Legal Notice

By accessing this MACROKIOSK's World Wide Web (“the Website”), you acknowledge and agree to be bound by the following terms and conditions ("T&C"). You must not access the Website if you do not agree to the T&C.

i. Disclaimer

MACROKIOSK group of companies and its related companies ("MACROKIOSK") reserves all its rights on the information contained in the Website. All rights of reproduction, transfer, distribution or storage of part or all of the content in the Website in any form without the prior written permission of MACROKIOSK is strictly prohibited unless otherwise agreed by MACROKIOSK in writing. The information on this Website server is provided on an "as is" basis. No warranty or representation of any kind, either by way of express, implied or otherwise; including but not limited any implied warranty in relation to the reliability, accuracy, and completeness of the content of the pages and technical inaccuracies or typographical errors.

You are advised to visit this Website frequently to determine any changes to the T&C. MACROKIOSK assumes no responsibility for material created or published by third parties that the Website has a link to or such other materials contained in the Website which has not been verified or authenticated by MACROKIOSK.

Your access to the Website is at your own consent and subject always to the T&C herein. MACROKIOSK shall not be responsible for any damages suffered as a result of your use of the information and contents contained in this Website, and in no event shall MACROKIOSK be liable for any direct, indirect, incidental, consequential, special, punitive or exemplary damages arising from your use of the Website.

If you have any questions or comments relating to our Legal Notice, please contact us.

Privacy Statement

This privacy statement represents the privacy policy applicable to all legal entities owned by MACROKIOSK. In the event of any changes to this privacy statement for the betterment of our services, we will post such changes here. Please read and understand this privacy statement before providing your information to us or using our services.

This privacy statement applies to macrokiosk.com and the websites of any MACROKIOSK’s legal entity and related online activities. Further, this privacy statement provides information to external data subjects who are not engaged or employed by MACROKIOSK, where the data subjects provide us with Personal Data, or we collect data as part of our normal business operations, from a third party service provider, contract partner, public sources, previous employers or organisations, trade fairs or communications channels such as email.

1. How and Why We Use Personal Data

    

   • Personal Data

     While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but not limited to:

     • Name (including but not limited to individual name or business entity registered name)

     • Personal identification details (including but not limited to passport details)

     • Email address

     • Phone number

     • Address, State, Postal Code, City

     • Banking details

     • Credit card or debit card information (including but not limited to card number, cardholder name, expiry date and CVC)

     • Preferred language

     • Preferred services or products

     • Other relevant information

      

   • When you visit our website

     When you visit MACROKIOSK website, we collect data through cookies to track the activity on our website. The data we collect through cookies consists of data relating to your device, IP address and your usage of the websites. We use the data collected through cookies to provide you with the best user experience and for improving the websites’ content by tracking usage patterns and recording preferences and for allowing you to log on to specific sites.

      

   • When you subscribe to a newsletter

     When you contact us, such as for business relations or interest, ordering products and services or in relation to projects, media or, investor contacts, supplier relations, sponsorships, or sign up for an event, we collect your Personal Data in order to enable us to meet your request or interest, provide support, or comply with contractual obligations or prepare to enter into a contract. When we have an existing customer relationship with you, we may also use your Personal Data to provide communication and direct market our products and services.

      

     MACROKIOSK uses the provider “MailChimp” to dispatch our newsletters. Your email address will be saved here, as well as information regarding the analysis of our newsletter. The newsletter is usually sent once a month. After receiving the first newsletter, however, you have the option to unsubscribe from the mailing list via an unsubscribe link in each newsletter.

      

   • When you apply for a job

     When you apply for a job in MACROKIOSK, we may use recruitment system and job application portal operated by external service providers on our behalf, for processing and handling your job application. The service provider may collect your Personal Data. For certain positions a background check will be performed by third-party service providers. You might also be asked to undergo psychometric tests and/or competency assessments.

      

     We use this information in order to determine your eligibility for the job and select the right candidate for the position in question. With your consent, we may also retain your data for the purposes of identifying you as a potential candidate for future suitable vacancies and/or to inform you of future suitable vacancies.

      

     The legal basis for processing and storing your job application, CV and related information is your consent and that the processing is necessary in order to take steps at your request prior to entering into a contract. You can withdraw your consent or update your information at any time by using the contact information available in the job application portal.

      

   • When you blow the whistle

     Please refer to our Whistle Blowing Policy for more information on how we handle your Personal Data when you submit a report through the whistle blowing channel.

