PRIVACY POLICY
PERFECT ENT HEARING AND SPEECH CENTRE SDN. BHD. and any of its holding, subsidiary or
related companies as defined in the Companies Act 2016 (collectively, “the Company”, “the
Group”, “PerfectHearing“, “we”, “us” or “our”) respects your rights with regards to your
personal information when you communicate with us.
We have developed this Privacy Policy to inform you how we collect, store, use, share,
process and protect personal information about our Distributors / Customer (“you”). It also
tells you how you can access and update your personal information and make certain
choices about how your personal information is used.
By using our websites applications, PerfectHearing Member’s Portal, perfecthearing.my or
by otherwise giving us your personal information you are accepting the practices
described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use
our websites or applications or give us any of your personal information. We reserve the
right to make changes to this Privacy Policy at any time. Any changes will be posted in this
Privacy Policy. We encourage you to regularly review this Privacy Policy to make sure you
are aware of any changes and how your information may be used.
If you have any requests concerning your personal information or any queries with regard to
this Privacy Policy, please Contact Us.
1. What does this Privacy Policy apply to?
This Privacy Policy applies to personal information that we collect from you or receive from
third parties that act on our behalf as our agents, contractors, service providers and/or
professional advisors that provide us administrative and business support (“Authorised Third
Parties”), or from our parent company and its subsidiaries anywhere in the world
(collectively “Related Companies”) about our Members / Customers. This Privacy Policy does
not apply to information outside of our possession, control or power.
Please note we may combine personal information that we collect via one method (e.g., a
website) with personal information that we collect via another method (e.g., an offline
event). We do this to get a more complete view of our Distributors, which in turn, allows us
to serve you better and with more customisation.
This Privacy Policy applies to all personal information collected by us including via:
• PerfectHearing websites, including any Member-directed websites operated by
PerfectHearing and pages that we run on third party social networks;
• PerfectHearing mobile sites and applications;
• PerfectHearing text messaging programmes;
• application or registration forms which we may collect from Members, whether
online or offline, including by post, during in-store demonstrations, or other in-
person events or contests;• any of PerfectHearing’s contests, events or campaigns;
• call centres;
• authorised Third Parties; and
• other sources (e.g. third party data aggregators).
2. What personal information does PerfectHearing collect and how does PerfectHearing
collect it?
Personal information or personal data is information that can be used to identify you on its
own or in combination with other data that we collect or have access to. In cases where
personal and other information is combined (e.g. personal contact information with account
login or demographic information), such information is considered to be personal
information).
We strive to limit the amount of personal information we collect and store to only that
which is reasonably necessary to provide you with the relevant services.
This Privacy Policy applies to all personal information collected by us such as –
• Personal contact information – information that would allow us to contact you
personally such as your name, home or mailing address, phone number or email
address. In some cases it would include information you give us about someone else
(e.g. if you provide a friend’s email address for a tell-a-friend programme).
• Account login information.
• Demographic information (e.g. date of birth, age etc.)
• Technical computer information (e.g. IP addresses, type of operating system, web
browser type) See further the answers to Question 8.
• Website Usage Information – information about how you use or navigate our
websites, applications, online advertisements including which links you click, which
pages you view and for how long, and other similar information and/or statistics
such as date and time of visit, which site you came from, favourite recipes and site
activities). See further the answers to Question 8.
• Member / Customer feedback.
• Member / Customer generated content – This includes information that you create
and voluntarily share with us (and perhaps others) by uploading it to one of our
websites or applications, including on our social network sites such as but not
limited to Facebook or Twitter.
• Social network information – this includes information that is part of your profile on
a third party social network (such as but not limited to Facebook) and that you allow
the third party social network to share with us.
• Payment information including your credit card details, billing name and address (for
example when you buy a PerfectHearing product online)• Other information which we might need to collect for a specific PerfectHearing’s
contest, event or campaign, form, feature or other service that you use or request.
• Sensitive personal information – This includes information about your physical or
mental health or your medical condition and your religious beliefs which was
gathered with your explicit consent at the point of collection.
3. How does PerfectHearing keep your personal information secure?
We take all reasonable technical and organisational measures to protect the confidentiality
and security of your personal information collected through the various methods described
in this Privacy Policy. These efforts include, but are not necessarily limited to:
(i) storing your personal information in secure operating environments that are not
available to the public and that are only accessible to authorised Perfect Hearing’s
employees, and Authorised Third Parties (defined in Question 1) who are contractually
bound to take reasonable measures to keep information secure);
(ii) ensuring sufficient security measures are implemented to protect the confidentiality
and security of certain sensitive personal information (such as credit card information or
health information) during transmission, and,
(iii) verifying the identities of registered users before they can access the personal
information, we maintain about them.
4. What purposes does PerfectHearing use your personal information for?
Your personal information will be used for the purposes for which you provided it to
PerfectHearing. It will also be used to administer, support and obtain feedback on the level
of our services and to prevent breaches of security, the law or our contract terms.
Additionally, we may use your personal information for the purposes set out below. Please
note that not all of the uses below will be relevant to every Member.
