in surveys or subscribe to receive our publications. In this case, we collect the following Personal Data as far as provided by you:
- your name; company; address data, email address and phone number;
- content and type of your request or preferences;
- date and time of your request;
- your marketing preferences, including any consents you have given us;
- any other information you provide to us in connection with your use of our Online Services.
We will mark mandatory fields, if any, of any contact form available under any Online Service. However, you can choose to withhold Personal Data from us, or to provide information to us under a pseudonym. Without providing the requested Personal Data you may prevent us from answering and meeting your requests or to provide our Online Services properly.
When you visit our Online Services, we automatically collect Personal Data through your visit or use of our Online Services. This Personal Data may include, without limitation, the type of browser you use, the third-party web site from which your visit to our Online Services originated, the search terms you use on our Online Services, the specific web pages you visit on our Online Services and the duration of your visits, your IP address, device ID and other unique identifiers, information about your operating system, settings and system configuration.
Business Partner Contacts
In the context of a potential or existing business relationship, we may process the following Personal Data about Business Partner Contacts:
- contact information, such as full name, work postal address, work telephone number, work cell/mobile phone number, work fax number, work email address, and job title;
- payment data, such as credit/debit card numbers, security code numbers, tax ID and other related billing information and data necessary for processing payments and fraud prevention;
- further information necessarily processed in the course of a project or contractual relationship with us or voluntarily provided by the Business Partner Contacts, such as Personal Data relating to orders placed or payments made;
- Personal Data collected from publicly available resources (e.g. names of shareholders or directors, professional identifiers, affiliation details, representatives or auditors);
- other Personal Data, if required for compliance screenings of our Business Partners or Business Partner Contacts, performed in line with applicable law. This may include date of birth, ID numbers, identity cards and information about relevant and significant litigation or other legal proceedings against Business Partners, Business Partner Contacts and other individuals associated with Business Partners;
- any other information you provide to us in connection with your business relationship with us.
We may process Personal Data during the course of our interactions or that you chose to provide to us for the purposes outlined below.
You have the option of not disclosing Personal Data to us or to use a pseudonym instead, unless it is impractical, in our determination, for us to assist you or we are otherwise required by law or a court or tribunal to deal with you on an identified basis. If you choose to withhold any Personal Data, we may not be able to provide you with all or part of our Online Services or fulfil a contract with the relevant Business Partner.
We process Personal Data of Online Services Users for the following purposes:
- as required for operating and managing our Online Services and to be able to allow you to access and use our Online Services with all its functions;
- as required to provide content to you, respond to your queries or requests, communicating and interacting with you;
- as required by Shamrock to operate our business;
- to send you an email confirming your registration to monitor the use of our Online Services products, to improve and develop our Online Services; and for internal statistical or operational purposes, such as for measuring and understanding the demographics, interests, purchases and trends of our Online Services Users;
- as required to administer and perform marketing campaigns, surveys, market analysis, contests, sweepstakes or other promotional activities or events;
- to protect our rights and interests as well as the rights and interests of our Online Services Users and any other person;
- to comply with applicable legal or regulatory obligations (including, but not limited to, use in connection with legal claims) and for compliance, regulatory, investigative purposes (including disclosure of such information in connection with legal process or litigation).
We process Personal Data of Business Partner Contacts in the context of a potential or existing business relationship for the following purposes:
- to communicate with you about products and services, or to respond to any your queries or requests;
- to establish and fulfil a contract with you or one of our Business Partners, a request for a quotation or a purchase order. This may include delivery of products or services, verifying your identity and your company’s financial solvency and credit risk, collection of payments due to us inclusive the (re-)financing of debts, performing accounting, auditing;
- the management of our relationship with you and the Business Partner represented by you;
- to administer and perform marketing campaigns, surveys, market analysis, contests, sweepstakes or other promotional activities or events;
- to comply with applicable laws (such as record keeping obligations), compliance screening obligations (e.g. anti-money laundering checks), and to protect Shamrock’s legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims and compliance, and for regulatory or investigative purposes (including disclosure of such information in connection with a legal process or litigation).
We rely on the following legal grounds to process Personal Data:
- As required to establish, manage, perform and/or terminate contracts with you.
- As required to pursue our legitimate interests, to the extent that such legitimate interests are not overridden by your data protection rights.
- Where we have obtained your prior consent.
- As required to comply with applicable laws or if is in the public interest.
This Website contains links to other sites. We are not responsible for the privacy practices or the content of such sites. We have established relationships with advertisers and/or business partners but such relationships are generally technical in nature, or content collaborations. If any advertisers and/or business partners 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 Website may then opt out of completing the registration.
Cookies are small text files which are placed on your computer or device. Cookies can identify your internet browser but not you. You can adjust your web browser settings to restrict, limit or deny cookies, but note that this may result in aspects of our Online Services not functioning correctly. Your consent is not required for us to place necessary cookies (Session Cookies) which ensure the continuity of your browsing session while you move around the Online Services, enable you to access secure areas, or allow you to save items to an online list or “basket”.
We will ask for your consent before placing any cookies on your computer or device that collect information about which aspects of our Online Services are most visited and what errors are experienced on our Online Services, so that we can improve the design and layout of our Online Services and improve the effectiveness of our platforms and software applications.
We will ask for your consent before placing any cookies (Persistent Cookies) on your computer or device that enable our Online Services to recall selections you have previously made, in order to provide you with a personalised experience (e.g. displaying content in your preferred language or remembering your city or country location).
We will ask for your consent before placing any advertising cookies on your computer or device that enable the delivery of advertising content related to your browsing history.