      

   • When we conduct integrity due diligence investigations

     If and when we deem necessary, we will evaluate integrity due diligence investigations. This includes collection information to evaluate potential business relations or partners, their operation and business ethics. This investigation may include processing of Personal Data such as organisations position and roles, connections or relations to public authorities’ representatives or relevant decision makers, possible sanction listings, contracts, relevant memberships, references, legal claims and reputational issues. The legal basis is to comply with legal obligations, pursue our legitimate interests and to establish, exercise or defend legal claims.

      

   • When we safeguard and protect

     We have implemented various safety and security measures where we process Personal Data. We perform this to safeguard against illegal or unauthorised access to areas, buildings, data centers, systems, processes or equipment. Our safety measures include access control, CCTV cameras and identity checks. The categories of Personal Data we collect, and process may include identity information, contact information, role and employment data, date and time logs, CCTV recordings, vehicle registration and etc. depending on the different security measures.

    

2. Sharing of Personal Data

   We will not share your Personal Data with third parties except for in circumstances where such sharing is necessary as part of our regular business operations or to provide our services and support to you.

    

   Occasionally we use external third-party service providers for delivering services on our behalf and on our instructions as set out in a data processing agreement with the relevant service provider. We use such service providers for consultancy purposes, recruitment services, financial services, security services, IT services, communication services and integrity due diligence services. In such instances, we may share your Personal Data with such parties to the extent necessary to perform such work.

    

   We will not knowingly disclose your Personal Data to third parties for the purposes of allowing them to market their products or services to you.

    

   When required by law, regulation, legal process or an enforceable governmental request, we may share your Personal Data for legal reasons within MACROKIOSK and to public authorities or governments but only to the extent we are required to do so.

    

3. Transfer of Personal Data

   Your personal information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

    

   Your consent to the Privacy Statement followed by your submission of such information represents your agreement to that transfer.

    

   We will take all steps reasonable necessary to ensure that your data is treated securely and in accordance with this Privacy Statement and no transfer of your personal information will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

    

4. Cookies

   Some of our website or Service may use cookies and similar tracking technologies to track the activity on our website or service and hold certain information.

    

   Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.

    

   In the event you do not wish to receive such cookies, you may configure your browser to not refuse all cookies or to indicate when a cookie is being sent. However, you may not be able to use all the features and functionality of our website or service.

    

5. Security of Processing

   We will process your Personal Data securely and will apply and maintain appropriate technical and organisations measures to protect your Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing.

    

   Access to Personal Data is strictly limited to authorised personnel of MACROKIOSK and affiliates who have appropriate authorisation and a clear business need for that data.

    

6. Retention and Deletion of Data

   Your Personal Data will be retained as long as necessary to fulfil the legitimate purpose(s) for the processing and as long as required by law. If you or your employer have a contractual relationship with us, any Personal Data relating to you will be retained as long as necessary to enable us to fulfil our obligations relating to that contractual relationship.

    

   If you consent to certain processing, we store your Personal Data until you withdraw your consent or once the Personal Data is no longer necessary for achieving the purpose of the processing.

    

7. Your Rights as a Data Subject

   You have the right to request access to and rectification of any information we have collected about you through your use of the website and its online functionalities. To help us keep your Personal Data updated, we advise you to inform us of any changes or discrepancies.

    

   You also have the right to erasure and restriction of processing in some instances. You may have a right to receive Personal Data concerning you in a machine-readable format and to forward the data to another party (data portability), provided that certain conditions are met.

    

   To exercise your rights as a data subject, if you wish to object to the processing, including if the processing is for marketing purposes or to make a complaint regarding our compliance with this Privacy Statement, you may reach us with the contact details stated in Section 10.

    

8. Privacy Statements of Third Parties

   This Privacy Statement addresses the collection, use and disclosure of Personal Data by MACROKIOSK as described above. This Privacy Statement does not address or govern the privacy practices adopted by third parties on third party websites or in relation to third party services that may be accessible through use of the website. Although we try only to link to websites that share our high standards for privacy, we are not in any way responsible for the content or the privacy practices employed by third party websites or third-party services. We encourage you to familiarise yourself with the privacy policies applicable to such websites or services prior to providing them with your Personal Data.

    

9. Changes to This Privacy Statement

   We may update our Privacy Statement from time to time. If such updates are minor and do not have a material meaning for your rights or the way we use Personal Data, we may make such changes without posting a specific notice on our website. You are advised to review this Privacy Statement periodically for any changes.