• Account & Membership maintenance, including administering any Member loyalty
or rewards programs that are associated with your account
• To conduct Member insight studies
• Customer / Member service
• Product improvement and customization
• Consumer / Member engagement
• Contests and other promotions
• Marketing communication
• Third party social networking, which may be integrated in our sites or applications
for the purposes of running contests, allowing you to share content with friends, etc.
• Website improvement and personalisation• Website community features such as sharing pictures, videos, artwork or other
messages or content
• Website viral features, which allow you to easily share certain news, product
information, promotions, wish list items, or other content with family members and
friends (typically using names and email addresses)
• Order fulfilment
• Other general purposes (e.g. website security, internal research, etc.)
By using any of the features and services described in Question 1 above, you consent to our
collection, use and disclosure (as the case may be) of your personal information as set out in
this Privacy Policy.
5. Who does the Group disclose or transfer your personal information to and why?
Perfect Hearing may share and transfer your personal information with our related
companies anywhere in the world including our parent company and its subsidiaries
(collectively our “Related Companies”), and Authorised Third Parties (defined in Question 1).
We may also share your personal information with co-sponsors and promotion partners.
This may involve, in some cases a transfer of your personal information outside Malaysia.
Please see Question 7– “Which countries will your personal information be sent to and
why?” for information on data transfers outside Malaysia.”
When you become a winner in a contest or participate in our events, we may publish your
name, photographs and other personal information without compensation for advertising
and publicity purposes.
If you do not want your information to be collected by or shared with a company other than
us, our Related Companies and our Authorised Third Parties (defined in Question 1), you can
always choose not to opt in or participate in these events at the time the personal
information is collected/requested.
Aggregate Information
We may share aggregated demographic or survey information with third parties, but this
information is in an anonymous form and does not contain any personal information. The
aggregate information that we share may include anonymous information that is captured
through the use of cookies and other similar Tracking Technologies, as explained in Question
8 below.
• We may disclose your personal information to government bodies and law
enforcement agencies if we are required to do so by law; or if in our good faith
judgement, such action is reasonably necessary to comply with legal process; to
respond to any legal claims or actions; or to protect the rights of Perfect Hearing, its
customers and/or the public.• We may also supply your personal information to potential acquirers of any relevant
PerfectHearing business.
6. How can you access, modify or make other choices regarding the use of the personal
information you send to us?
The following outlines the choices you have with respect to the collection and use of your
personal information by us.
You can opt out – You always have the option not to share any of your personal information
with us. However, if you choose this option, you will be limited in the activities and features
we can provide you.
How to opt out – If you do not want to receive communications and/or services from a
Perfect Hearing website or brand, please do not opt-in for those communications or services
at the time of registration. If you have opted-in and, at a later time, wish to opt-out, please
visit the appropriate opt out section(s) on our website or application and amend your
preferences.
What if I receive an email, message or another contact I am not expecting – Along with
every email marketing communication sent to you, we provide you the option to discontinue
receiving future marketing communications (i.e., unsubscribe). Simply follow the
unsubscribe process or directions provided in the email.
How do I know whether I am opted in – You can always review or update any personal
information that we may have collected about you. To do this, please visit the appropriate
opt out section(s) on our website or application.
If any of the mechanisms set forth above is not available or you wish to make a different
request or if you have any questions, complaints, or comments regarding this Privacy Policy
or our information collection practices please let us have your written requests or queries
at-
• Address: Perfect ENT Hearing and Speech Centre Sdn Bhd, No. 5,(Ground Floor),
Pusat Perniagaan Jubli, 20, Jalan Singa J 20/J, Seksyen 20, 40300 Shah Alam,
Selangor Malaysia;
OR
• Email: equiry@perfecthearing.my;
OR
• Contact us via WhatsApp: +6011 6515 5942 (Operating Hour: 09:00 am to 05:00 pm,
Monday to Friday)
7. Which countries will your personal information be sent to and why?
PerfectHearing may evolve into a global company and your personal information may be
transferred across borders. Your personal information may be transferred between RelatedCompanies (defined in Question 5) and Authorised Third Parties (defined in Question 1) of
the Group (parent company of PerfectHearing or sister companies or associate in which
PerfectHearing related to either direct or indirect ownership) located in different countries.
PerfectHearing takes the reasonably appropriate measures to maintain security of the
personal information both during transit and at the receiving location. PerfectHearing will
ensure that the country your data is transferred to has a similar or equivalent personal data
protection laws in place.
The server that makes our websites available may be located outside the country from
which you have accessed this website. All providers are bound by an agreement that ensures
a high standard of privacy protection and requires (amongst other provisions) that it act only
on PerfectHearing’s instructions and implements all technical measures necessary on an
ongoing basis to keep your personal information secure.
8. Tracking Technologies – How and why does PerfectHearing use them?
PerfectHearing uses Tracking Technologies to gain a better understanding how visitors use
this website. Tracking Technologies help us tailor PerfectHearing websites to your personal
needs, to improve their user-friendliness, gain customer satisfaction feedback on our
websites (through designated partners) and to communicate to you elsewhere on the web.
