4.TYPES OF PERSONAL DATA WE PROCESS AND PURPOSES OF PROCESSING 

4.1.When you subscribe to our newsletters, we collect, store, use, and otherwise process the following categories of personal data about you:

(a)Personal contact details: such as your first name, last name, valid Malaysian mobile number, and email address.

4.2.If you do not provide us with your personal data, we will be unable to process your newsletter subscription. 

4.3.We collect, store, use, and otherwise process your personal data for the following purposes:

(a)Mandatory purposes 

·Subscription management: To process your registration for newsletter subscription, and maintain your newsletter subscription;

·Communication delivery: To send you newsletters, updates about products, services, events, promotions, and campaigns, and company news;

·Legal and regulatory compliance: To comply with applicable legal and regulatory obligations, including consumer protection requirements;

·Analytics and performance monitoring: To measure the effectiveness of our newsletters, and improve our content strategy, communication methods, and user experience; and

·Surveys and research: To invite you to participate in surveys or market research to improve our products or services.

5. Data Sharing

5.1.We will only disclose your personal data to third parties where required by law or where necessary to facilitate your newsletter subscription, or for other purposes outlined above. Such disclosure may be made to our employees, contractors, designated agents, or third-party service providers that need access to the data for these purposes. These third parties may be located outside of Malaysia and may include:

(a)our customer relationship management and marketing communications platform provider, Salesforce.com Singapore Pte. Ltd. (Address: 5 Temasek Boulevard, #13-01, Suntec Tower 5, Singapore 038985);

(b)our data hosting service provider, Amazon Web Services Singapore Private Limited (Address: 1 Robinson Road, #17-00, AIA Tower, Singapore 048542); and

(c)our information technology service provider, DTN e-Commerce Software Company Limited (Address: B12B-02, Vinhomes Gardenia, Cau Dien, Nam Tu Liem, Hanoi, Vietnam).

5.2.When we work with third parties, we require them to implement appropriate security measures to protect your personal data consistent with our policies and any data protection obligations applicable to us.

5.3.Your personal data may also be shared with or accessed by our affiliates, including those located outside of Malaysia, for internal operations across our corporate group and for other purposes outlined in this Privacy Notice. 

5.4.We may also disclose your personal data to comply with legal obligations or valid legal processes, such as warrants, subpoenas, or court orders.

5.5 Your personal data may be transferred to locations outside of Malaysia, including Hong Kong SAR, Indonesia, Japan, Singapore, the United States of America, and Vietnam, for the purposes described in this Privacy Notice.A

4. Types of Personal Data We Process and Purposes of Processing 

4.1.When you register for our Heavy Duty Club, we collect, store, use, and otherwise process the following categories of personal data about you:

(a)Personal contact details: such as your first name, last name, valid Malaysian mobile number, and email address;

(b)Transaction information: such as your purchase history and loyalty points balance;

(c)Demographic information: such as your date of birth, gender, the trade that you work in, and preferences, if you choose to provide them; and

(d)Other information: any additional personal details that you otherwise voluntarily provide to us. 

4.2.Certain fields marked with an asterisk (*) in the registration form, along with any other information we identify as necessary during the registration process, are mandatory for the registration. Failure to provide such required data may prevent us from processing your registration. 

4.3.We collect, store, use, and otherwise process your personal data for the following purposes:

(a)Mandatory purposes 

·Membership registration and management: To process your registration for our Heavy Duty Club, verify your identity, create and maintain your membership account, and enable access to membership benefits;

·Benefits administration: To administer and deliver loyalty rewards, discounts, promotions, and other Heavy Duty Club-related benefits;

·Legal and regulatory compliance: To comply with applicable legal and regulatory obligations, including tax, accounting, and consumer protection requirements;

·Legal rights and claims: To defend any legal claims that may be brought against us in connection with your registration or participation in our Heavy Duty Club, or to establish, bring or pursue any claim against you;

·Internal administration and recordkeeping: To maintain records of your membership and transactions, and to support internal operations, such as reporting, analytics, audits, and customer service; and

·Surveys and research: To invite you to participate in customer satisfaction surveys or market research to improve our products or services. 

(b)Voluntary purposes

·Marketing communications: Subject to your consent, to send you marketing communications, updates about products, services, events, promotions, campaigns, and exclusive member offers; and tailor the content of our communications based on your preferences and purchase history. 

5.Data Sharing

5.1.We will only disclose your personal data to third parties where required by law or where necessary to facilitate the registration process, administer and manage our Heavy Duty Club, or for other purposes outlined above. Such disclosure may be made to our employees, contractors, designated agents, or third-party service providers that need access to the data for these purposes. These third parties may be located outside of Malaysia and may include:

(a)our customer relationship management and marketing communications platform provider, Salesforce.com Singapore Pte. Ltd. (Address: 5 Temasek Boulevard, #13-01, Suntec Tower 5, Singapore 038985). 

