Last updated: [29 JAN 2025]

T-BROKER MARKETPLACE - PRIVACY POLICY

This Privacy Policy must be read before using the Website. By using any part of the Website, you confirm that you have read, understood, and accepted this Privacy Policy. The Marketplace website and platform (“Website”) is operated by Mal Central Travel Sdn. Bhd. (“we,” “us,” “our,” or “MCT”), including its affiliated companies and third-party operators (the “Operator”). The Website provides an online platform (“Marketplace”) for the marketing, advertising, and buying or selling of travel and tourism-related goods and services between registered users: Buyers and Vendors (collectively, “Users”). In this Privacy Policy, “you” and “your” refer to anyone who accesses the Website, including:
  1. Registered Users (Buyers or Vendors).
  2. Individuals acting on behalf of Buyers or Vendors.
If you do not agree to the terms of this Privacy Policy, please discontinue using the Website immediately.

Scope

This Privacy Policy outlines how we collect, use, disclose, and protect your personal data when you use our website and services. By accessing and using this Website, you acknowledge and agree to this Privacy Policy. If you do not agree with any part of this policy, please discontinue use immediately.

Changes to privacy policy

We reserve the right to amend or update this Privacy Policy at any time, as required to comply with applicable laws, regulations, or to reflect changes in our operational practices. Any modifications will take effect immediately upon being published on this Website. By continuing to use the Website after any updates, you acknowledge and agree to be bound by the revised terms. Please note that if you navigate from this Website to a third-party website, the privacy policy of that third-party website will govern your use of their services. We are not responsible for the privacy practices or policies of any third-party websites, and we recommend that you review their privacy policies carefully.

How Information is Obtained

Personal data refers to any information that directly or indirectly relates to you and allows you to be identified as an individual. Depending on the circumstances, we may collect and store various types of personal data about you, including:
    1. Information You Provide to Us:
      • Name, gender, national identification details, date of birth, email address, delivery/billing address, and contact details.
      • Information submitted during bookings or transactions, such as payment details, passport details for VISA applications, or other travel services.
      • Account security credentials, such as usernames and passwords.
      • Information submitted through forms, surveys, campaigns, or contests on the Website, for example, to request additional services or provide feedback.
      • Preferences related to your use of our products and services, such as personalization settings.
    2. Information Automatically Collected:
      • Technical Data: Internet protocol (IP) address, browser type, and operating system details, which help us enhance your experience on the Website.
      • Log Data: Records of your visits, including the date, time, duration, and location of access, as well as searches, orders, and the content you interact with. This helps us understand user behavior and improve our Website.
      • Cookies: We use cookies to improve your experience and analytics. Cookies allow us to store data on the device you use to access our Website. While you may block cookies in your browser settings, this may limit your access to certain features. Refer to your browser’s settings for instructions on managing cookies.
    3. Additional Information:
      • Communications sent to us, such as reports of issues, inquiries, or suggestions.
      • Any further information we may request as part of the user authentication process or when required to verify your account details.
Verification and Documentation: We reserve the right to request additional documentation to verify the accuracy of the information you provide. If you choose not to provide requested information that we consider essential, or if you object to the collection or processing of such information, we may be unable to provide you with our products and services. Sharing Third-Party Data: If you disclose personal data about another individual, we rely on your representation that you have obtained their consent for us to collect, use, and process their information as outlined in this Privacy Policy.

How Information is Used

In addition to providing you with our products and services, we may use or disclose the personal data we collect about you for the following purposes:
    1. Service Provision:
      • To deliver the products, services, and information you request from us.
      • To assist with and process transactions or communications with third parties via the Website.
      • To maintain and manage your user account.
    2. Customer Support and Communication:
      • To assist with inquiries and improve customer support.
      • To communicate with you regarding your account, transactions, or services.
    3. Compliance and Verification:
      • To carry out “Know Your Customer” (KYC) processes for identity verification and authentication purposes.
      • To evaluate credit and risk profiles as required for transactions.
      • To comply with legal and regulatory obligations.
    4. Analytics and Improvement:
      • To analyze user behavior and improve products, services, and user experience.
      • To measure the effectiveness of advertising and deliver relevant advertisements to you.
      • To provide you with a personalized, smooth, and efficient experience.
      • To make recommendations or suggestions about products or services that may interest you.
    5. Operational Purposes:
      • To manage billing and account-related matters.
      • To support internal operations, including troubleshooting, data analysis, testing, research, statistical purposes, audits, and surveys.
      • To optimize and present Website content in the most effective way for you and your device.
    6. Safety and Security:
      • To ensure the safety and security of the Website and its users.
      • To enforce the Marketplace Terms of Use or other applicable terms and conditions.
    7. Business and Legal Transactions:
      • To manage or facilitate business asset transactions or potential business asset transactions.
      • To maintain and strengthen business relationships if you are a customer or user of the Website and Services.
Disclosure to Third Parties: In limited circumstances, we may disclose collected information, including personal data, to third parties to provide the Services or comply with legal obligations. For example, we may share information with business partners, regulators, or authorized parties as required by law. Use of Non-Personal Data: We may use non-personal data, such as aggregated statistics or Website performance metrics, to evaluate and improve our Services. As non-personal data cannot identify you, its use or disclosure is unrestricted.