We will not sell, rent, transfer or disclose any of your Personal Data to any third party without your consent. However, we may disclose your Personal Data to the following third parties, for one or more of the above Purposes:
- our related corporations and affiliates either in Malaysia or overseas;
- successors in title to us;
- any person under a duty of confidentiality to which has undertaken to keep your Personal Data confidential which we have engaged to discharge our obligations to you;
- any party in relation to legal proceedings or prospective legal proceedings;
- our auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our business on a strictly confidential basis, appointed by us to provide services to us;
- any party nominated or appointed by us either solely or jointly with other service providers, for purpose of establishing and maintaining a common database where we have a legitimate common interest;
- data centres and/or servers located within or outside Malaysia for data storage purposes or otherwise;
- payment channels including but not limited to financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to us in connection with your purchase of our products and/or services;
- government agencies, law enforcement agencies, courts, tribunals, regulatory bodies, industry regulators, ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities;
- our joint venture/business partners, third-party product and/or service providers, suppliers, vendors, contractors, data processors or agents, that provide related products and/or services in connection with our business, or discharge or perform one or more of the above Purposes and other purposes required to operate and maintain our business, including but not limited to call centers, telecommunication companies, logistics companies, information technology companies and data centers; insurance companies for the purpose of applying and obtaining insurance policy(ies), if necessary;
- financial institutions for the purpose of applying and obtaining credit facility(ies), if necessary;
- financial institutions, merchants and credit card organisations in connection with your commercial transactions with us;
- the general public when you become a winner in a contest by publishing your name, photographs and other Personal Data without compensation for advertising and publicity purposes;
- to third-party credit reporting or employment agencies as part of the recruitment and selection process and/or otherwise in connection with your application for employment with us;
- in the event of a potential, proposed or actual sale/disposal of any of our business or interest, merger, acquisition, consolidation, re-organisation, funding exercise or asset sale relating to us, or in the event of winding-up (“Transaction”), your Personal Data may be required to be disclosed or transferred to a third party as a result of, or in connection with, the Transactions.
You hereby acknowledge that such disclosure and transfer may occur and permit us to disclose and transfer your Personal Data to such third party and its advisors/representatives and/or any other person reasonably requiring the same in order for us to operate and maintain our business or carry out the activities set out in the Purposes.
We are committed to ensuring that your Personal Data is stored securely. In order to prevent unauthorised access, disclosure or other similar risks, we endeavour, where practicable, to implement appropriate technical, physical, electronic and procedural security measures in accordance with the applicable laws and regulations and industry standard to safeguard against and prevent the unauthorised or unlawful processing of your Personal Data, and the destruction of, or accidental loss, damage to, alteration of, unauthorised disclosure of or access to your Personal Data.
We will make reasonable updates to its security measures from time to time and ensure the authorised third parties only use your Personal Data for the Purposes set out in this Policy.
The Internet is not a secure medium. However, we will put in place various security procedures with regard to the Site and your electronic communications with us. All our employees, joint venture/business partners, agents, contractors, vendors, suppliers, data processors, third-party product and/or service providers, who have access to, and are associated with the processing of your Personal Data, are obliged to respect the confidentiality of your Personal Data.
Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may be routed through a number of countries before being delivered – this is the nature of the World Wide Web/Internet.
We cannot and do not accept responsibility for any unauthorised access or interception or loss of Personal Data that is beyond our reasonable control.
You as Data Subjects generally have the following rights:
- You can request information from us at any time as to whether and how we process your Personal Data and request that we give you access to your Personal Data or send you a copy of it.
- If you believe that your Personal Data is incorrect or incomplete, you can ask us to correct or complete it.
- You may also have the right to object to the processing of your Personal Data and you may request us to restrict our use of your Personal Data and to delete your Personal Data.
- If we process your Personal Data based on your consent, you have the right to withdraw your consent at any time. You can withdraw your consent by emailing Shamrock. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent.
With regard to the Personal Data we process based on your consent or based on a contract, you may request a copy of this Personal Data from us. Some of these rights are restricted. For example, we cannot delete Personal Data if we are obliged to store it by law or if we retain it based on a contract with the relevant Data Subject. In addition, information about, and access to, Personal Data may be denied if Personal Data about another person would be disclosed in the course of complying with the request, or if it is not possible for us to disclose the requested Personal Data for legal reasons. If Personal Data is required by us to fulfil a legal or contractual obligation, providing this information is mandatory. If this information is not provided, we cannot perform the contract or fulfil our obligations. In all other cases, the provision of the requested Personal Data is voluntary.
If you, as a Business Partner or Data Subject, would like to access, amend, restrict or enquire about your data, please contact or email us at Shamrock.
If you wish to make a complaint or report a data privacy breach, please email Shamrock.
We will keep Personal Data for as long as it is necessary for the relationship with Data Subjects or otherwise permitted or required under applicable law. If we are processing a specific request that you have sent us, we will generally keep the concerned Personal Data for as long as is necessary to process this request. Afterwards, we may retain Personal Data for an appropriate period to protect ourselves from legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold the relevant Personal Data for specific periods.
If we process Personal Data based on consent, we will delete this Personal Data upon withdrawal of the consent. If a different retention period will apply to any Personal Data, this will be specified at the time that Personal Data is collected (e.g. when we ask for consent). Once the purpose for which the Personal Data was initially collected is achieved and the retention period has ended, we will delete or anonymise it in a secure manner without unreasonable delay. If we cannot entirely delete Personal Data due to statutory retention obligations or billing and accounting obligations, the Personal Data will be “blocked” (meaning that the Personal Data cannot be used further) until the relevant retention period expires or until the billing or accounting purpose has been fulfilled.