5.2.When we work with third parties, we require them to implement appropriate security measures to protect your personal data consistent with our policies and any data protection obligations applicable to us.

5.3.Your personal data may also be shared with or accessed by our affiliates, including those located outside of Malaysia, for internal operations across our corporate group and for other purposes outlined in this Privacy Notice. 

5.4.We may also disclose your personal data to comply with legal obligations or valid legal processes, such as warrants, subpoenas, or court orders

5.5.Your personal data may be transferred to locations outside of Malaysia, including Hong Kong SAR, Indonesia, Japan, Singapore, the United States of America, and Vietnam, for the purposes described in this Privacy Notice.

4. Types of Personal Data We Process and Purposes of Processing 

4.1.When you submit the form to express your interest in our JSS, we collect, store, use, and otherwise process the following categories of personal data about you:

(a)Personal contact details: such as your full name, valid Malaysian mobile number, email address, company name, and job title;

(b)Demographic information: such as your date of birth, gender, postal code, and the trade in which you work; and

(c)Other information: any additional personal details that you otherwise voluntarily provide to us. 

4.2.If you do not provide us with your personal data, we will be unable to process your registration of interest in our JSS. 

4.3.We collect, store, use, and otherwise process your personal data for the following purposes:

(a)Mandatory purposes 

·Registration and communication: To process your registration of interest in our JSS, contact you regarding your registration and provide information about our JSS services, and arrange site visits and assessments by our JSS team;

·Service provision: To assess your jobsite needs and provide tailored solutions for power tool inventory management, and deliver pre-sales services;

·Legal and regulatory compliance: To comply with applicable legal and regulatory obligations, including consumer protection requirements;

·Legal rights and claims: To defend any legal claims that may be brought against us in connection with your registration of interest in our JSS or use of our JSS services, or to establish, bring or pursue any claim against you;

·Analytics and improvements: To analyze user preferences and behaviors to improve our services, products, and offerings;

·Internal administration and recordkeeping: To maintain records of your registration of interest in and use of our JSS services, and to support internal operations, such as reporting, and audits; and

·Surveys and research: To invite you to participate in customer satisfaction surveys or market research to improve our products or services. 

(b)Voluntary purposes

·Marketing communications: Subject to your consent, to send you marketing communications, updates about new products, services, events, promotions, and campaigns, and company news; and tailor the content of our communications based on your age, gender, and the trade in which you work.

5.Data Sharing

5.1.We will only disclose your personal data to third parties where required by law or where necessary to facilitate your registration of interest in, or use of, our JSS services, or for other purposes outlined above. Such disclosure may be made to our employees, contractors, designated agents, or third-party service providers that need access to the data for these purposes. These third parties may be located outside of Malaysia and may include:

(a)our customer relationship management and marketing communications platform provider, Salesforce.com Singapore Pte. Ltd. (Address: 5 Temasek Boulevard, #13-01, Suntec Tower 5, Singapore 038985);

(b)our data hosting service provider, Amazon Web Services Singapore Private Limited (Address: 1 Robinson Road, #17-00, AIA Tower, Singapore 048542); and

(c)our information technology service provider, DTN e-Commerce Software Company Limited (Address: B12B-02, Vinhomes Gardenia, Cau Dien, Nam Tu Liem, Hanoi, Vietnam).

5.2.When we work with third parties, we require them to implement appropriate security measures to protect your personal data consistent with our policies and any data protection obligations applicable to us.

5.3.Your personal data may also be shared with or accessed by our affiliates, including those located outside of Malaysia, for internal operations across our corporate group and for other purposes outlined in this Privacy Notice. 

5.4.We may also disclose your personal data to comply with legal obligations or valid legal processes, such as warrants, subpoenas, or court orders. 

5.5.Your personal data may be transferred to locations outside of Malaysia, including Hong Kong SAR, Indonesia, Japan, Singapore, the United States of America, and Vietnam, for the purposes described in this Privacy Notice.

4. Types of Personal Data We Process and Purposes of Processing 

4.1.When you submit the Contact Us form, we collect, store, use, and otherwise process the following categories of personal data about you:

(a)Personal contact details: such as your full name, valid Malaysian mobile number, and email address; and

(b)Other information: any additional personal details that you otherwise voluntarily provide to us. 

4.2.If you do not provide us with your personal data, we will be unable to respond to your request or inquiry. 