    

Effective Date: 1st July 2020

NOTE:

If you have unresolved concerns, you also have the right to complain to the supervisory authority competent to resolve such concerns according to the applicable law.

If you have any questions or comments relating to our Privacy Statement, please contact us.

ISO27001 ISMS

This policy framework ensures that MACROKIOSK will uplift its perseverance in having a good practice in protecting the confidentiality, integrity and availability of the entire information from all threats, whether internal or external, deliberate or accidental. This policy framework will also minimise the possibility of a threat to information security causing losses or damages, security breach or exposure to its customers, business partners and MACROKIOSK.

MACROKIOSK is convinced and shall practice the followings in providing a safe and secure business relationship:

• Protect MACROKIOSK information assets from all threats, whether internal or external, deliberate or accidental;

• Ensure that information should be made available with minimal disruption to staff and the public as required by the business process by maintaining its CONFIDENTIALITY, INTEGRITY and AVAILABILITY;

• Comply to the statutory, regulatory and legislative requirements;

• Protect critical business processes from the effects of major failures or disasters;

• Ensure information security policy and security handbook is made available to all staff;

• Fulfill the customer's security requirements and expectations consistently;

• Continuously improve the Information Security Management Systems by performing periodic reviews.

If you have any questions or comments relating to our ISO27001 ISMS Certification, please contact us.

Anti-Spam

Spamming is the sending of unsolicited commercial communications. Mobile phones provide the utmost personal and direct access to a customer. Using it carelessly will have an intrusive and profound negative effect. Spamming puts all the actors in the wireless industry at risk. MACROKIOSK believes that user request-and-receive interaction is the best solution for the delivery of wireless content. It forces providers to develop content and services from the needs of the customer and establishes a dialog that leads to deeper customer relationships.

• MACROKIOSK does not accept spamming traffic; evidence of a client sending spamming will entail immediate suspension of the service and/or termination of the contract between that client and MACROKIOSK.

• No SMS, EMS or MMS must be sent to a mobile subscriber without having previously obtained his/her consent.

• MACROKIOSK clients need to set up a simple and inexpensive opt-out procedure allowing mobile subscribers to stop receiving SMS, EMS and MMS when they wish.

• MACROKIOSK clients must at all times comply with applicable laws and regulations concerning the collection, processing and the use of personal data.

• SMS, EMS and/or MMS related to marketing campaigns must at all times unequivocally indicate who is sending them and clearly indicate the price of the service promoted in accordance with advertisement legislation.

• MACROKIOSK strongly recommends that clients adhere to at least one direct marketing code of practice. In any case, the text or images displayed must not be misleading, and must straightforwardly describe or illustrate the services offered.

• Breach or suspected breach of this anti-spamming policy will cause immediate suspension of the service. If the breach is evident, client's contract will be terminated immediately. MACROKIOSK also reserves the right to initiate legal proceedings against the sender.

MACROKIOSK is convinced that building a trust-based relationship between mobile subscribers, network carriers and service providers is a paramount to success of the wireless industry. This policy will be interpreted in accordance with this principle.

If you have any questions or comments relating to our Anti-Spam Policy, please contact us.

Corporate Integrity Pledge

As part of the commitment towards the corporate integrity pledge, MACROKIOSK shall strive to participate and to contribute in creating a business environment (Not limiting to Malaysia, but in all MACROKIOSK business practices) that is free from corruption through the following actions:

• COMMITTING to promoting values of integrity, transparency and good governance.

• STRENGTHENING internal systems that support corruption prevention.

• COMPLYING with laws, policies and procedures relating to fighting corruption.

• FIGHTING any form of corrupt practice.

• SUPPORTING corruption prevention initiatives:

  • By the Malaysian Government.

  • By the Malaysian Anti-Corruption Commission (MACC).

  • By any Governmental and Agencies that MACROKIOSK has business practice in.

MACROKIOSK is convinced that to conduct business free from corruption and in accordance with the Anti-Corruption Principles for Corporations in Malaysia and in all MACROKIOSK business practices is to ultimately act in the best interests of the Company, its shareholders and employees, as corruption destroys shareholder value, undermines the confidence of investors and employees, and is the antithesis of sustainable growth.

If you have any questions or comments relating to our Corporate Integrity Pledge, please contact us.

