Last Updated: 16 NOVEMBER 2022

Galactic Ventures Sdn. Bhd. (1172907-D) (hereinafter known as “the COMPANY” or “us” or “we” or “our”) is committed to ensuring that your privacy is protected. In the event we require you to provide certain information by which you can be identified when using this StreetPaw Website and App, then we will ensure you that such information will only be used in accordance with this privacy policy and statement (“Privacy Policy”). This Privacy Policy sets out how the COMPANY and its Related Companies uses and protects any information that is provided by all individual who is the subject of the personal data whom information is collected, stored and processed by COMPANY or its Related Companies (hereinafter known as “you” or “your”).

This Privacy Policy shall be read together with the Terms of Use of this StreetPaw Website and App (available at this link: http://streetpaw.com/privacy). If you do not accept the Terms of Use (including any changes), please discontinue your access to the StreetPaw Website and App. The COMPANY reserves the right to change, amend, vary, update or substitute any portion of this Privacy Policy from time to time without any prior notice. Kindly check our StreetPaw Website and App for the most updated version of the Privacy Policy.

All capitalised terms in this Privacy Policy are defined at the ‘Definition’ section set out at the end of this document. The COMPANY may change this Privacy Policy from time to time by updating this page. You should check this page from time to time to ensure that you are updated with any changes.

1. COLLECTION OF PERSONAL DATA(a) In performing the Services, we may collect your personal data as defined under the Act including but not limited to the following information that you have or will provide:(i) personal particulars including name, age, race, date of birth;(ii) contact information including address, phone number and email address;(iii) education and employment background;(iv) banking information; and(v) other personal information relevant to advertising, customer surveys, statistical analysis and/or promotions. (collectively, hereinafter referred to as “Personal Data”.)(b) We may collect your Personal Data directly from you including but not limited to the following:-(i) when you communicate with us, our Related Companies, our Representatives, the Merchants or any persons on behalf of the Merchants;(ii) when you engage us, our Related Companies, or the Merchants for the Services and/or register your interest or request for information of the Services or Merchant’s Deliverables (through any available channels);(iii) when you use or browse our StreetPaw Website and App;(iv) when you visit the Merchant’s business premises or offices;(v) when you participate in any of our surveys or feedback or respond to any marketing materials sent by us, our Related Companies or our Representatives (whether in hard copy, verbally or electronically);(vi) when you commence a business relationship with us or our Related Companies (for example, as a service provider/business partner);(vii) when you are in a job application process to become our or our Related Companies’ employee or become employed by us or our Related Companies; and(viii) when you lodge any complaint with us, our Related Companies or our Representatives.(c) Other than Personal Data obtained from you directly, we may also obtain your Personal Data from third parties that we deal with or are connected with you including from such other sources where disclosure of your Personal Data is consented by you and/or where otherwise lawfully permitted.(d) Further, kindly note that by using our StreetPaw Website and App, we may collect your Personal Data particularly via your IP address which is used to help identify you including your membership information and your demographic information. Your IP address helps us or our service provider diagnose problems with our server, and to administer our StreetPaw Website and App. Personal Data may also be collected from the use of cookies. Please refer to the section below on the ‘Use of Cookies’ for further information.

2. USE AND PURPOSE OF YOUR PERSONAL DATA(a) With your consent, your Personal Data that you have provided or will provide to us (or our Related Companies or our Representatives) will be used, collected, obtained, recorded, stored, retained and processed by us, our Related Companies or our Representatives or on our behalf for various purposes including but not limited to the following purposes:-(i) performing the Services and to communicate with you about your orders, the Merchants or the Merchant’s Deliverables, enquiries on the Services and/or Merchant’s Deliverables and any other related or non-related requests;(ii) for preparing any document or instrument which may be required for the purposes set out in sub-paragraph (i) above and such other ancillary work or services in connection with sub-paragraph (i) above, including but not limited to preparing the necessary contract or agreement or instrument to which you are a party or a party having interest in the matter(s);(iii) for our internal processes, billing, invoicing, registration, renewals, appeals, complaints, research and development, administrative purposes or any other purpose relating to the Services;(iv) carrying out the obligations and/or transactions that you have requested, agreed or authorised us and/or our Representatives to do;(v) delivery of notices and/or marketing, promotional and advertising materials whether or not related to the Services and/or the Merchants including providing you information about our past, current and/or future Services, promotional materials, season greeting cards, newsletters, articles, write-ups, updates, policies, promotions, vouchers, events, conferences, workshops, talks, courses and seminars;(vi) requesting additional information or feedback from you about the Services or the Merchants including conducting surveys, statistical analysis or research in relation to the Services or the Merchants;(vii) compliance with our obligations under law or any regulations imposed by regulatory or governmental authorities;(viii) in order to protect the vital interests of another person, in a case where your consent or consent on your behalf has been unreasonably withheld;(ix) for marketing, business strategy, advertising and promotional purposes;(x) for the administration of justice, to obtain legal advice or to establish, exercise or defend legal rights in any legal proceedings; and/or(xi) such other purposes which may be required by us from time to time (collectively, the “Purpose”).(b) As soon as practicable (in any case before we use the personal data other than for the purpose the Personal Data was collected), we shall by written notice inform you:-(i) that your Personal Data is being processed by us or on our behalf;(ii) the purposes for which the Personal Data is being or is to be collected and further processed;(iii) of any information available to us as to the source of that Personal Data;(iv) of your right to request access to and to request correction of the Personal Data and how to contact us with any inquiries or complaints in respect of the Personal Data;(v) of the class of third parties to whom we disclose or may disclose the Personal Data;(vi) of the choices and means that we offer to you for limiting the processing of the Personal Data;(vii) whether it is obligatory or voluntary for the you to supply the personal data; and(viii) where it is obligatory for you to supply the Personal Data, the consequences if you fail to supply the Personal Data.(c) Kindly note that you may, by notice in writing withdraw your consent to the processing of your personal data at any time. The COMPANY and its Related Companies shall, upon receiving such notice cease the processing of your Personal Data.

