1. Our Commitment to Your Privacy
1.1 Luwjistik (hereinafter, “Luwjistik”, “we”, “us” or “our”) is owned and operated by Ally Logistics Integrators Pte. Ltd. (202119298H) an exempt private company limited by shares incorporated under the laws of Malaysia. Luwjistik is committed to protecting the privacy and security of your personal data (as defined in the Personal Data Protection Act 2010 of Malaysia (“PDPA”)).
1.2 This privacy policy and notice (“Policy”) describes how we collect, maintain, use, disclose, process and safeguard your personal data and the personal data of any third party individual, including any sensitive personal data (as defined in the PDPA), as may be voluntarily or required to be provided by you in the course of you utilising our website at https://luwjistik.com/ and https://www.luwjistik.io ( (the “Platform”). This Policy also tells you about your rights and how the applicable laws protect you.
1.3 This Policy supplements the other notices and terms of use on the Platform (including our General User Terms of Use (“T&Cs”)) and is not intended to override them.
2. Your Consent Is Important
2.1 At Luwjistik, we value your privacy and will protect your personal data as provided by you in the course of utilising the Platform in compliance with the laws of Malaysia, in particular the PDPA.
2.2 Before you use our services (i.e., the ‘Platform Services’ as defined in the T&Cs) (“Services”), please read this Policy in its entirety, as it serves to help you make informed decisions about how we collect, use and process your personal data.
2.3 Luwjistik will only collect and use your personal data in accordance with such applicable laws (including the PDPA), this Policy and/or the privacy terms in any agreement(s) that you may have or will enter with Luwjistik.
2.4 This Policy explains:
2.4.1 what kind of personal data we collect about you and how we collect it from you;
2.4.2 how we use your personal data;
2.4.3 the parties that we disclose your personal data to;
2.4.4 the rights in respect of your personal data; and
2.4.5 the choices we offer, including how to access and update your personal data.
2.5 By providing us your personal data either at our request or voluntarily, using our Services and/or order or purchase any services on the Platform, and communicating with us on the Platform, you hereby consent to our collection, use, processing and disclosure of your personal data in accordance with this Policy.
Effective Date: 1 January 2022
2.6 If you provide us information on behalf of someone else, you represent and warrant to us that the other person has appointed you to act on his/her behalf and has fully agreed that you have the authority to:
2.6.1 give consent on his/her behalf to the processing of his/her personal data;
2.6.2 receive on his/her behalf any privacy notice; and
2.6.3 give consent to the transfer of his/her personal data abroad.
2.7 If you are a user of our Platform, the provision of your personal data is voluntary. However, if you do not provide your personal data, we will not be able to process your personal data for the purposes outlined in this Policy and may cause us to be unable to provide our Services or accept payments from you.
2.8 If you are an agent, client, supplier, service provider, network partner or strategic partner of Luwjistik, the provision of you or your representative’s personal data is required for the purpose of registering for a user account with Luwjistik (“User Account”), providing our Services to you and failure to provide your or your representative’s personal data may cause us to be unable to engage you to list your services for sale on the Platform, issue payments to you for services listed by you on the Platform, process your orders or provide refunds.
3. Information Collection and Use
3.1 As part of using our Services, placing an order and registering for a User Account with us, and in order to enable us to deal with your enquiries, if any, and to generally allow us to provide you with our Services, we may need to and/or may be required to collect, record, hold, use, disclose and store (“process”) personal data and financial information about you, including but not limited:
3.1.1 to establish your personal identification and background; and/or
3.1.2 to establish your financial standing and creditworthiness (where required).