4.3.We collect, store, use, and otherwise process your personal data for the following purposes:

(a)Mandatory purposes 

·Inquiry management: To process and respond to your inquiry, request, or comment, and to communicate with you as necessary;

·Legal and regulatory compliance: To comply with applicable legal and regulatory obligations, including consumer protection requirements;

·Internal administration and recordkeeping: To maintain records of your inquiries, requests, or comments, and our responses, and to support internal operations, such as reporting, analytics, audits, and customer service; and

·Surveys and research: To invite you to participate in surveys or market research to improve our products or services.

(b)Voluntary purposes

·Marketing communications: To send you marketing communications, updates about products, services, events, promotions, and campaigns, and company news, subject to your consent.

5. Data Sharing

5.1.We will only disclose your personal data to third parties where required by law or where necessary to facilitate the handling of your inquiry, request, or comment, or for other purposes outlined above. Such disclosure may be made to our employees, contractors, designated agents, or third-party service providers that need access to the data for these purposes. These third parties may be located outside of Malaysia and may include:

(a)our customer relationship management and marketing communications platform provider, Salesforce.com Singapore Pte. Ltd. (Address: 5 Temasek Boulevard, #13-01, Suntec Tower 5, Singapore 038985);

(b)our data hosting service provider, Amazon Web Services Singapore Private Limited (Address: 1 Robinson Road, #17-00, AIA Tower, Singapore 048542); and

(c)our information technology service provider, DTN e-Commerce Software Company Limited (Address: B12B-02, Vinhomes Gardenia, Cau Dien, Nam Tu Liem, Hanoi, Vietnam).

5.2.When we work with third parties, we require them to implement appropriate security measures to protect your personal data consistent with our policies and any data protection obligations applicable to us.

5.3.Your personal data may also be shared with or accessed by our affiliates, including those located outside of Malaysia, for internal operations across our corporate group and for other purposes outlined in this Privacy Notice. 

5.4.We may also disclose your personal data to comply with legal obligations or valid legal processes, such as warrants, subpoenas, or court orders.

5.5 Your personal data may be transferred to locations outside of Malaysia, including Hong Kong SAR, Indonesia, Japan, Singapore, the United States of America, and Vietnam, for the purposes described in this Privacy Notice.

4. Types of Personal Data We Process and Purposes of Processing 

4.1.When you submit the form to participate in our Brand Survey, we collect, store, use, and otherwise process the following categories of personal data about you:

(a)Personal contact details: such as your full name, valid Malaysian mobile number, email address, company name, and job title;

(b)Demographic information: such as your date of birth, gender, postal code, and the trade in which you work; and

(c)Other information: any additional personal details that you otherwise voluntarily provide to us.

4.2.If you do not provide us with your personal data, we will be unable to process your survey response or deliver related communications or services. 

4.3.We collect, store, use, and otherwise process your personal data for the following purposes:

(a)Mandatory purposes 

·Analytics and improvements: To analyze survey responses for internal research aimed at enhancing our products, services, and customer experience;

·Communication delivery: To send you newsletters, updates about products, services, events, promotions, and campaigns, and company news; and tailor the content of our communications based on your age, gender, and the trade in which you work; and

·Legal and regulatory compliance: To comply with applicable legal and regulatory obligations, including consumer protection requirements.

5.Data Sharing

5.1.We will only disclose your personal data to third parties where required by law or where necessary to facilitate your participation in our Brand Survey, or for other purposes outlined above. Such disclosure may be made to our employees, contractors, designated agents, or third-party service providers that need access to the data for these purposes. These third parties may be located outside of Malaysia and may include:

(a)our customer relationship management and marketing communications platform provider, Salesforce.com Singapore Pte. Ltd. (Address: 5 Temasek Boulevard, #13-01, Suntec Tower 5, Singapore 038985);

(b)our data hosting service provider, Amazon Web Services Singapore Private Limited (Address: 1 Robinson Road, #17-00, AIA Tower, Singapore 048542); and

(c)our information technology service provider, DTN e-Commerce Software Company Limited (Address: B12B-02, Vinhomes Gardenia, Cau Dien, Nam Tu Liem, Hanoi, Vietnam).

5.2.When we work with third parties, we require them to implement appropriate security measures to protect your personal data consistent with our policies and any data protection obligations applicable to us.

5.3.Your personal data may also be shared with or accessed by our affiliates, including those located outside of Malaysia, for internal operations across our corporate group and for other purposes outlined in this Privacy Notice. 

5.4.We may also disclose your personal data to comply with legal obligations or valid legal processes, such as warrants, subpoenas, or court orders.

5.5 Your personal data may be transferred to locations outside of Malaysia, including Hong Kong SAR, Indonesia, Japan, Singapore, the United States of America, and Vietnam, for the purposes described in this Privacy Notice.