3. TRANSFER OF PERSONAL DATA OUTSIDE MALAYSIA(a) We may be required to transfer your Personal Data outside Malaysia if, for instance:-(i) any of our Merchants, service providers or strategic partners (“overseas entities”) who are involved in providing part of the Services are located in countries outside Malaysia; and/or(ii) you use the StreetPaw Website and App from a country other than Malaysia.(b) In such circumstances, you consent to us transferring your Personal Data outside Malaysia. To the extent practicable, reasonable steps will be taken to ensure that any such overseas entities are contractually bound not to use your Personal Data for any reason other than to provide the services or product they are contracted to provide.

4. SECURITY OF PERSONAL DATA(a) When processing Personal Data, we will ensure practical steps are taken to protect your Personal Data from any loss, misuse, modification, unauthorised access or disclosure, alteration or destruction.(b) To the best of our ability, we have put in place suitable practical measures to safeguard and secure the information that we collect from you. We will only disclose Personal Data to our Representatives, our Related Companies, the Merchants, Merchant’s Related Companies and the Merchant’s Representatives only on a need to know basis and our Representatives are required to maintain confidentiality of such Personal Data.

5. RETENTION OF PERSONAL DATA(a) COMPANY and/or its Related Companies shall keep records of the Personal Data for as long as the necessary processes for the Purpose is required. However, in line with the retention principle under the Act, we will not keep the Personal Data processed for any Purpose for any period longer than is necessary for the fulfilment of that Purpose.(b) Where possible, we shall endeavour to take reasonable steps to ensure that all Personal Data is destroyed or deleted if it is no longer required for the Purpose for which it was to be processed.

6. YOUR ACCESS TO INFORMATION AND CORRECTION OF PERSONAL DATA(a) You shall be responsible to ensure that all Personal Data provided to and processed by COMPANY, its Related Companies, the Merchants and the Merchant’s Related Companies are accurate, complete, not misleading and updated. In the event you may need to provide us with Personal Data relating to third parties, you confirm that you have (i) obtained their consent or otherwise entitled to provide their Personal Data to us and for us to use accordingly, and (ii) informed them to read this Privacy Policy at our StreetPaw Website and App.(b) However, in the event you discover that any of your Personal Data is inaccurate, incomplete, misleading or not updated in whole or in part, you may in accordance with our internal procedures request in writing for access to be given and correction to be made to your Personal Data held by COMPANY, its Related Companies, the Merchants and the Merchant’s Related Companies (please refer to our contact details in the relevant section below). We will use reasonable efforts to comply with your request to access or correct your Personal Data within twenty-one (21) days of receiving your request and the relevant processing fee.(c) Kindly note that, in accordance with the Act, we and/or our Related Companies may refuse to comply with your data access request under certain circumstances as prescribed under the Act including the following situations:-(i) we and/or our Related Companies are not supplied with such information as we or our Related Companies may reasonably require in order to satisfy ourselves as to your identity as the requestor or a relevant person; or(ii) we and/or our Related Companies are not supplied with such information as we and/or our Related Companies may reasonably require to locate the personal data to which the data access request relates;(iii) the burden or expense of providing access is disproportionate to the risks of your privacy in relation to the Personal Data in question;(iv) we and/or our Related Companies cannot comply with the data access request without disclosing personal data relating to another individual who can be identified from that information, unless—(A) that other individual has consented to the disclosure of the information to the requestor; or(B) it is reasonable in all the circumstances to comply with the data access request without the consent of the other individual;(v) any other data user controls the processing of your Personal Data in such a way as to prohibit the us or our Related Companies from complying, whether in whole or in part, with the data access request;(vi) providing access would constitute a violation of an order of a court;(vii) providing access would disclose confidential commercial information; or(viii) such access to your Personal Data is regulated by another law.