Sharing Your Information

As a necessary part of providing our products and services, we may share your data with trusted third parties for the purposes outlined in this Privacy Policy. These disclosures include, but are not limited to:

    1. Affiliates and Service Providers:
      • We may disclose certain personal data to our affiliates, third-party service providers, agents, and contractors (e.g., payment processors, IT support, or mailing handlers).
      • These parties will only use your personal data to perform services on our behalf and must comply with applicable data protection laws.
    2. Legal Requirements:
      • Under limited circumstances, we may cooperate with legal investigations or be subject to legal requirements to disclose data collected through the Website or Services.
      • This may include disclosures to courts, governmental agencies, or regulatory authorities, as required by law.
      • Our policy is to fully comply with all such legal obligations.
    3. Fraud and Security:
      • We may disclose personal data to protect or defend the rights or property of MCT (or its licensors) or users of the Services.
      • This includes investigating violations of the law, this Privacy Policy, or the Marketplace Terms of Use, as well as exchanging information with other companies for fraud protection and credit risk reduction.
    4. Professional Advisors and IT Support:
      • We may share your data with third parties who support our information technology systems, handle mailings, or provide professional advice (e.g., legal or financial advisors).
    5. Trusted Vendors for Bookings:
      • We may share your data with trusted travel vendors to facilitate bookings and related services.
      • While vendors are required to comply with booking protocols, standardized data security agreements may not always be in place.
      • We aim to ensure your data is handled appropriately.
    6. Non-Personal Data:
      • We may use and disclose non-personal data (e.g., aggregated statistics or performance metrics) without restriction.
      • Such data cannot be used to identify you personally.

Data Retention

We retain your personal data indefinitely unless you request its deletion. This retention is necessary to provide ongoing services and maintain business operations. Users may request data deletion at any time by contacting their assigned salesperson or using the contact methods provided in this Privacy Policy. If you choose to delete your account or data, please note that we may still retain certain information as required to comply with legal obligations, resolve disputes, or enforce agreements. When retention is no longer necessary, we will securely delete or anonymize your data.

Security

We implement a range of administrative, technical, and physical safeguards to ensure the security and integrity of your personal data. These measures include, but are not limited to, access controls, encryption, and regular security audits.
    1. Data Protection and Access Controls
      • We apply industry-standard security protocols to prevent unauthorized or accidental access, loss, theft, misuse, alteration, or destruction of personal data.
      • Access to your personal data is strictly limited to authorized personnel on a need-to-know basis, in accordance with our corporate security policies.
    2. Encryption and Secure Transmission
      • While we take reasonable steps to protect your data, please note that no method of data transmission over the internet is 100% secure.
      • We use encryption and secure communication protocols to enhance the protection of your personal information.
    3. Account Security and User Responsibility
      • Some sections of this Website may require a username and password for access.
      • To protect your account, we strongly recommend that you:
        • Keep your login credentials confidential.
        • Use strong, unique passwords.
        • Change your password regularly, if required.
      • You are solely responsible for any unauthorized access or activities that occur under your account due to failure to maintain the confidentiality of your login credentials.
    4. Ongoing Security Monitoring
      • We conduct regular security assessments and audits to identify vulnerabilities and improve data protection.
      • If we detect any security breaches that may impact your personal data, we will take appropriate actions as required by law.

Third-Party Links

This Website may contain links to third-party websites that we believe may be of interest to you. However, these external websites operate independently and are governed by their own privacy policies and terms of use.
    1. User Responsibility
      • When you navigate to a third-party website, you acknowledge that their privacy policies and security practices apply.
      • We strongly encourage you to review the privacy policies of any external websites before providing them with your personal information.
    2. No Endorsement or Liability
      • The inclusion of a third-party link on our Website does not constitute an endorsement, approval, or association with that website or its operators.
      • We do not control, and are not responsible for, the content, security, or data handling practices of third-party websites.
    3. Risk Awareness
      • Your interactions with third-party websites, including the sharing of personal data, are at your own risk.
      • We disclaim any liability for any issues that may arise from your use of external websites, including but not limited to, data misuse, security breaches, or fraudulent activities.

Access to Your Information

Depending on the features available on the Website, you may be able to access, update, or manage your personal information through your user account settings. Access may be subject to authentication and security measures to protect your data.
    1. Managing Your Information
      • You may have the ability to access, update, or manage your personal information through your user account settings.
      • Access to your data may require authentication and security measures to protect your information.
    2. Requesting Access or Corrections
      • If you wish to request:
        • Access to personal data we hold about you.
        • Correction of inaccurate or outdated information.
      • Please refer to the “Contact Details” section below for instructions on submitting your request.
      • Requests will be processed in accordance with applicable data protection laws and our internal policies.

Contact Details

If you have any questions or concerns about this Privacy Policy or your personal data, you may contact our Privacy Officer using the details below.
    1. Reasons to Contact Us
      • Request access to or correction of any personal data we hold about you.
      • Withdraw your consent for specific data processing activities (subject to legal or contractual obligations).
      • Make a complaint regarding how we handle your personal data.
      • Raise any other inquiries related to your personal information.
    2. Processing Your Request
      • We will process your request in accordance with applicable data protection laws.
      • The information we provide in response may be limited as required by law.
      • Withdrawing consent for certain uses of your data may impact our ability to provide services or fulfill requests. If this applies, we will inform you of the consequences based on the specific type of data.
    3. Contact InformationFor any inquiries, please contact our Privacy Officer at: [email protected]

Prevailing language

This Privacy Policy is available in both English and Bahasa Malaysia. In the event of any inconsistencies or discrepancies between the two versions, the English version shall prevail and will be the authoritative text for resolving any disputes, to the extent permitted by law.