3.2 We may, from time to time, collect the following personal data and information from you:
3.2.1 Contact Information, such as: your name, alias, email address, mailing address and phone number, delivery address, and residential address;
3.2.2 Personal Identification Information, such as: your age, gender, nationality, date of birth, professional or job title or occupation (including your identity card number or passport number);
3.2.3 User Account/ Profile Information, such as: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey/ contest responses (if a corporate user, information about your business, such as company name, address, business type, owner, directors’ and shareholders’ details (if applicable)); if you are logging in and accessing the Platform using a third party social media network such as Facebook or a web account hosting service such as Google or Apple, such account information that may be accessible by us (including your profile name, date of birth, email address, and mobile number), given your authorisation;
3.2.4 User-generated Content, such as: photos, videos, audio, messages, reviews you leave for network partners, customer service information, any feedback or testimonials that you may provide to us about our Services, or such other content that you may publish on the Platform;
3.2.5 Payment/ Financial Information, such as: your bank account and payment details (including where applicable, credit or debit card number or e-wallet information), shipping and billing information, TAC codes and verification numbers, expiration date of your credit or debit card (where applicable), and information about your transactions and purchases with us;
3.2.6 Device, Connection and Usage Information, such as: information on how you use our Services, order our network partners’ services, or view any content on the Platform, data that your browser sends to us whenever you visit our service or when you access the Platform using a mobile device, which may include your computer or mobile device’s Internet Protocol (IP) address, browser type and language, browser version, device type and operating system, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data;
3.2.7 Transaction Information, such as: details about payments made by and to you, and other details of services that you have ordered or purchased on the Platform; and
3.2.8 Marketing and Communications Information, such as: your preferences in receiving marketing material and communications from us and any third party,
including any other information as required by us from time to time for the purposes specified in this Clause 3 and the following Clause 4, and any other information you choose to directly provide to us in connection with your use of the Services.
3.3 The types of personal data set out under Clause 3.2 is not a definitive or exhaustive list of all the personal data that we will collect from you. Nonetheless, we will only collect your personally identifiable information where it is necessary to provide our Services to you and to accurately establish or verify the identities of individuals to a high degree of fidelity.
3.4 We may obtain this information from you directly and from a variety of sources, including but not limited to:
3.4.1 through your relationship with us, for example information provided by you in enquiry, when you sign up for a User Account with us, when using our Services, when you order or purchase any services on the Platform, when taking part in customer surveys, competitions, activities and promotions conducted on the Platform, when you message or communicate with us by phone, email or other correspondence methods;
3.4.2 through your verbal and/or written communications with us and/or our authorised agents;
3.4.3 through any photos/videos collected by us and/or our authorised agents;
3.4.4 from third parties connected with you, such as your partners, directors, shareholders, employers, employees, joint account holders, guarantors, subject to your prior consent, and our terms of use with the said third party;
3.4.5 from an analysis of the way you use and manage your account(s) with us; and/or
3.4.6 from such other sources in respect of which you have given your consent to disclose information relating to you and/or where not otherwise restricted, including from consumer data resellers, public records databases, conferences and other events, our Affiliates, social media networks, in accordance with your privacy preferences on such services, third-party payment processors who collect information on our behalf and who also have an independent relationship with you, third party suppliers and sellers, survey, contest and sweepstake service providers, researchers and analysts, advertising providers, analytics providers, and/or cookies and tracking technologies deployed on our Platform.
4. Purposes of Processing Your Personal Data
4.1 Other than as stated above under Clause 3.1, we may use your personal data for one or more
of the following purposes:
4.2 Where you are a user of the Platform:
4.2.1 to generally provide you with our Services;
4.2.2 to perform our obligations in respect of any contract entered into with you, and for any legitimate business interests that we may have;
4.2.3 to administer your User Account;
4.2.4 to send bills, invoices and receipts;
4.2.5 to assess your order for any services;
4.2.6 to process your orders and to enable the relevant network partners to provide their services to you;
4.2.7 to process payments relating to any services that you have ordered;
4.2.8 to verify your financial standing through credit reference checks;
4.2.9 to manage and maintain your relationship with us, and to provide you with customer service and technical support;
4.2.10 to provide you with information on offers and promotions on the Platform which may be of interest to you, including personalised newsletters, marketing or promotional materials, special offers and general information about other products, services and events which we offer that are similar to those that you have previously purchased or enquired about (you may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us);
4.2.11 to improve our services and to develop new products and/or services by analysing and researching on how you use our Services;
4.2.12 to notify you about benefits and changes to the features of our Services and/or Platform;
4.2.13 to notify you of software updates that affect Services provided by us;
4.2.14 to process your participation in any offers, competitions, events, activities, contests, polls, surveys or promotions, and to fulfil the delivery of any prizes to you;
4.2.15 monitor, detect and prevent fraud, spam or malware on the Platform; and/or
4.2.16 to use Cookies (as defined in Clause 13.1) to enhance our processes, advertising, notifications, authentication, security and compliance, analytics and/or preference management.