Anti-Bribery and Corruption

This Policy establishes controls to ensure compliance with Anti-Bribery laws, and to ensure that MACROKIOSK’s business is conducted in a lawfully, professionally, ethically and socially responsible manner. Our commitment to prevent bribery and corruption is to ensure our employees, customers, vendors, agents and third parties whom we have dealings with also do so in compliance with effective anti-bribery and corruption policies. Hence, it is imperative that you read, understand and agree to all the provisions set out in this Policy. For the purpose of this Policy, the capitalised expressions shall have the meanings set out under “Definition” at the bottom of this Policy.

You undertake that as long as you are the Employee or Business Partner of MACROKIOSK:

1. You must not be involved in, an organised crime group (“Organised Crime”), a member of any Organised Crime, a person equivalent to a member of an Organised Crime, a company affiliated with any Organised Crime, a group engaging in criminal/illegal/unlawful activities including but not limited to providing funding to any Organised Crime, a group engaging in criminal/illegal/unlawful activities under the pretext of conducting social campaigns or Organised Crime involved in intellectual crimes and such other activities which the authorities deem as part of Organised Crime from time to time;

    

2. You have not been convicted nor are we subject to any investigation, inquiry or enforcement proceedings by the relevant authorities of any actual or suspected breach Anti-Bribery Laws and will report any actual or suspected breach as soon as reasonably practicable and to the extent permitted by the law, to MACROKIOSK;

    

3. You must comply with (i) the Anti-Bribery Laws and you must not take any actions or make any omissions which would could cause MACROKIOSK to be in violation of the Anti-Bribery Laws;

    

4. You must not give or offer to give, agree to give, authorise, solicit or accept of any gratification, gift, commission or consideration of any kind as an inducement or reward for obtaining or retaining business or doing or promising to do any act or otherwise secure an improper advantage whatsoever for whatever reasons, by or for any person, including government or party officials, our employees, officers or any person acting on their behalves;

    

5. You must not (i) make any Facilitation Payments or transfer of value, offers or promises; or (ii) give any financial or other advantage (including kickbacks), make any requests, agreements to receive or accepting any advantage whether financially or otherwise; in each case either directly or indirectly which has the purpose or effect of, or would mean acceptance of or acquiescence in, either directly or indirectly, public or commercial bribery, other unlawful or improper means of obtaining or retaining business or commercial advantage or the improper performance of any function or activity;

    

6. You must promptly assist and cooperate with MACROKIOSK, its clients or any government body with any bribery and corruption risk assessment and due diligence by providing all relevant and/or required information upon request;

    

7. You must promptly inform MACROKIOSK of any suspicious bribery and corruption activities, including but not limited to any request or demand for any undue financial or other advantage of any kind you received or being offered by the Employees of MACROKIOSK;

    

8. You declare, to your best knowledge and belief, that you are not aware of any actual, potential or perceived conflict of interest situation or circumstances with MACROKIOSK or other stakeholders of MACROKIOSK;

    

9. You agree and acknowledge that the provisions set out in this Undertaking shall form an integral part of the terms and conditions of your letter of offer, employment agreement appointment, contract of service and/or any agreement you entered into with MACROKIOSK and/or any dealings you have with MACROKIOSK;

    

10. You agree and acknowledge that in the event (i) you breach, or fail to comply with this Undertaking (“Said Breach”), MACROKIOSK reserves the right to (a) suspend or terminate the contract, agreement, job, services whatsoever and disqualify you as the Employee or Business Partner of MACROKIOSK or from tendering for future contracts/ jobs; and/or (b) report the same to the police and disclose all information required by the police; and (ii) you shall indemnify MACROKIOSK and its directors and officers for all damages and costs they suffered and/or incurred as a result of, or in connection with, the Said Breach; and

     

11. You fully understand, acknowledge and agree to the provisions set out in this Policy.

All forms of bribery and facilitation payments are prohibited. However, your safety is our utmost concern and in the event there are circumstances which you have no choice but to make facilitation payment so to protect against your loss of life, limb or liberty, please report this matter to us and we will do take all necessary actions permitted by law, including but not limited to making a police report.

If you require more information on what constitutes or deems a bribe, Facilitation Payment, gift etc, you may refer to the Anti-Bribery Laws, your legal advisor or request more information from us. However, you acknowledge any such information provided by us to you is on an “as is” basis without any warranty or representation of any kind and we do not act as your legal advisor in any manner.

