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Copy of Privacy Policy

Privacy Policy 

This privacy policy sets out the principles The Whisky Notes follows when collecting, using, disclosing, retaining and removing your personal data in accordance with Malaysia’s Personal Data Protection Act 2010 (the “PDPA”).  

This policy may be updated from time to time to keep up with changes in regulations, so please do check back here for the latest prevailing version applicable.  

To begin, “Personal Data” refers to data, whether true or not, about any individual who can be identified from that data or from that data in combination with other information, to which The Whisky Notes may have access.  

By subscribing for, purchasing or using any of The Whisky Notes’ products, services or campaigns or submitting information to or otherwise communicating with The Whisky Notes (through email, by telephone, via our website or otherwise), you agree and consent to The Whisky Notes collecting, using and disclosing your Personal Data in accordance with this policy.  

Collection of Personal Data  

  1. Personal Data collected by The Whisky Notes may include any of the following:
    • name, title, address;
    • personal identification and/or passport number;
    • telephone number;
    • email address and online passwords;
    • records of communications with The Whisky Notes;
    • responses to market surveys and contests conducted by The Whisky Notes;
    • credit card, debit card and/or e wallet information;
    • website usage information.

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  1. Personal Data collected by The Whisky Notes may include any of the following:  
  • name, title, address;  
  • personal identification and/or passport number;  
  • telephone number;  
  • email address and online passwords;  
  • records of communications with The Whisky Notes;  
  • responses to market surveys and contests conducted by The Whisky Notes;  
  • credit card, debit card and/or e-wallet information;  
  • website usage information.  


  1. We may collect your Personal Data:  
  • when you order or purchase products or services from us;  
  • when you post a feedback or interact with us over meetings, emails, texts or telephone calls (which may be recorded for training, quality control, business and/or other lawful purposes);  
  • when you use our services including establishing any online accounts with us;  
  • when you request that we contact you, be included in an email or other mailing list;  
  • when you respond to our promotions, campaigns or other initiatives or attend our events;  
  • when you visit our website;  
  • when you take part in any contest, survey or promotion conducted by us and/or our business partners;  
  • when you submit your Personal Data to us for any other reasons; and/or  
  • when we collect your Personal Data by other lawful means.  


  1. The Whisky Notes only collects, uses and discloses personal data with an individual’s consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations.  


  1. In providing any Personal Data to us, you warrant and represent to us that (a) Personal Data which you disclose to us is accurate and complete; and (b) where you volunteer Personal Data of another person to us, that you are authorized by such other person to disclose such Personal Data to us, and that such Personal Data is accurate and complete.  


Use, Collection and Disclosure of Personal Data  

  1. The Whisky Notes will generally only collect and use Personal Data for the following primary purposes:  
  • to verify and process your personal particulars and payments;  
  • to provide our goods and services to you;  
  • to respond and deal with enquiries and other customer-care matters or otherwise communicate with you;  
  • to monitor or record phone calls and customer-facing interactions for quality assurance, training and performance evaluation and identity verification purposes;  
  • to manage payment, billing, and accounting matters;  
  • to send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services;  
  • to manage, develop and improve our business and operations (including our website) to serve you better;  
  • to carry out marketing promotions and campaigns, contests, market surveys and personalising your experience with us;  
  • to carry out market research and customer surveys;  
  • to conduct investigations or audits or to comply with legal and regulatory requirements;  
  • for other purposes for which we have obtained your consent; and/or  
  • for any other purposes reasonably necessary, ancillary or related to the above specified purposes.  


  1. The Whisky Notes only discloses Personal Data:  
  • for the primary purposes for which it was collected; or  
  • for purposes that a reasonable person will consider appropriate in the circumstances; or  
  • where the individual has consented; or  
  • for direct marketing by The Whisky Notes where consent has been given but always giving individuals the opportunity to opt out of such direct marketing (The Whisky Notes includes its contact details in any direct marketing so please feel free to let us know if you wish to opt out); or  
  • where permitted under the PDPA or other applicable law or if required by law.  


  1. We will never disclose your Personal Data for any secondary purposes unless your consent has been given or if so permitted or required under the PDPA or other applicable laws and regulations. We will likewise never sell or license any Personal Data that we collect from an individual.  


  1. If there are other situations where we may collect and use Personal Data which are outside a person’s reasonable expectation, we are committed to providing you with an explanation for the possible uses of such Personal Data when asking for your consent.  