4.3 Where you are our network partner:
4.3.1 for the purposes of engaging you as a network partner to provide services to clients;
4.3.2 to facilitate or enable any checks as may be required by us in order to engage you;
4.3.3 to process payments relating to any services you have provided;
4.3.4 to verify your financial standing through credit reference checks;
4.3.5 to provide personalised feedback to you, so that you are able to identify specific areas for improvement; and/or
4.3.6 to contact you in relation to the provision of your services.
4.4 General:
4.4.1 to respond to your enquiries, feedback and complaints;
4.4.2 to improve the quality, efficiency and utilisation of our Services;
4.4.3 to maintain, update, consolidate and improve the accuracy of our database records;
4.4.4 to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
4.4.5 to conduct research for data analytical purposes including but not limited to data mining and analysis of your transaction with us;
4.4.6 to meet the disclosure requirements of any law binding on Luwjistik;
4.4.7 for audit, compliance and risk management purposes;
4.4.8 to assess financial and insurance risks;
4.4.9 to transfer or assign our rights, interests and obligations under any of your agreement(s) with us;
4.4.10 to protect or enforce our rights to recover any debt owing to us;
4.4.11 to maintain the safety and security of our Services;
4.4.12 for crime detection, prevention and prosecution;
4.4.13 to detect, prevent and address any technical issues arise from our Services; and/or
4.4.14 for any other purpose that is required or permitted by any law, regulations and/or guidelines.
4.5 Based on your consent, we have the right to use your photos, images and recordings for our marketing, advertising and publicity purposes without any payment of royalty or image fees to you. We may also publish your name and photo on the Platform at our sole and absolute discretion when you become a winner in a contest which you participate in that we may from time to time organise. If you do not agree to such use, please write to us to request to withdraw your consent.
4.6 We will seek your separate consent for any other purposes which do not fall within the purposes stated in this Clause 4.
5. Disclosure of Your Personal data
5.1 As a part of providing you with our Services and the management and/or operation of the same, we may disclose your personal data (to the extent necessary) to the following third parties:
5.1.1 companies and/or organisations that act as our service providers, network partners, strategic partners and/or licensors;
5.1.2 companies and/or organisations that assist us in providing value added services to you (where necessary);
5.1.3 your advisers (including but not limited to accountants, valuers, adjustors, auditors, tax consultants, lawyers, bankers, financial advisers or other professional advisers) which are authorised by you;
5.1.4 any person notified by you as authorised to give instructions or to use the User Account or Services on your behalf;
5.1.5 any rating agency, insurer or insurance broker or direct or indirect provider of credit protection;
5.1.6 any financial institutions, and where applicable, e-wallet service providers, VISA International Services Association, MasterCard International Incorporated and other card associations in relation to any credit card and/or debit card issued to you;
5.1.7 any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us;
5.1.8 any government departments/agencies and statutory authorities in connection with any investigations or enquiries;
5.1.9 fraud and crime prevention agencies for the purposes of assessing the risk of crime, fraud and money laundering and this is a condition of us entering into any contract with you;
5.1.10 our IT service providers who provide technical infrastructure services, software and development work, analyse how our Services are used, or provide customer service to you; and/or
5.1.11 other parties in respect of whom you have given your express or implied consent.
5.2 With your authorisation, we may disclose your personal data to a third-party. If you authorise this disclosure, the use and disclosure restrictions contained in this Policy will not apply to such third party, as we do not control the privacy practices of any third parties.
5.3 We do not currently have any affiliates, but if we do in the future, we may disclose your personal data to a parent company, any subsidiaries or other companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to comply with this Policy.
5.4 Your personal data may also be disclosed as part of any merger, acquisition, joint venture, debt financing, sale of Luwjistik or its business assets, as well as in the event of an insolvency, bankruptcy or receivership in which personal data could be transferred to third parties as one of our business assets. In such an event, we will attempt to notify you before your personal data is transferred, but you may only have the right to opt out of, or object to, any such transfer to the extent allowed under the PDPA.
