iLyF connects and protects your family and friends and keeps them safe through built-in insurance and smart geolocation features. We are dedicated to preserving your privacy and take it as seriously as you do. This Privacy Policy tells you how we collect, use, share, transfer, store, and protect your personal information that we get from our products and services, as well as what you can do about it.

SyncWealth Sdn Bhd (“us”, “we”, or “our”) operates https://ilyf.io and iLyF mobile application (hereinafter referred to as “Service”). As you review our policy, keep in mind that it applies to iLyF, Inc.’s ("iLyF", "we", "our", or "us") websites, mobile apps (iLyF), help center and other associated services we provide (“Services”).

It also applies to partner products that have the iLyF technology embedded within them) Please read this Policy carefully and make sure you understand how we collect, store, use, and disclose your personal information before utilizing our Products and/or Services.

I. INFORMATION WE COLLECT

The information iLyF collects depends on what iLyF Products or Services you use and how you use them.

Note that failure to provide necessary information when requested may result in you not being able to fully utilize our Products and/or Services.

A. Information You Give Us Directly

When you create or modify a iLyF account, update your preferences, purchase and/or activate a Product, contact us (including by social media), participate in an online survey, or otherwise interact with iLyF’s Products and Services, we may collect a variety of information, including:

• Account Information. Your username, email address, real name, nicknames, date of birth, telephone number, password, shipping and billing addresses, and Products activated. You may also choose to provide a photo to associate with your iLyF account
• “Tribe” Information. When you create a Tribe in your iLyF app and invite a friend or family member to join your Tribe, we collect their name, email address, mobile phone number, and photo if one is provided.
• Identity Verification. In certain circumstances, for instance, depending on the features of our Products and Services you use or based on your age and relevant country of residence, we may collect additional information to verify that your parent or guardian has consented to your use of the Services which may include an image of their government-issued ID along with a selfie image which are used with facial recognition technology to produce a unique biometric identifier based on facial geometry.
• Payment and Transaction Information. When you place an order for a Product or upgrade to a premium subscription, you’ll need to provide an email address, a first and last name and/or a shipping address. Any payment information provided is processed by the relevant billing and/or payment processor. We may also collect information such as which version of the Product or subscription service you are using, the date and time that you activated your account, the duration of your subscription, the data related to any subscription cancellation request, and any in-app purchases you may make.
• Optional Account Information. You may also customize your in-app map by labeling locations, such as “work” and “home,” to make it easy to spot your favorite places and to provide alerts when Tribe members leave and arrive using the “Smart Alert” feature.
• Contest Prize and Tax Information. If you are the recipient of a contest or sweepstakes prize that requires tax reporting, we may collect identifiers associated with your government-issued documents (such as a social security number).
• Other Information You Provide to Us. Information you provide in response to surveys about our Products or Services; any information about your friends that you provide us through our referral services, any information or content that you voluntarily submit or post to the iLyF or Tile websites or blogs, or comments you post to our Facebook page (or other social media pages), information you provide when seeking help from us, such as your name, email address, telephone number, mailing address and records (including call recordings) and technical information related to the issues you experience.

B. Information We Collect When You Use or Interact with our Products and Services

We may collect other information when you use our Products and Services, such as:

• Device Information. Information about your device, hardware and software information, such as your mobile device identifiers, IP address, or browser information (including browser type and language preference),
• Location and Movement Information. We collect your location and motion information through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device, motion information such as altitude, heading and speed.
• Driving Event Information. We may collect sensory and motion data from your mobile device including gyroscope, accelerometer, compass and Bluetooth (including, information related to your motion activity such as whether you are cycling, walking running or driving, and information about your speed, acceleration and deceleration).
• Messages and Member Content. We collect information when you message other members of your Tribe through use of our Services, when you provide iLyF with feedback, when you make a blog post, comment, or when you tag iLyF in a social media post, any photos or videos your send via the messaging to other members of your Tribes.

Certain data we collect may be considered sensitive under applicable law. When we collect sensitive personal information, we only use it for the purposes that we say we will and in accordance with the law.

C. Information Provided to Us by Third Parties

We may receive information about you from other sources, including through third-party services that you connect to your iLyF account, or third-party services and organizations to supplement information provided by you. For example:

• When you add your vehicle to our platform to enable aggregation and comparison of vehicle insurance price as well as road tax renewal details, we may collect vehicle details for successful VIX API requests of all added vehicles of yourself and Tribe.
• When you choose to connect or interact with our Services through a third-party social networking service (“Social Network”), such as when you Like us on Facebook or post a comment to our Facebook page, we may collect information that you have already made public on your Social Network account.
• We may use social plugins, widgets and other features (each, a “Social Feature”) that are made available by and/or access third-party Social Networks. These Social Features allow these Social Networks to place cookies on your browser and to collect certain information, which may be associated with your personal Social Network account such as your name, your Social Network user identification number, your Social Network username, location, gender, birth date, email, profile picture, and your contacts on the Social Network.

