Thank you for your continuous support to FingerTec. At FingerTec, we respect your privacy. Hence, we've developed the FingerTec Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal data. It is formulated in accordance with the Personal Data Protection Act 2010 ("Act") of Malaysia and also designed to comply with the EU General Data Protection Regulation (GDPR).

Please read this Privacy Policy to understand how we use the personal information we may collect from you.

If you use our Website and Services, you consent to this Privacy Policy, including our Cookies Policy.

Consent
If you use our Website and Services, you consent to the collection, use and sharing of your personal data under this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy). We provide you choices that allow you to opt-out or control how we use and share your data.

We may modify this Privacy Policy from time to time. If we make material changes to it, we will provide notice through our Website, or by other means (e.g. notice posted on our Facebook page along with the updated Privacy Policy), to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may withdraw your consent by contacting the FingerTec Team with the contact details provided below. Your continued use of our Website and Services after we publish or send a notice about our changes to this Privacy Policy means that you are consenting to the updated Privacy Policy.

In this Privacy Policy, you will understand:
• About Personal Information
• Who Collects and Processes Data Collected
• Information We Collect
• How We Use Your Data
• Data Disclosure
• Data Security
• Data Retention
• International Transfer of Information Collected
• Your Rights & Obligations
• Protection of Minors
• How to Contact Us

About Personal Information
Personal information refers to any information which relates directly or indirectly to you. This includes any information that can be used to distinguish, identify or contact you. For the purposes of this Privacy Policy, personal information encompasses sensitive personal information which relates to information relating to your health, political opinions, religious beliefs, etc. For the avoidance of doubt, please note that this Privacy Policy is applicable only if you are a natural person / an individual.

Who Collects and Processes Data Collected
FingerTec is the brand used for our products, services and website, which is owned by and managed under the company, TimeTec Computing Sdn. Bhd. TimeTec Computing is therefore the data controller (defined in the GDPR) for the processing of personal data collected from our Website and Services. If you have any questions on our use of your personal data, you can reach us with the contact details provided in the 'How to Contact Us' section below.

Information We Collect

•	We may collect a variety of personal information, including your name, mailing address, phone number, email address and contact preferences when you Communicate with us. This includes instances where you create a FingerTec member ID, register your products for warranty, purchase a product, download a software update, register for online training, participate in an online survey, register for our publications such as newsletters, complete online forms (including call back requests), post on our blogs, download information such as white papers or other publications or participate in any other interactive areas that appear on our website.
•	Personal data provided when you respond to any marketing materials we send out or when you contact us for any enquiries, including communication by telephone, email, chat services and social media.
•	Information about your computer or device used to access our Website, and about your visits to and use of our Website (including your IP address, geographical location, operating system, browser type, number of visits, average time spent on the site and pages viewed). The collected information is used to provide an overview of how people are accessing and using the FingerTec website and not for any additional purpose, such as to profile users. We may do this using cookies, web beacon or similar technologies. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes. To read more about how we use cookies, please read our Cookies Policy.
•	Details of the emails and other electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication. We use this to help ensure our communications are useful for you.
•	Personal data provided when you commence a business relationship with us such as being our service provider/business partner
•	Personal data provided when you lodge a complaint with us
•	Personal data provided when you provide feedback to us through websites or other channels
•	Other than personal information obtained from you directly, we may also obtain your personal information from third parties we deal with or are connected with you (credit reference agencies or financial institutions), and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted.

How We Use Your Data
We may collect and use personal data from you or from the category of third parties identified in this Privacy Policy, for one or more of the following purposes:

•	The personal information we collect allows us to conduct our internal marketing and promotional activities and keep you posted on FingerTec’s newsletters, upcoming events and etc. If you don’t want to be on our mailing list, you can opt out anytime using the links provided in the emails we send to you. Please refer to the section below on 'Your Rights' to object to processing for marketing purposes.
•	We also use personal information to help us develop, deliver, and improve our products, services, content, and advertising.
•	We may also use personal information for internal purposes such as auditing, data analysis, and research to improve FingerTec's products, services, and customer communications.
•	If you enter into a FingerTec contest, or similar promotion we may use the information you provide to administer those programs.
•	To establish and better manage any business relationship we may have with you
•	To process any communications you send us (for example, answering any queries and dealing with any complaints and feedbacks)
•	To produce data, reports and statistics which shall be anonymized or aggregated in a manner that does not identify you as an individual
•	To investigate, respond to, or defend claims made against, or involving TimeTec Computing Sdn. Bhd.
•	To maintain records required for security, claims or other legal purposes
•	To comply with legal and regulatory requirement
•	For any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities

Data Disclosure
As a part of providing you with FingerTec Website & Services, we may be required or need to disclose information about you to the following third parties:

