Privacy Statement

TRON’S PRIVACY PRINCIPLES 

Your privacy matters to us. To preserve the confidentiality of all information you provide to us, we maintain the following privacy principles:-

  • We only collect Personal Data that we believe to be relevant and required.
  • We use your Personal Data to provide you with better customer services and products.
  • We may disclose your Personal Data to our Related Corporation or other third parties as identified in this Privacy Statement.
  • We endeavour to collect your Personal Data with your knowledge and consent which we believe to be true, accurate and complete in all respects.

We endeavour to give effect and respect to your privacy and to comply with the Personal Data Protection Act 2010 and all regulations and codes of practices made thereunder.

IMPORTANT NOTICE & DEFINITIONS 

Please read this Privacy Statement carefully as it forms part of the terms and conditions of use of any Tron Services or services which you acquire from us or any of our Related Corporation.

In this Privacy Statement, the following expressions shall, unless the otherwise expressly stated, bear the following meaning:-

Personal Data means any information in the possession or control of Tron that relates directly or indirectly to you (or any other individual) to the extent that you (or the other individual) is identified or identifiable from that information or from that and other information in the possession of Tron including but without limitation to your personal information such as name, date of birth, current and previous addresses, telephone or mobile phone number(s), e-mail address(es), bank account or credit card details, personal interests, and shall include any sensitive personal data (include any personal data consisting of information as to the physical or mental health or condition of a data subject, your political opinions, religious beliefs or other beliefs of a similar nature, etc), and expression of opinion and including but without limitation to all information and details in relation to the Tron Services provided by Tron to you and any information pertaining to the commercial transactions as stipulated in the agreement between you and Tron as well as the Tron Services which include your content and traffic usage.

Privacy Statement shall mean the entire statement herein and shall include all such further and future amendments, modifications and/or rectifications.

Process, Processing shall mean any dealings by us with the Personal Data including but without limitation to the collection, recording, holding, storing, use and disclosure of the Personal Data and shall further include but without limitation to the organisation, adaptation, alteration of the Personal Data, the access to, retrieval, consultation or use of the Personal Data, the disclosure of the Personal Data by transmission, transfer, dissemination or otherwise making available or the alignment, combination, correction, erasure or the destruction of the Personal Data.

Related Corporation in relation to any corporation means any subsidiary or holding company of that corporation or any subsidiary of that holding company.

Tron Services means any services and/or products and/or a combination of both provided by Tron, our Related Corporation(s), authorised agents, authorised affiliated partners or associates. Any references to “Tron Services” in this Agreement shall mean all the Tron Services or any of them as the context requires.

“Tron”, Our, Us, We refers to Talk Focus Sdn. Bhd. (Company Registration No.: 753644-T) a company duly incorporated pursuant to the Companies Act, 1965 Malaysia and having its principal business address at Tron Headquarter, K-2-8, 2nd Floor, Kuchai Business Park, Jalan 1/127, off Jalan Kuchai Lama, 58200 Kuala Lumpur, Malaysia and its Related Corporation(s).

Tron Website means the website used by Tron, namely http://www.tron.myhttp://www.tron.com.my and other web address(es) as may be used and/or adopted by Tron from time to time.

Any references to person(s) shall include any company, partnership, individual person, firm, joint venture, association, corporation, statutory body, unincorporated body of persons, trust, bureau, minister, agency, instrument, court, regulatory body, government or state, any authority or other body corporate and vice versa;

In the event of any doubt in relation to the definitions contained in this statement, the definitions as provided in the Personal Data Protection Act 2010 shall prevail.

COLLECTION OF PERSONAL DATA – HOW DO WE COLLECT YOUR PERSONAL DATA? 

We collect your Personal Data through various ways, including but without limitation to the following manner:-

  • During the registration process – any personal information provided by you whenever you register for any of the Tron Services, whether by way of telephone conversation, in the application forms and/or other agreements/forms, or through the Tron Website and/or any other mode of telecommunications.

The Personal Data herein described is collected automatically and if you wish to stop and/or prohibit us from processing this Personal Data about you, we will no longer be able to provide the relevant Tron Services to you.

  • From your use of the Tron Services – any information in our records including the type, genre and status of the Tron Services acquired by you including any mobile content, and any information in relation to how you use the Tron Services or any of them (including but not limited to telephone numbers and e-mail address(es) of calls, SMS, MMS, e-mails and other communications made and received by you and the date, duration, time and cost of such communications, your internet browsing/searching/surfing history, access to content, uploads and downloads (including the amount of data consumed), your IP address, the quality of the Tron Services you have received from us (in terms of network reception and data quality), your mobile or fixed cellular phone’s location, your billing and payment status and records, your personal interests and preferences (by looking at the types of the Tron Services you acquire and how you use them), the equipment which you use when accessing or using our Tron Services such as your mobile handset and your image, by way of video surveillance logs installed in some of our centres as part of our security infrastructure (when applicable).

The Personal Data herein described is collected automatically and if you wish to stop and/or prohibit us from processing this Personal Data about you, we will no longer be able to provide the relevant Tron Services to you.