7. RIGHT TO PREVENT PROCESSING FOR PURPOSES OF DIRECT MARKETING(a) Except where otherwise requested or notified by you, we or our Related Companies, the Merchants and/or the Merchant’s Related Companies may use your Personal Data for the purpose of Direct Marketing and we or our Related Companies may use your Personal Data to send promotional information about third parties which we believe may be of interest to you.(b) However, you may at any time by written notice to us require us to cease or not to begin processing your Personal Data for purposes of Direct Marketing. Please refer to our contact details in the relevant section below.

8. USE OF COOKIES(a) Our StreetPaw Website and App may use cookies, a small file which is placed on your computer's hard drive whereby with your consent the file is added and such file helps analyse web traffic or your history of visiting a particular website as well as gathering and remembering information about your preferences. We may use cookies to help us analyse data about web page traffic and improve our StreetPaw Website and App in order to tailor it to user’s needs.(b) While most web browsers automatically accept cookies, please note that you may choose to accept or decline cookies by modifying your browser setting to decline cookies. However, this may prevent you from taking full advantage of the StreetPaw Website and App.

9. LINKS TO OTHER WEBSITES(a) For ease of browsing, we may include links in our StreetPaw Website and App to enable you to visit other third parties’ websites. Once you have clicked on these links, you will leave our StreetPaw Website and App and we may no longer have control such other StreetPaw Website and Apps.(b) Where you have left our StreetPaw Website and App for another link, this Privacy Policy shall no longer be applicable and COMPANY and/or our Related Companies shall not be responsible for the privacy and the protection of any information including your Personal Data. Such other website may have its own applicable privacy policy and you should read such privacy policy to determine how your Personal Data is dealt with.

10. OUR CONTACT DETAILS
If you have any questions, concerns, complaints or requests in respect of this Privacy Policy or your Personal Data including to limit the processing of your Personal Data or to access and request for correction of your Personal Data, please do not hesitate to contact us at the following contact point:-

Designated person: PDPA OFFICERPhone Number: +6012 668 7319Email: support@streetpaw.comAddress: 1228, Lobby 6, Level 12, Block A, Damansara Intan Business Park, Jalan SS 20/27, 47400 Petaling Jaya
11. DEFINITION:“Act” means the Personal Data Protection Act 2010 including regulations, orders, notifications and other subsidiary legislation made under the Personal Data Protection Act 2010;“Direct Marketing” means the communication by whatever means of any advertising, promotional or marketing material which is directed to particular individuals;“Merchants” means all the merchants and their related businesses which are listed on or form part of StreetPaw Website and App;“Merchant’s Deliverable” means the product and/or services to be delivered and/or performed by the Merchant in accordance with the booking, purchase and/or order made by any persons or entities that use, view, access and/or browse the StreetPaw Website and App;“Merchant’s Related Companies” means Merchant’s related corporations, holding companies, associated companies, subsidiaries companies, affiliates, branches or business partners;“Merchant’s Representatives” means employees, directors, officers, representatives, associates, affiliates, agents, advisers, auditors, financiers, insurers and service providers of the Merchant and the Merchant’s Related Companies;“StreetPaw Website and App” means:-(a) www.streetpaw.com and/or direct subdomains, subpages, redirected subdomains, subpages, mobile applications and any other web display pages directly and indirectly correlated to www.streetpaw.com;(b) any other StreetPaw Website and App, domain, subdomain, webpage, subpage or mobile applications which has been set up, and/or is being maintained or operated, by Company or any of its Related Companies which replaces or is intended to replace or substitute any of www.streetpaw.com;(c) the mobile applications which provides, hosts and maintains all the services by Company or its Group under the brand name StreetPaw; and/or(d) the Restricted Site and/or direct subdomains, subpages, redirected subdomains, subpages, mobile applications and any other web display pages directly and indirectly correlated to the Restricted Site, which provides, hosts and maintains all the information and contents provided by Company and/or its Related Companies.“Personal Data” has the meaning ascribed to it in section 1(a) above;“Purpose” has the meaning ascribed to it in section 2(a) above;“Related Companies” means COMPANY’s related corporations, holding companies, associated companies, subsidiaries companies, affiliates, joint venture entities, branches and business partners;“Representatives” means employees, directors, officers, representatives, associates, affiliates, agents, advisers, auditors, financiers, insurers and service providers of the COMPANY and its Related Companies; and“Services” means any function, feature, access to and use of the internet, internet information and/or other services through the StreetPaw Website and App which includes but is not limited to, online transactions, e-commerce transaction, search engines, automated services, chat, discussion groups and/or e-mails, any Merchant Deliverables and other online products and/or services offered by Company or its Group and/or the Merchants.