Privacy Policy

The MyTreats Privacy Policy was updated on November 16, 2020.

Your privacy is important to MyTreats so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal information.

In addition to this Privacy Policy, we provide data and privacy information imbedded in our products connected with our Data & Privacy icon for certain features that ask to use your personal information.

You can review this information before enabling these features, in Settings related to those features and/or online at www.mytreatsasia.com/privacy-policy. Please take some time to familiarize yourself with our privacy practices and contact us if you have any questions.

Collection and Use of Personal Information

Personal information is data that can be used to identify or contact a single person.

You may be asked to provide your personal information anytime you are in contact with MyTreats or any of MyTreats affiliated company. MyTreats and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of the types of personal information MyTreats may collect and how we may use it.

What personal information we collect

When you create a profile as a user or member in MyTreats mobile application after as successful subscription process for the membership (applicable for signed-up members), we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information, debit card information and profile information where the contact is via social media.

When you use MyTreats mobile application for the purpose of sharing your invitation link with anyone in your contacts, or when anyone in your contacts has used your invitation link that contains your referral code to become a member, or when any member transfer or receive Treats points from you, requesting an item in the Wishlist’s section, MyTreats may collect the information you provide about those people such as name, status, account type, last active, last redemption, total redemption, date joined, membership date, expiration date, date of birth, gender, email address, phone number, mailing address, up-line member, Tier 1 / 2 / 3, total amount of Treats points, total number of referrer and referee and Wishlist’s information. MyTreats may use such information to fulfil your requests, provide the relevant product or service, or for anti-fraud purpose.

In certain jurisdictions, we may ask for a government issued ID in limited circumstances including when setting up a MyTreats account either as a user or a member for the purpose of extending commercial credit, managing reservations, or as required by law.

How we use your personal information

We may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which MyTreats is subject, for the performance of a contract to which you are party, in order to protect your vital interests, or when we have assessed it is necessary for the purposes of the legitimate interests pursued by MyTreats or a third party to whom it may be necessary to disclose information. If you have questions about this legal basis you can contact our Data Protection Officer.

The personal information we collect allows us to keep you posted on MyTreats’ latest product announcements, mobile application updates, and upcoming events. If you don’t want to be on our mailing list for such announcements and notifications on updates, you can opt-out anytime by updating your preferences.

We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes.

We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users, and pre-screening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.

Where we use your information for anti-fraud purposes, it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services.

For certain online transactions we may also validate the information provided by you with publicly accessible sources.

We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of MyTreats account holders.

From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with MyTreats, you may not opt out of receiving these communications.

We may also use personal information for internal purposes such as auditing, data analysis, and research to improve MyTreats’ mobile application and the products and services provided by third party merchants, and customer communications.

If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs.

If you apply for a position at MyTreats or we receive your information in connection with a potential role at MyTreats, we may use your information to evaluate your candidacy and to contact you. If you are a candidate, you will receive more information about how MyTreats handles candidate personal information at the time of application.

Source of your personal information where they are not collected from you

We may have received your personal information from other persons if that person has shared their content with you using MyTreats platforms (mobile application, and website), transferred points or gifts or superdeals, or invited you to subscribe as a MyTreats member or any participation in MyTreats’ educational work courses. We may also validate the information provided by you when creating a MyTreats account using MyTreats mobile application, with a third party for security and fraud prevention purposes.

If you are a potential candidate for employment with MyTreats, we may have received your personal information from third parties such as recruiters or external websites. We will use the personal information we receive to contact you about a potential opportunity or in evaluating your candidacy. If you did not provide us your personal information directly, we will inform you of the source when we first contact you regarding your candidacy. For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to re-identify individuals who may appear therein.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

We may collect information such as occupation, language, zip code, area code, location, and the time zone where MyTreats mobile application is used so that we can better understand the customer behavior and improve our products, services, and advertising.

We may collect information regarding customer activities on our website, App Store, Play Store, Huawei App Gallery and from our other merchants whom providing MyTreats with the products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered nonpersonal information for the purposes of this Privacy Policy.

We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.