  • Use of “cookies” – your visit to Tron Website maybe recorded for analysis on the number of visitors to the site and general usage patterns. Some of this information will be gathered through the use of “cookies”. “Cookies” are small bits of information that are automatically stored on a person’s web browser. We use cookies to make visiting our sites and our partner sites easier. Cookies allow Tron to save preferences for you so that you will not have to re-enter them the next time you visit. Cookies also help us to collect anonymous click stream data for tracking user trends and patterns. Tron may use the anonymous clock stream data to help our advertisers deliver better-targeted advertisements to Tron Website.

The use of “cookies” is not an industry standard and is commonly used in most websites. If you wish, you may reset your browser either to notify you when you have received a cookie, or to refuse to accept cookies. Please take notice that areas of certain sites will not function properly if you set your browser to not accept cookies.

  • Voluntary Personal Data – Any information voluntarily provided by you when you subscribe to certain Tron Services.

Subscription to certain Tron Services is voluntary and you can choose to unsubscribe them at any time. If you do not wish for us to process such information, you should not subscribe for such Tron Services.

  • Marketing Communications & Postings – We will collect your Personal Data through direct communications with you (including by way of SMS, MMS, e-mails, telephone conversations and any other mode of telecommunications) and when you respond to requests from us (such as contests, questionnaires or surveys). We will also collect your Personal Data when you participate in any of our redemption programme. We may also collect and process any postings/views/comments/opinions from you which you posted on the Tron Website. If you change your mind about receiving any promotional e-mails from us please contact us and we will remove you from our mailing list.

The Personal Data will be collected with your knowledge and consent and is provided by you voluntarily. If you do not agree to this information being collected and used by us then you should not provide or post it, which in turn means that you may not be able to participate in or receive the full benefit of such communications, contest, polls, questionnaires or surveys.

PROCESSING OF PERSONAL DATA – THE PURPOSES 

Your Personal Data may be processed for various purposes, including but without limitation to the following purposes:-

  • To verify your identity;
  • For the performance of any agreement between Tron and for any purpose which is necessary or related to the provision of the Tron Services to you;
  • For the performance of a contract in which you are a party;
  • For the taking of steps at your request with a view to entering into a contract;
  • To protect your vital interest or another person in a case where the consent cannot be given by or on your behalf or you cannot reasonably be expected to obtain the consent the data subject;
  • To provide and facilitate the Tron Services you acquired;
  • To assist you when subscribing to our services;
  • To administer and manage Tron Services and your account with us whether on Tron Website or otherwise;
  • To assess and/or verify credit worthiness and/or to conduct credit check;
  • To detect and prevent fraudulent activity;
  • For the administration of justice or prevention or detection of a crime, or for purpose of investigations or for the purposes of public interest or legal proceedings;
  • For execution of any functions conferred on any person by or under any law or was required or authorised by or under any law or by the order of a court or any administrative or regulatory bodies having jurisdiction over the matter;
  • For medical purposes and is undertaken by a healthcare professional or a person who in the circumstances owes a duty of confidentiality which is equivalent to that which would arise if that person were a healthcare professional;
  • For the purpose of obtaining legal advice in relation to the Tron Services;
  • For the purposes of establishing, exercising or defending legal rights;
  • For the assessment or collection of any tax or duty or any other imposition of a similar nature;
  • To manage the network;
  • To process your order for any Tron Services and/or any redemption vouchers, services, or products which you have requested;
  • To investigate and resolve any service issues, billing queries, complaints or other enquiries that you submit to us regarding our network, Tron Services or customer relations personnel;
  • To contact you and maintain communication with you;
  • To manage staff training and quality assurance;
  • To help us to monitor and improve the performance of our services, our customer relations and service providers, mobile content providers etc;
  • To maintain and develop our business systems and infrastructure, including testing and upgrading of the system;
  • To gain an understanding of your information and communication needs in order for us to enhance our services;
  • To conduct research and development and statistical analysis in connection with the Tron Services and to identify your needs, preference and market trend;
  • To send you seasonal greetings, messages or public service announcements;
  • To promote and market to you (including but without limitation by way of direct mail, bill inserts, telemarketing, SMS, MMS, e-mail and/or any other mode of telecommunications) other services or products provided by us or our Related Corporation(s) and/or strategic partners, products, services, promotion, special offers of third parties whose products and services we think may be of interest to you;
  • For any other purposes which you have explicitly consent to, whether contained herein or otherwise.