•	Strategic partners that work with FingerTec to provide better products and services, or that help FingerTec market to customers. For example, when you inquire to buy a FingerTec product, FingerTec may send your email with your personal or non-personal information to Third Parties (Authorized Resellers in specified) for sales follow-ups. Personal information will only be shared by FingerTec to provide FingerTec products and services to you; it will not be shared with third parties for their marketing purposes.
•	companies and/or organisations that act as our agents, contractors, service providers (including their sub-contractors) and/or professional advisers
•	other parties in respect of whom you have given your express or implied consent
•	law enforcement agencies
•	government agencies
•	subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to FingerTec's Website & Services
Please note that FingerTec uses data processors that collect, store and process your data on behalf of FingerTec. The selected processors offer all the appropriate guarantees with regard to technical and organizational security measures regarding the processing of your personal data. They are used for the following purpose:
•	Hosting of our customer relationship management system,
•	Enabling payments,
•	Enabling user support functionalities, such as website chat rooms,
•	Enabling visit and usage analytics

Data Security
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use non SSL and SSL technology to encrypt data during transmission through public internet, to be only accessed by those authorized with special access rights to our systems.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.

If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

Data Retention
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. We will retain and use this personal information as necessary to comply with our legal obligations, maintain accurate financial and other records, resolve disputes, and enforce our agreements.

International Transfer of Information Collected
Our company is based in Malaysia and we use IT and other service providers which are located in multiple countries. Our website may be hosted in Malaysia and when you send an email to us, this will also be stored on our email servers in Malaysia. Your information collected by FingerTec may be stored and processed in Malaysia, Singapore, the United States, Europe, or any other country in which FingerTec or its affiliates or service providers maintain facilities.

When submitting your personal data, you are agreeing to such processing, transfer or storage as outlined above. We will ensure at all times to take all reasonable steps necessary to maintain the security of your personal data in accordance with this Privacy Policy. We shall also take reasonable steps to ensure that any such third party entities are contractually bound not to use your personal information for any reason other than to provide services that are agreed in their contract and to adequately safeguard your personal information.

For personal data that is subject to European data protection laws, this means that any information which is submitted by you through the website may be transferred to Malaysia, Singapore, the United States or to other territories outside of the EEA. We may also transfer your information to service providers outside the EEA for the purpose of providing our services and advertising to you.

We take steps to ensure that where your information is transferred outside of the EEA to our service providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on certification of compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework or the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.

By using our website, products or services or by interacting with us in the ways described in this Privacy Policy, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Policy. If you do not want your information to be transferred outside the EEA you should not use our website or services.

Your Rights & Obligations
Right to Access, Correction, Deletion, Data Portability
We can assist you to access, correct or delete your personal information held by us. Where you wish to have access to your personal information in our possession, wish to amend or to delete your information, you may make a request to us by contacting FingerTec Team with the contact details provided below. You should quote your name, address and phone number and provide brief details of the information you want a copy of in any such request. We will use reasonable efforts to comply with your request to access, correct or delete your personal information within 30 days of receiving your request. We will fulfil your request by sending your copy electronically, unless the request expressly specifies a different method. Please note that we may have to withhold access to your personal information in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event 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.

Restriction of Processing, Object to Processing & Withdraw Consent
At any time, you may request to place restrictions on processing or object to the processing of your Personal Data, on legitimate grounds, except if it's otherwise permitted by applicable law. You may at the time of collection and at any later time, oppose the processing of your personal data for the purposes of marketing. Where the processing of your information is based on your consent, you have a right to withdraw that consent subject to legal or contractual restrictions.

If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us with the contact details provided below. You also have a right to lodge a complaint with data protection authorities.

Incomplete Personal Information
Where indicated (for example in registration/application forms), it is obligatory to provide your personal information to us to enable us to process your application for FingerTec Website & Services. Should you decline to provide such obligatory personal information, we may not be able to process your application or provide you with FingerTec Website & Services.

Your Obligations
You are responsible for providing accurate and complete information to us about yourself and any other person whose personal information you provide us and for updating this personal information as and when it becomes incorrect or out of date by contacting the FingerTec Team via the contact details provided below. This obligation is a condition to the provision of FingerTec Website & Services to you and/or any other person authorised or permitted by you or your organisation/company to use the Products and/or Services. In the event you may need to provide us with personal information relating to third parties (for example about your spouse or children or where you are the designated person in charge (from an organisation or company) for dealing with us, if you are acquiring and are responsible for a service and/or product that they will use), you confirm that you have (i) obtained their consent or otherwise entitled to provide their personal information to us and for us to use accordingly, and (ii) informed them to read this Privacy Policy at our website.

Protection of Minors
As a general rule, children and persons under the age of 18 years should not disclose personal data to us without the consent of their parents or guardians. We do not solicit personal data from children and we do not knowingly collect personal data from children, use said data in any way or disclose said data to third parties without authorization.

How to Contact Us
If you have requests and questions or concerns about FingerTec Privacy Policy, please contact us at:
TimeTec Computing Sdn. Bhd.
No. 6, 8 & 10, Jalan BK 3/2
Bandar Kinrara
47180 Puchong
Selangor, Malaysia
Tel: +603 - 8070 9933
Email: info@fingertec.com

Last updated: May 15, 2018