5.5 The above Clauses 5.1 and 5.2 shall be subject, at all times, to any laws (including regulations, standards, guidelines and/or obligations) applicable to Luwjistik (whether in or outside Malaysia).
6. Disclosure for Marketing and Promotional Purposes
6.1 If you have given us your permission, we may contact you by mail, telephone, SMS, text/picture/video online instant messaging, email or other correspondence methods about our, or our strategic partners’, sponsors’ or advertisers’ services, promotions, special offers, events or activities that may be of interest to you.
6.2 We do not and will not disclose, rent, sell or otherwise make available your personal data to third parties for direct marketing purposes.
6.3 If you prefer not to receive any marketing communications, notifications and materials from us, you can opt out at any time by following the unsubscribe instructions or using the unsubscribe links within the emails that we send to you or by writing to us.
6.4 You may select whether or not you wish to continue to receive newsletters, updates, promotional materials, festive greetings or other communications by writing to us. In addition,
you may “opt out” of receiving any category of subscription, marketing or promotional email from us by following the unsubscribe instructions or using the unsubscribe links within the emails that we send to you. Please note, however, that as long as you remain as a user with us, you may not “opt out” of receiving user-related notifications and materials from us, failing which, we will not be able to provide user-related services to you.
7. Situations Under Which We Disclose Your Personal Data
7.1 Save as set out above, we will otherwise treat your personal data as private and confidential and will not disclose your information to anyone except in any of the following situations:
7.1.1 where you have given permission for us to disclose your personal data in accordance with this Policy;
7.1.2 where we are required or permitted to do so by law;
7.1.3 where required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over Luwjistik;
7.1.4 where we may transfer rights and obligations under this Policy; and/or
7.1.5 where we are required to meet our obligations to any relevant regulatory authority.
8. Data Security
8.1 As we are committed to protecting your personal data, we will take reasonable security arrangements to safeguard your personal data in our possession or control from (a) unauthorised access, collection, use, disclosure, copying, modification or similar risks; and (b) the loss of any storage medium or device on which your personal data is stored.
8.2 Any of your personal data provided to us are stored on secure servers located in Singapore. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will also apply and maintain an appropriate security procedure to manage and protect the use and storage of records containing your personal data, and this includes regularly reviewing and updating the technical and organisational security measures governing the processing of personal data to be carried out.
8.3 We will not retain any personal data for a period longer than is necessary for the fulfilment of the purpose for which it is to be processed. We will take reasonable steps to ensure that such personal data is destroyed or permanently deleted when it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, or is no longer necessary for our legal or business purposes.
9. Your Obligation to Provide Complete Personal Data
9.1 Where indicated, we require you to provide your personal data to us to enable us to process your information to enable us to provide our Services and allow you to place orders for services on the Platform. Should you decline to provide such obligatory personal data, we may not be able to process your order or provide you with our Services.
9.2 You confirm that all your personal data is true, accurate and complete and that none of the personal data provided is misleading or outdated. In the event of any change to your personal data, you will promptly update us on any such change.
10. Your Rights to Access and Correct Your Personal data
10.1 We can assist you to access and correct your personal data provided to us, and the following will apply:
10.1.1 You may have access to your personal data collected and stored by us by making a request by writing to us, subject to your payment of the relevant processing fee (if applicable). If you make such a request, we will use reasonable efforts to provide you with a copy of the requested personal data within twenty-one (21) days of receiving your duly completed ‘Access Request Form’ and the processing fee. If we are unable to provide you with access to any of your personal data or to make a correction requested by you, we will provide you with the reasons why we are unable to do so (or if we are not required to do so under the PDPA).
10.1.2 Please note that Luwjistik may have to withhold access to your personal data in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential nature or in the event where we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.
10.1.3 Where your request for data access is successful and you are of the opinion that such personal data held by us is inaccurate, incomplete, misleading or where relevant, not up-to-date, you may make a request to correct such personal data.
10.1.4 You can also assist us to keep your personal data (such as your current mailing address) up-to-date, as it will enable us to serve you better.