DISCLOSURE TO THIRD PARTIES

Your Personal Data may be disclosed to third parties, including but without limitation to the following persons:-

  • any person engaged/contracted/appointed by us (including our employees, workers, staffs, shareholders, directors, agents, contractors, business partners or associates, etc) to facilitate the performance and provision of Tron Services and/or any other purpose which is necessary or related to the provision of Tron Services to you;
  • to any of our Related Corporation(s) and our shareholders and the shareholders of our Related Corporation(s) and/or any other entity, corporation and company affiliated with us;
  • to our network service provider;
  • to our strategic partners that work with us to provide Tron Services or that help market Tron Services including our network of distributors, dealers and retailers;
  • to other telecommunication and information service providers when you have used their networks, for billing and service resolution purposes and including for the purpose of facilitating mobile number portability (“MNP”) (if applicable);
  • to payment channels including without limitation to financial institutions;
  • to any person for the performance of a contract in which you are a party;
  • to any person for the purpose of compliance of any legal obligation, other than an obligation imposed by contact;
  • to any person necessary for the administration of justice or prevention or detection a crime, or for purpose of investigations or for the purposes of public interest;
  • to any person for medical purposes or for the purposes of obtaining legal advice or for the purpose of execution of any functions conferred on any person by or under any law or was required or authorised by or under any law or by the order of a court or any administrative or regulatory bodies having jurisdiction over the matter;
  • to any person for the assessment or collection of any tax or duty or any other imposition of a similar nature;
  • to any person for the purpose of responding to services or technical issues or marketing activities;
  • to our professional advisors on a need to know basis for the purpose of those advisors providing advice to us;
  • to parties nominated or appointed by us either solely or jointly with other service providers, for purposes of establishing and maintaining a common database where we have a legitimate common interest;
  • to any third party which acquires all or part of the assets or business of Tron;
  • otherwise as permitted under Malaysian law, including without limitation, the Personal Data Protection Act 2010 (if applicable).

OUR COMMITMENTS & SECURITY

As our commitment to you as our customer, we shall in our best endeavour adhere to the following principles when processing your Personal Data:-

  • we will take reasonable practical steps to protect the Personal Data from any loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction of the Personal Data;
  • we will not disclose your Personal Data to any spamming syndicate;
  • we will take reasonable practical steps to ensure that third parties who receive your Personal Data from us shall safeguard the confidentiality of your Personal Data.

We take security very seriously and we have amongst others the following security features in processing your Personal Data:-

  • authentication – this assures your browser that your data is being sent to the correct computer server, and that the server is secured;
  • encryption – this encodes the date, so that it cannot be read by anyone other than the secured server;
  • data integrity – this checks the date being transferred to ensure it has not been altered.

Our website has reasonable security measures in place to protect the loss, misuse and alteration of the information under our control. We use Secure Socket Layers (SSL) technology to ensure the privacy of the information provided to us in the order forms. At no time are the customers’ debit/credit cards details transmitted un-encrypted over the Internet.

YOUR OBLIGATIONS

You are responsible for updating your Personal Data with us and you hereby confirm that all Personal Data furnish to us are true, accurate, complete, not misleading and kept up-to-date at all time. You shall immediately report and notify us in the event of any error in the Personal Data which you have submitted and/or provided to us and/or otherwise collected by us whether through your usage of the Tron Website and/or Tron Services or otherwise. If you do not wish to receive certain information from us whether via SMS, MMS, e-mail or otherwise you shall notify us and request to be excluded from such services, failing which you shall deemed to have accepted the services voluntarily.

We shall not be responsible for any Personal Data made available by you on any third party sites which may have a link on Tron Website.

YOUR DECLARATION

By agreeing to this Privacy Statement and/or by registering for and continuing to use the Tron Services signifies and indicates your voluntary and explicit acceptance and consent to your Personal Data being processed by us for the purposes set out in this Privacy Statement and disclosed by us to those classes of third parties identified in this Privacy Statement. Please take note that you are at liberty to refuse to provide us with any Personal Data and to terminate your relevant Tron Services agreement with us.

This Privacy Statement shall constitute sufficient NOTICE to you in relation to the process of Personal Data by us.

YOU HAVE ACCESS & YOU HAVE RIGHTS

  • Right to be informed & right to access: You are entitled to make a written request to us for information of the Personal Data that is being processed by or on behalf of Tron upon payment of a prescribed fee. You may also request for a copy of the Personal Data upon payment of a prescribed fee.
  • Right to correct your personal data: You may also request for correction and/or modification in relation to any of your Personal Data. If you are concerned with the confidentiality of any information given or you wish to correct any Personal Data provided by you to us, kindly contact Tron. at:-

Dial 1 300 800 188 – in Malaysia
Dial +603 6275 8233 – from abroad

Email:- enquiries@tron.com.my (between 10.00am to 7.00pm), daily. You may also use this address to communicate any concerns you may have regarding compliance with this Privacy Notice.

  • Right to prevent processing for direct marketing purpose: If you do not wish to receive certain information from us whether via SMS, MMS, e-mail or otherwise you shall notify us and request to be excluded from such services, failing which you shall deemed to have accepted the services voluntarily.
  • Right to prevent processing of data likely to cause distress & Right to withdraw consent: You are entitled to inform us in writing should you wish us to stop processing your data but we may not be able to provide Tron Services to you.

MODIFICATIONS

Tron reserves all absolute rights to amend, modify, vary, terminate, delete and/or add any part or all of this Privacy Statement at any time and from time to time and any notice in relation to any such amendment, modification, variation, termination, deletion and/or addition shall be posted on Tron Website. Your continued usage of the Services after being notified of any changes to this Privacy Statement you shall be deemed to have agreed to and accepted and consented to those changes. If you do not agree to any such changes, you may terminate your relevant Tron Services agreement with us.