For the purpose of this Policy, the expression of:

1. “Anti-Bribery Laws” means all applicable laws, statues, by-laws whatsoever relating to anti-bribery and corruption in the jurisdictions in which MACROKIOSK operates. These laws include but are not limited to the Malaysian Penal Code (revised 1977), the Malaysian Anti-Corruption Commission Act 2009 (revised 2018), the Malaysian Companies Act 2016, UK Bribery Act 2010, Prevention of Corruption Act (Chapter 241) of Singapore, Republic Act no. 3019 (The Anti-Graft and Corrupt Practices Act of Philippine),Thailand’s Act Supplementing the Constitution Relating to the Prevention and Suppression of Corruption B.E.2561 (2018) (New Anti-Corruption Law) and Prevention of Bribery Ordinance (POBO) of Hong Kong;

    

2. “Business Partner” means any third party (including but not limited to agents, consultants, contractors, subcontractors, affiliates, distributors, resellers, business contacts, professional advisors, joint venture partners) who (i) has contractual relationship with MACROKIOSK; and/or (ii) has, or potentially has, any dealings (including not limited to business dealings or provision of goods or services) whatsoever with MACROKIOSK; and

    

3. “Employee” means all employees whether temporary, fixed-term, or permanent and include without limitation to consultants, contractors, trainees, agency staff, interns, sponsors or any other person or persons associated with MACROKIOSK (including third parties);

    

4. “Facilitation Payment” means a payment or other provision made personally to an individual in control of a process or decision or is given to secure or expedite the performance of a routine or administrative duty or function.

    

5. “MACROKIOSK” means all subsidiaries and/or associates companies, whether locally or internationally, of Macro Kiosk Berhad.

    

If you have any questions or comments relating to our Anti-Bribery and Corruption Policy, please contact us.

No Gift

MACROKIOSK believes in equal and unbiased treatment, professionalism and non-discriminatory acts as MACROKIOSK upholds its quest to conduct business in the highest standards in terms of integrity and honesty. Consistent with the foregoing, if you fall within the following categories, we request that you do not offer or send any gifts to us:

• Vendors

• Suppliers

• Customers

• Potential and ex-employees

• Potential vendors and suppliers, and/or

• Any individuals or organisations (Government and Non-Government, Public and Non-Public, Profit and Non-Profit)

Exceptions

The following are exempted:

• Gifts obtained from public events such as tradeshows, conferences, training and seminars whether in the form of physical goods or food or beverages.

• Gifts in the form of Greeting cards, Thank You notes, Certificates, or in such other written form.

• Gifts that are no more than USD1.00 in value.

If you have any questions or comments relating to our No Gift Policy, please contact us.

Malaysia Digital Climate Action Pledge (MDCAP)

Through this pledge, MACROKIOSK is committed to undertake the following actions:

• Conduct business operations in an environmentally responsible manner, through Reduce, Reuse, Recycle practices;
• Take action to minimise greenhouse gas emissions by implementing energy efficiency and/or renewable energy or other emission-reducing measures;
• Implement responsible sourcing across our supply chain;
• Define a climate governance strategy in accordance with the mission, vision, and values of our company;
• Encourage stakeholder dialogue on our company's sustainability practices;
• Share sustainability best practices in terms of strategies, action plans and initiatives.

MDCAP is a corporate pledge jointly developed by the Malaysia Digital Economy Corporation (MDEC) with United Nations Global Compact Network Malaysia and Brunei (UNGCMYB).

If you have any questions or comments relating to our Malaysia Digital Climate Action Pledge (MDCAP), please contact us.

Whistleblowing Code of Conduct

MACROKIOSK has established a Whistleblowing Code of Conduct that sets out a standard operating procedure for legitimate matters of concern to be objectively investigated, addressed and solved.

Individuals will be able to raise matters of concern about unlawful, unethical and/or questionable actions/behaviours as well as practices by stakeholders directly and/or indirectly related to the company without fear, the risk of punishments and discrimination.

Whistleblowing is a voluntary disclosure by the management or employees within the group of companies.

Below are the steps in making the disclosure:

1. The whistleblower decides on the disclosure approach - Internal or External channel.
2. The whistleblowing champion will administer, classify and evaluate the disclosure.
3. The whistleblowing committee will deliberate on the disclosure and decide on the next cause of action.
4. The investigation team will conduct the investigation and issue a report on the findings to the whistleblowing committee to further deliberate on the disclosure to decide on the next cause of action.
5. Human Capital and Administration will invoke the disciplinary action processes and procedures followed by a formal notice on the outcome of the disclosure to the whistleblower.

If you have any questions or comments relating to our Whistleblowing Code of Conduct, please contact us.