With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Cookies and Other Technologies

MyTreats’ websites, online services, mobile application, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us to better understand user behaviour, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as nonpersonal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

Ads that are delivered by MyTreats’ advertising platform may appear in any communication platform such as social media and in the App Store / Play Store / Huawei App Gallery. If you do not wish to receive ads targeted to your interests from MyTreats’ advertising platform, you can choose to enable Limit Ad Tracking, which will opt your MyTreats account out of receiving such ads regardless of what device you are using. If you enable Limit Ad Tracking on your mobile device, third-party apps cannot use the Advertising Identifier, a non-personal device identifier, to serve you targeted ads. You may still see ads in the App Store or Play Store or Huawei App Gallery and communication platforms such as social media platforms based on context like your search query or the channel you are reading. In third-party apps, you may see ads based on other information.

MyTreats also uses cookies and other technologies to remember personal information when you use our website and mobile application. Our goal in these cases is to make your experience with MyTreats more convenient and personal. For example, knowing your first name lets us welcome you the next time you renew your account with MyTreats using MyTreats mobile application. Knowing your country and language − and if you are an educator, your school − helps us provide a customized and more useful and entertaining shopping experience.

Knowing someone using your device with your MyTreats account, has shopped for a certain product or used a particular service provided in the MyTreats mobile application, helps us to make our advertising and email communications more relevant to your interests. And knowing your contact information, hardware identifiers, and information about your computer or device in using the MyTreats mobile application helps us to personalize your operating system and provide you with better customer service.

If you want to disable cookies, you may select option from the browser you’re using to search about MyTreats in the browser’s preferences, then to the privacy pane to manage your preferences. On your mobile device, go to Settings, scroll down to the Privacy & Security section, and tap on “Block Cookies” to manage your preferences. Every browser of different type of device used to use the MyTreats app or search about MyTreats, do check with your provider to find out how to disable cookies. Please note that certain features of the MyTreats mobile application or those in MyTreats’ websites may not be available once cookies are disabled.

As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date / time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behaviour on the site, to improve our mobile application, websites as well as the product and services provided, and to gather demographic information about our user base as a whole. MyTreats may use this information in our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the MyTreats website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

Disclosure to Third Parties

At times, MyTreats may provide third parties with certain personal information to provide or improve our products and services, including to deliver products at your request, or to help MyTreats market to consumers. When we do, we require those third parties to handle it in accordance with relevant laws. MyTreats does not sell personal information, and personal information will never be shared with third parties for their marketing purposes. For example, when you make a purchase on the membership, you authorize MyTreats and your carrier to exchange the information you provide during the activation process to carry out service and to start enjoy features in the MyTreats mobile application as a member, including information about your device. If you are approved for service, your account will be governed by MyTreats and your carrier’s respective privacy policies.

Service Providers

MyTreats shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever MyTreats operates.

Others

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for MyTreats to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.  This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Protection of Personal Information

When your personal data is stored by MyTreats, we use Amazon Cloud Server and computer systems with limited access housed in facilities using physical security measures. MyTreats’ members data is stored in encrypted form including when we utilize third-party storage.

When you use your MyTreats account, or participate in any of MyTreats webinars or chat in live-streaming, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

The Existence of Automated Decision-Making, Including Profiling

MyTreats does not take any decisions involving the use of algorithms or profiling that significantly affect you.

Integrity and Retention of Personal Information

MyTreats provides hassle-free update for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service specific privacy summaries. When assessing these periods we carefully examine our need to collect personal information at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

Your Privacy Rights

You can help to ensure that your contact information and preferences are accurate, complete, and up to date by signing in to your MyTreats account using MyTreats mobile application. For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if MyTreats is not required to retain it by law or for legitimate business purposes.

We may decline to process requests that are frivolous / vexatious, jeopardise the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. Online tools for the exercise of access, deactivation/restriction, correction, or deletion requests are available on a regional basis by going to the Message Center feature in the MyTreats mobile application. When you make any request using MyTreats mobile application, or done via email or any communication methods, pertaining to the MyTreats mobile application, we will verify your identity and the legitimacy of your request.

Personal Data Protection Act 2010 (PDPA)

On 15 November 2013, the Personal Data Protection Act 2010 (PDPA) came into force in Malaysia with the objective of protecting the personal data of individuals with respect to commercial transactions. A commercial transaction is defined as a mutual agreement done between at least two parties in the exchange of items of value which normally involves money or some other remuneration for goods or services.