  1. By providing us with Personal Data, you agree that such Personal Data may be transferred, stored and/or processed in a country or territory outside Malaysia and you consent to any such transfer, storage and/or processing of your Personal Data outside Malaysia. We will however ensure that any party to whom we transfer your Personal Data outside Malaysia provides to such Personal Data a standard of protection at least comparable to the protection under the PDPA. This includes without limitation ensuring that any party coming into contact with the Personal Data outside Malaysia:  
  • complies with the PDPA and accompanying guidelines issued by the relevant regulatory authorities, all applicable laws and regulations and this Privacy Policy (“Data Standards”) and shall not do or permit anything to be done which might cause such party or us to breach the Data Standards;  
  • takes all appropriate measures to ensure such compliance by implementing such Data Standards as may be notified by us to them from time to time and appropriate technical and organisational measures and providing a standard of protection for the Personal Data that is comparable to the protection under the PDPA;  
  • protects the Personal Data by making reasonable security arrangements to prevent unauthorised access, use, disclosure or modification.  


Accuracy, Correction & Access  

  1. The Whisky Notes endeavours to ensure that information and Personal Data you provide to us is accurate and up-to-date by updating its records whenever changes to information come to its attention.  


  1. If you have submitted Personal Data to us electronically or otherwise, and would like it corrected, then please feel free to sent us a written request to the Privacy Officer at hello@thewhiskynotes.com. We will comply with reasonable requests to correct Personal Data as soon as practicable.  


  1. If you wish to be provided with information regarding your Personal Data that is in the possession or under the control of The Whisky Notes or understand the ways in which such Personal Data has been used or disclosed by us in the year preceding such request, then please likewise send a written request by email to the Privacy Officer at [email address] or at the address below. We will handle such requests as soon as reasonably possible in accordance with the PDPA.  


Withdrawal of Consent  

  1. You may withdraw your consent to our continued use and disclosure of your Personal Data or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) at any time by writing to the Privacy Officer at hello@thewhiskynotes.com. You may also withdraw your consent for specific forms of communication via the unsubscribe options as stated on our email or other marketing messages.  


  1. In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you and that we may cease such provision accordingly without any liability.  


  1. We endeavour to update our records in a timely manner but please note that it may take a reasonable time for any request for consent withdrawal to be processed and reflected in our systems. We will then cease to collect, use or disclose the personal data upon such withdrawal unless otherwise permitted or required by the PDPA or other applicable laws and regulation.  


Security of your Personal Data  

  1. The Whisky Notes takes protection of your Personal Data seriously, and is committed to taking reasonable steps to ensure that Personal Data is securely stored and protected against risks of unauthorised access, collection, use, disclosure, copying, modification, disposal or destruction.  


  1. We protect Personal Data from misuse or loss by restricting access to the information in electronic format and by reasonable and appropriate physical and communications security measures. Any data destroyed is also disposed of in a manner that protects the privacy of Personal Data in an appropriate manner.  


  1. Notwithstanding our security measures for protecting your Personal Data, we should highlight that no data transmission over the Internet is entirely secure and by providing your Personal Data to us in this manner, you understand that you transmit this information at some risk.  


Retention of Personal Data  

  1. We will retain your Personal Data for as long as you purchase or use our products or services and such data is necessarily required or relevant for business or legal purposes.  


Using our Website  

  1. As with most websites, when you visit the The Whisky Notes website, we may record anonymous information such as IP addresses (where not used to identify a specific individual), time, date, referring URL, pages accessed and documents downloaded, duration of stay or use, type of browser and operating system. Such information is usually collected on an aggregate and anonymous basis.  


  1. We also use “cookies”, which are small files that stay on your computer until, depending on whether they are sessional or persistent cookies, you turn your computer off or they expire. Cookies may collect and store your Personal Data. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use our website but may be limited in the use of some of the features.  


  1. By accessing and using our website and services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents.  


  1. Our website and/or services may contain links to or from third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by such third-party websites or other services. We therefore encourage you to exercise caution, and review the privacy statements applicable to such websites and services. To the fullest extent permitted under laws, we cannot be responsible for a third party’s acts, omissions, data policies or their use of cookies, or the content or security of any third party websites, even if linked to our website. Any such liability is expressly disclaimed and excluded.  
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