To enable this some Tracking Technologies are applied when you enter our sites.
PerfectHearing keeps all the information collected from these Tracking Technologies in a
non–personally identifiable format.
Please ensure that your computer setting reflects whether you are happy to accept cookies
or not. You can set your browser to warn you before accepting cookies, or you can simply
set it to refuse them, although you may not have access to all the features of this website if
you do so. See your browser “help” button for how you can do this. You do not need to have
cookies on to use or navigate through many parts of this and other STEMHEAL websites.
Remember that if you use different computers in different locations you will need to ensure
that each browser is adjusted to suit your cookie preferences.
9. What is SPAMMING and what is PerfectHearing’s position on SPAM?
Spamming is where advertisements or marketing related materials are communicated to
you either orally or in writing in an unsolicited manner and without your consent.
PerfectHearing DOES NOT send SPAM. STEMHEAL will not use your personal information
(including your email address, address, phone number) for direct marketing or follow-up
communications unless you give us your EXPRESS permission. This is called “OPT-IN” consent.
PerfectHearing websites give you the option to receive marketing information by email.
Every email sent by PerfectHearing will give you the option to stop receiving any form of
marketing materials at any time.If for some reason you believe you have received SPAM from the Company, please inform us
immediately. For contact details please see Question 6.
10. How long does PerfectHearing keep your personal information?
PerfectHearing may store the personal information that you send to us in its separate
databases. Your personal information will be kept by the Group only for as long as is
reasonably necessary taking into consideration our need to answer queries or resolve
problems, provide improved and new services and comply with legal requirements under
applicable law(s). This means that we may retain your personal information for a reasonable
period after you stop using PerfectHearing’s services or stop using PerfectHearing websites.
After this period, your personal information will be deleted from all systems in the Group.
We may keep aggregated demographic or survey information to be used internally, but this
information is in anonymous form and does not contain any personal information. The
aggregate information that we share may include anonymous information that is captured
through the use of cookies and other similar Tracking Technologies, as explained in the
Question 8 above.
We remind you that you have a right to have your personal information deleted at any time.
Please see Question 6 on how can you access, modify or make other choices regarding the
use of the Personal Information you send to us.
11. What is PerfectHearing’s policy on communication with children?
We believe that it is highly important to protect the privacy of children and we encourage
parents or guardians to spend time with their children to participate in and monitor their
activities, including e-activities.
We only collect personal information from children if parents or guardians provide consent
for the child to submit personal information and we will ask children only for the personal
information necessary to participate in the program for which the child is registering.
Children specific Websites
Special note to Children under the age of 18
If you are under the age of 18, we advise that you speak with your parent or guardian
BEFORE giving your personal information to PerfectHearing websites. If you are not sure you
understand something in this section, you should ask your parent or guardian for their help.
Special note to Parents of Children under the age of 18
We recommend that parents/guardians regularly check and monitor their children’s use of
email and other on-line activities.
Please make sure that your child does not give us personally identifiable information on-line
without asking your permission.You can, at any point of time, check your child’s personal information and have it changed or
deleted online. Alternatively, you can also ask us to delete any of your child’s information by
email/postal mail to the address given in contact details set out in Question 6.
12. Does PerfectHearing link to other third-party websites and what happens to my
personal information when this linking happens?
PerfectHearing links to other websites to offer you an opportunity to review connected and
interesting information related to PerfectHearing. These third-party websites are outside our
control and are not covered by this Privacy Policy. If you access other websites using the
links provided, the operators of these websites may collect your personal information.
Please ensure that you are satisfied with the Privacy Policies of these third-party websites
before you submit any personal information. Perfect Hearing is not responsible legally or
otherwise for the activities, privacy policies or levels of compliance of these third parties,
neither does PerfectHearing endorse the practices and content of any third-party websites.
13. What happens to my personal information when I email a PerfectHearing web page to
someone else?
Some of our websites may provide you with the opportunity to email a web page address to
another person. For this feature to work, we may need to collect your email address and/or
the email addresses of those you send the web page to. Email addresses collected in this
way are not used for any purpose other than to fulfil your request. These email addresses
are not stored and are deleted immediately after your request is fulfilled.
14. What happens to my personal information if I participate in a survey conducted by
PerfectHearing?
From time to time, we may ask our website visitors or customers or participants in any of
our campaigns, contests or other promotional event to answer survey questions. Surveys
generally will relate to the content of our websites, our products or categories of products.
We may ask for age or age ranges, gender, and/or other non-personally identifiable
information. For the purposes of these surveys, we may add information obtained from
Tracking Technologies (for online surveys) deployed to your survey answers but no
personally identifiable information will be requested. Personal information gathered from
polls and surveys are for PerfectHearing internal use only but aggregated (and non-
personally identifiable) information may be shared with others.
15. Can PerfectHearing change the terms of this Privacy Policy?
PerfectHearing will occasionally make changes and corrections to this Privacy Policy. Please
check this Privacy Policy regularly to see the changes and how these may affect you.