Privacy Policy

Privacy Policy

Eltean Incorporated Sdn. Bhd. or any of its
subsidiaries, affiliates or any related companies or any of its authorised
personnel, representatives, appointed distributors, or any other relevant third
party (hereinafter referred to as “Eltean”) observes and complies with
the Personal Data Protection Act 2010 (“PDPA”).

Eltean is committed to ensuring that the Personal
Data (as defined in Section 4 of the PDPA) disclosed to and obtained by us are
protected and used within the scope of consent provided by the Data Subjects
and/or as permitted by law.

In this Privacy Policy, the term “we”, “us” and
“our” refers to Eltean who is the collector, processor and user of Personal Data
(hereinafter, referred to as “Data User”) (as defined in Section 4 of
the PDPA) and the term “you” and “your” refers to the Data Subject(s) (as defined
below).

This Privacy Policy mainly sets out the manner in which Eltean deals with your Personal Data including the manner in which we collect, process, use, disclose, transfer and store your Personal Data.

Eltean reserves the right to amend, update, revise and/or revoke and republish this Privacy Policy at any time and from time to time. The version of this Privacy Policy and/or any Supplemental Privacy Policy (to be read in conjunction with this Privacy Policy) being published on our website (www.eltean.com/privacy) shall be treated as the current version applicable and in force. We strongly advise you as a Data Subject to periodically review our Privacy Policy from time to time to stay informed and updated of the processing, usage, disclosure, transfer and storage of your Personal Data and your rights and protection accorded under the PDPA.

APPLICABILITY

This Privacy Policy (and any subsequent amendments, variations or alterations thereof which may be made and published from time to time) outlines and explains the policies and principles pertaining to the Personal Data that we collect from you (whether in person, online or any other manner whatsoever), as our valued customers, our landlords or tenants, consultants / advisors, vendors, suppliers, service providers, authorized distributors or any such party which Eltean deals, transacts, corresponds and in any way conducts its business with (collectively referred to as “Parties”) and employees of Parties and/or any such person whose Personal Data is required to be collected by us by reason of, or incidental to, the provision of our products and services or in the ordinary course of our business (collectively, referred to as “Data Subject(s)”).

This Privacy Policy applies to our day-to-day
business operations including visitors to our website (www.eltean.com) (“Eltean’s Home Site”), our official
social media pages on Facebook (www.facebook.com/SebamedMalaysia) and Instagram (www.instagram.com/sebamed_malaysia) and our Sebamed Malaysia official e-stores hosted
on, including but not limited to, Shopee Malaysia and Lazada Malaysia
(collectively referred to as “Eltean Websites”).

PRIVACY POLICY TO CONSTITUTE WRITTEN NOTICE TO DATA
SUBJECTS

This Privacy Policy shall constitute written notice
to you, as a Data Subject, in accordance with the Data Protection Principles
under the PDPA.

By your dealings, interactions, communications, correspondence, transactions and/or any form of dealing with us in the usual course of our business or otherwise, usage and continuous usage of our Eltean Websites and/or by submitting your Personal Data to us, you have agreed to be bound by this Privacy Policy whereby we shall have the right to process your Personal Data in accordance with this Privacy Policy.

Eltean reserves the right to revise and/or amend
this Privacy Policy at any time and from time to time. The latest and
applicable version of this Privacy Policy and/or any supplemental Privacy
Policy shall be posted at Eltean’s Home Site. Kindly review this Privacy Policy
on a periodic basis to stay informed of your rights, your consent status, the
Personal Data we collect or have collected from you, requests for revision /
amendment of your Personal Data retained by us or any other issues or enquiries
you would like to make in relation of your Personal Data that is collected,
processed and retained by us.

PART I – CONSENT TO THE COLLECTION OF PERSONAL DATA

1. We collect your
   Personal Data when you interact with us via online or offline channels
   including, but not limited to, your name, contact number, e-mail address,
   residential address, age, skin, hair and scalp conditions, etc.

• In this regard, by providing, informing and/or submitting your Personal Data to us by any means, whether written or otherwise, and by using and continuing to use Eltean’s Home Site, it is deemed that you have given your consent for us to use and process your Personal Data in accordance with this Privacy Policy. Your failure, refusal or omission to consent to the above may result in our inability to provide our goods and services to you, wherever applicable.

• For any other individual whose data is required to be collected by us to facilitate various business transactions, contractual arrangements, engagements, etc., it is deemed that you have consented to our collection of your Personal Data as far as is necessary to enable the performance of such business transactions, contractual arrangements, engagements, etc. between Eltean and you.

PART II – PURPOSE OF COLLECTING PERSONAL DATA

• We collect your
  Personal Data for primarily for the purposes, including but not limited, to the
  following:

• for individual and/or corporate customers,
  processing your Account Opening Application Form and Credit Application Form to
  purchase any of Eltean’s product(s) or service(s);

• promotional and marketing of Eltean’s product(s) or
  service(s) and sending any advertising and/or promotional material to you via
  telephone calls, emails or instantaneous communication message (including but
  not limited to Short Message Service (SMS), WhatsApp, Facebook Messenger,
  Viber, Line, etc.), where you have expressly consented to the receipt of such
  materials.