The Personal Data Protection Act 2010 (PDPA) was gazetted in June 2010, it is an Act that regulates the processing of personal data in regards to commercial transactions.

A penalty of between RM100,000 to RM500,000 and/or between 1 to 3 years imprisonment will be imposed on the non-compliance.

This Act will be applicable to any person / organization who collects and processes personal data in regards to commercial transactions.

There are 7 included in the Act which include:

  1. General

  2. Notice and choice

  3. Disclosure

  4. Retention

  5. Security

  6. Access

  7. Data integrity principle

Personal data relates directly or indirectly to a data subject, who is identified or identifiable from that information, or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject. For example: name, identity card number, date of birth, mobile number and etc.

In the case where personal data processing is outsourced to a third party, known as the data processor, it is the responsibility of the user to ensure that the data processor provides sufficient guarantee to protect the personal data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction.

This Act affects the personal data life cycle management process from the point personal data is collected, used, stored and destroyed.

This Act applies to customers, employees and third party service providers’ personal data.

A company’s way of doing business will definitely be affected as business processes are required to be refined to comply with the PDPA requirements.

Most importantly, a central repository may be required for consent management. The process becomes more complex when cross border personal data transfer is involved.

Children & Education

We understand the importance of taking extra precautions to protect the privacy and safety of children using MyTreats’ mobile application and the products and services provided within the mobile application. Children under the age of 18, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own MyTreats account, unless their parents provided verifiable consent or as part of the child account creation to be used, under supervision of the parents. Such inquiries can be forwarded to enquiry@mytreatsasia.com.

If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible. If at any time a parent needs to access, correct, or delete data associated with the supervision to be provided by them in letting the child to use the mobile application, they may contact us via email at enquiry@mytreatsasia.com.

Location-Based Services

To provide location-based services on MyTreats mobile application, MyTreats and our partners and licensees, such as maps data providers, may collect, use, and share precise location data, including the real-time geographic location of your the computer or device used in using MyTreats application and it’s communication platforms. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by MyTreats and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.

Some location-based services offered by MyTreats, such as the feature that can be found in the MyTreats mobile application, to direct users to the merchant’s location, require your personal information for the feature to work.

ThirdParty Sites and Services

MyTreats mobile application, websites, products and service provided (by the appointed merchants), may contain links to third-party websites, products, and services. Our mobile application that contain variety of different products and services provided by the appointed merchants may also use or offer products or services from third parties − for example, a thirdparty merchant’s app.

Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

If you purchase a MyTreats Membership subscription within the MyTreats mobile application, we create a Membership ID that is unique to you and the developer or publisher which we use to provide reports to the developer or publisher that include information about the subscription you purchased, and your country of residence. If you cancel all of your subscriptions with a particular developer or publisher, the Membership ID will suspended after 7 days and then, fully terminated if you do not re-subscribe. This information is provided to developers so that they can understand the performance of their subscriptions.

Our Companywide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to all MyTreats employees and strictly enforce privacy safeguards within the company, ITZ MyTreats Sdn. Bhd.

Privacy Questions

If you have any questions or concerns about MyTreats’ Privacy Policy or data processing, you would like to contact our Data Protection Officer, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us. You can always contact us by phone or email at the relevant Support in MyTreats website at http://www.mytreatsasia.com/contact.

When a privacy question or question about personal information received in response to an access / download request is received we have a dedicated team which triages your contact to address your issue. Where your issue may be more substantive in nature, more information may be required from you, to help us assist you on your issues. All such substantive contacts receive a response within seven (7) working days wherever possible – providing a response on the issue raised, requesting additional information where necessary or indicating that a response will require additional time. You may at any time refer your complaint to the relevant regulator in your jurisdiction if you are unsatisfied with a reply received from us. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

Where your complaint indicates an improvement could be made in our handling of privacy issues we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person we will take steps to address that with you or that other person.

MyTreats may update its Privacy Policy from time to time. When we change the policy in a material way, a notification / notice will be provided via MyTreats app inbox / email / will be posted on our website along with the updated Privacy Policy. We will also contact you via your contact information on file, for example by email, notification or some other equivalent method.