10.1.5 In the event you wish to correct or update your personal data previously provided to us, you may write in or notify us at the address provided in Clause Error! Reference source not found.. We will use reasonable efforts to comply with your request to correct your personal data within twenty-one (21) days of receiving your written request.
10.1.6 Please note that Luwjistik may use its discretion in allowing the correction or update requested or may require further documentary evidence of the new information to avoid fraud and inaccuracy.
11. Exercising Your Choices in Respect of The Disclosure and Use of Your Personal data
11.1 Subject always to our contractual rights and obligations under relevant laws and regulations, you may exercise your choice in respect of the disclosure, retention and use of your personal data by Luwjistik. You may, at any time, access, correct, or update your personal data in your User Account, or any personal data stored with us. You may also delete any of your personal data from your User Account, or otherwise request for your personal data to be deleted from your User Account and/or our data servers. Should you wish to do so, kindly contact us at:
11.1.1 Email: [email protected]
12. Transfer of Personal Data
12.1 We currently do not transfer your personal data outside of Singapore. In the event that we do, your personal data may be transferred to, stored, used and processed in a jurisdiction other than Singapore where Luwjistik’s servers and/or service providers and partners may be located. We will also take all necessary steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA and in accordance with this Policy.
12.2 Your usage of our Services followed by your submission of such information represents your agreement to that transfer. You understand and consent to the transfer of your personal data out of Singapore as described herein, and such consent shall be deemed to remain valid until you have deactivated your account.
13. Cookies and Tracking
13.1 Luwjistik, its Affiliates, licensors, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of the Platform to track the activity on our Platform and we hold certain Cookies information to track, analyse and improve our Services. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of our Services, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.
13.2 Luwjistik may allow third parties to use Cookies on the Platform to collect the same type of information for the same purposes Luwjistik does for itself. Third parties may be able to associate the information they collect with other information they have about you from other sources. We do not necessarily have any responsibility, access to, or control over the Cookies they use.
13.3 Additionally, we may share non-personally identifiable information from or about you with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.
13.4 If you do not wish for your personal data to be collected via Cookies on the Platform, you may deactivate Cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also be able to limit our sharing of some of these information through your mobile device settings.
14. Links to Third-Party Websites
The Platform may contain links to third parties’ websites. If you click on a third-party link, you will be directed to that third party’s site. Please note that Luwjistik is not responsible for the
collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information directly to such sites, the privacy policy and terms of service on those sites are applicable and Luwjistik shall not be responsible for the information processing practices or privacy policies of such sites. We strongly advise you to review the privacy policy of every site you visit.
15. Personal Data from Minors and Other Individuals
15.1 Our Service is not intended to extend to, nor do we knowingly collect personal information of, anyone under the age of eighteen (18). As a parent or legal guardian, you are under the obligation to not allow a minor (individuals under eighteen (18) years of age) under your care to submit personal data to Luwjistik in their own capacity. In the event that such personal data is provided to Luwjistik, you hereby consent to the processing of the minor’s personal data and personally accept and agree to be bound by this Policy and take responsibility for his or her actions.
15.2 In some circumstances where you may have provided personal data relating to other individuals (such as your spouse, family members, friends, business partners, shareholders or directors), in such circumstances you represent and warrant that you are authorised to provide their personal data to Luwjistik and you have obtained their consent for their personal data be processed and used in the manner as set forth in this Policy.
15.3 If we become aware that we have inadvertently collected personal data from anyone under the age of eighteen (18) without verification of parental consent, we will take steps to remove that information from our servers.
16. Enquiries or Complaints
Should you have any queries, concerns or complaints in relation to this Policy or how we handle your personal data, kindly contact us at:
16.1.1 Email: [email protected]
17. Amendment and Language
17.1 Luwjistik shall have the right to modify, update or amend the terms of this Policy at any time, and from time to time by placing the updated Policy on the Platform, which shall be effective immediately. By continuing to communicate with Luwjistik and/or continuing to use our Services following the modifications, updates or amendments to this Policy, you acknowledge that such actions shall signify your acceptance of such modifications, updates or amendments.
17.2 In the event of any conflict between the English and other language versions of this Policy, the English version shall prevail to the extent of the conflict.