• for prospective employees of Eltean, processing
  your Application for Employment Form and all matters in connection with your
  employment with Eltean should you be successful in your employment application;

• for existing employees of Eltean, to continuously update your Personal Data kept of file for the purpose of your continuous employment

• for landlords and tenants of Eltean, to deal with
  all matters in connection with our landlord and tenant relationship with you,
  including but not limited to, payment of rental and communication with you as
  the landlord or tenant of Eltean;

• marketing of product(s)or service(s) and sending
  any advertising and/or promotional material to you via telephone calls, emails
  or short message services if you have expressly provided your consent for us to
  do so;

• notifying you of special offers, promotions,
  current and future product launches, special invitations that we consider might
  be of interest to you and for similar updates and promotion reasons via
  newsletters, electronic direct mailers, direct mailers, etc;

• for individuals who have previously shared any
  personal information such as your hair and scalp condition, skin condition, to
  continue to progressively monitor your skin condition when you engage in our
  services, including but not limited to, hair and scalp assessments, from time
  to time;

• performing statistical and analysis of your skin,
  hair, scalp and other characteristics for customer relationship management
  purposes, such as providing a suitable range of products for your personal
  needs;

• any purpose in connection with Eltean’s operation,
  administration, business development and the enhancement of its business.

PART III – DISCLOSURE OF PERSONAL DATA

• All Personal Data
  collected by Eltean shall be treated with confidentiality, to the best extent
  as is practicable or necessary. For the purpose of fulfilling and/or carrying
  out the Purposes set out in Part III above, Eltean may process, disclose,
  disseminate and/or transfer your Personal Data to the following parties, as
  follows: –

• any person to whom
  we are compelled or required to disclose pursuant to any laws in force in
  Malaysia;
• any related
  companies of Eltean, including but not limited to those located in different
  jurisdictions;
• any other third
  parties, including but not limited to, individuals, body corporates, agents,
  independent contractors, professionals engaged by Eltean for advisory purposes;
  and
• any government
  bodies, statutory bodies and/or regulatory authority.

• You also hereby
  consent to the disclosure of any of your Personal Data collected, retained and
  stored by Eltean to, governing bodies or relevant authorities) where such
  disclosure is requested or authorized by you, or necessary in the usual course
  of our business or to perform any services rendered to you

PART IV – SECURITY AND PROTECTION OF PERSONAL DATA

• All reasonable and practicable efforts and steps are taken to ensure that your Personal Data held by us are kept and protected to our best ability against data theft, unauthorized access, use, copying, disclosure or modification.

• We maintain strict policies and guidelines regarding our internal personnel’s authority to access records of your Personal Data. All our personnel are bound by a commitment of confidentiality to ensure that your Personal Data is being kept and maintained private and confidential, save and except for usage and disclosure of your personal data in accordance with the Privacy Policy.

PART V – RETENTION OF PERSONAL DATA

• Your Personal Data
  will be stored in printed form in any of Eltean’s physical offices or
  electronically in servers utilized by Eltean or any of our relevant service
  providers.

1. Any Personal Data
   collected, processed and used by Eltean will be retained for as long as is
   necessary for the fulfilment of the Purpose set out in Part III above and/or to
   comply with any statutory requirement in force in Malaysia from time to time.

1. All Personal Data
   of employees, customers, any other third parties which Eltean has an ongoing
   business and/or legal relationship with will be retained for as long as the
   employment, business or legal relationship continues to subsist.

PART VI – REQUEST TO ACCESS AND/OR UPDATE YOUR
PERSONAL DATA PROVIDED TO US

1. It is essential
   that you ensure that your Personal Data provided to us is accurate at all
   material times. As provided for in the PDPA, you have the right to request
   access, correction or modification to your Personal Data collected, retained
   and stored with us.

1. You may request for
   access, correction or modification to your Personal Data by contacting us in
   writing at the address and/or e-mail address below and specifying your request:

Eltean Incorporated Sdn. Bhd.
18 – 24, Medan Istana,
Bandar Ipoh Raya,
30000 Ipoh, Perak,
MALAYSIA

Attn: Personal Data Protection Department

E-Mail Address: eltean@eltean.com

PART VII – REVOKATION OF CONSENT TO PROCESS, USE,
DISCLOSE AND RETAIN PERSONAL DATA

1. You may, at any time, choose not to provide your Personal Data to us, or revoke your prior consent for us to process or use your Personal Data by writing to us at the address shown at Part VI – Paragraph 13 above. In any event, you are deemed to be aware that your failure to consent to our processing and usage of your Personal Data may result in our inability to provide you with our goods and services, or properly perform any business transactions, contractual arrangements, engagements in the usual manner.

PART VII – UPDATES & AMENDMENTS TO THIS PRIVACY
POLICY

1. This Privacy Policy
   will be reviewed from time to time to take into account new legislation and
   subsidiary legislation coming into force, changes or updates in our operations
   and best practices.

1. We reserve the
   right to amend and update this Privacy Policy from time to time. The most
   updated Privacy Policy will be uploaded on our Eltean Home Site at https://www.eltean.com/privacy.

If you have any enquiries or concerns regarding
this Privacy Policy, please do not hesitate to contact us by leaving us an
enquiry on our Eltean Home Site.

ver. Mar 2023