II. HOW WE COLLECT INFORMATION

When you visit our websites, use our apps, read our emails or otherwise engage with us, we may automatically collect certain information about your device through a variety of technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “Tracking Technologies”), and we may combine this information with other personal information we collect about you. We use these Tracking Technologies to collect usage and device information, such as:

• Information about the computer, tablet, smartphone or other device you use, for example, your device’s telephone number (if it has one), your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, whether the device is connected to WiFi, and other such information. With your permission, we may also access your photo or camera roll.

We also use Analytics, Advertising, and Anti-Fraud technologies in our Products and Services. These technologies may utilize the same cookies or similar mechanisms as further described below.

A. Cookies and Similar Technologies

Cookies are pieces of code that allow for personalization of our website experience by saving your information such as user ID and other preferences – if your browser is set to accept cookies. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes.

Web beacons (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the member’s device, web beacons are typically embedded invisibly on web pages (or in an e-mail).

For more information about the Cookies we use and how to manage their setting please click on “Do Share My Personal Information” page

B. Analytics and Advertising Technologies

We may collect analytics data, or use third-party analytics tools such as Google Analytics, which may use Tracking Technologies, to help us measure traffic and usage trends for our websites, Products and Services. They types of data that analytics technologies may capture are as follows:

• referral/exit pages;
• how frequently you access our Services;
• whether you open emails or click the links contained in emails;
• whether you access our Services from multiple devices;
• rthe features you use;
• the links you click;
• the ads you view and click on;
• purchase transaction information;
• your location when you access or interact with our Products and Services;
• technical related information about your computer or device and operating and/or network systems (such as IP Address and device ID);
• information about your engagement with certain features and usage statistics; and
• other similar actions.

We may collect and share your personal information, including your unique identifiers or Advertising IDs and other data such as app events, third-party ad networks, social media companies, including without limitation, to inform and improve tailored advertising, attribution, analytics or research purposes.

These advertising partners collect and use information such as:

• click stream information; timestamp; hashed email address; device ID or AdID; and
• your use of third-party applications.

and may combine this information with information they collect directly through Tracking Technologies or that they receive from other third-parties. These third party partners may use the information they have gathered independently according to their own privacy policies.

You have the right to object to and opt-out of certain third-party tracking and advertising. Where you have consented to iLyF’s processing of your information, you may withdraw that consent at any time and opt-out of certain processing activities, such as targeted marketing communications. Even if you opt-out, we may still collect and use information regarding your activities on our Sites and/or information from the advertisements on third-party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.

II. HOW WE USE YOUR INFORMATION

We may use and disclose your information to service providers that provide, maintain, and improve our Products and Services to develop new products and features, to determine which new products or services may be of interest to you and to promote our Products and Services.

We retain the information we collect for as long as necessary to provide our Products and Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.

We may also remove your name from the information we collect, make it anonymous, group it with other information, or collect it in a way that doesn't directly identify you. We could use and share this information as needed for our business and as allowed by the law.

The specific purposes for our acquisition, retention, use, and processing of your information are described in this Section III (How We Use Your Information).

A. Administrative Purposes

We may use information about you for our administrative purposes, including to:

• Provide the Products and Service to you;
• Measure interest in iLyF’s Products and Services;
• Develop new products and Services;
• Ensure the integrity, security and perform internal quality control and optimization of our Products and Service;
• Verify individual identity;
• Communicate about individual accounts and activities utilizing iLyF’s Products, Services, and systems;
• Make changes to any iLyF policies;
• Send messages to the email address you provide to us to verify your Account;
• For informational, transactional, marketing and operational purposes, such as Account management, customer service, or system maintenance;
• To process payment for products or services purchased;
• To process applications and transactions;
• To prevent potentially prohibited or illegal activities; and
• To enforce our Terms of Use and this Privacy Policy.
• To refer you to the loan, insurance and/ or financial product(s), and/ or financial institutions (or their authorized representatives) specified by you upon completion of application forms on our website.
  
  For more information, please refer to the respective privacy policy links below:
  https://www.zurich.com.my/en/customer-hub/show-me-more-info/personal-data-protection-notice
  https://www.generali.com.my/data-privacy-notice
  https://www.libertyinsurance.com.my/resources/pdpa

B. Marketing iLyF Products and Services

iLyF may use information, and Individuals who provide us with personal information may receive periodic emails, newsletters, mailings, or phone calls from us, as allowed by applicable law, for marketing purposes such as to:

• Provide you with information related to iLyF’s or our business partners’ products and services that may be of interest to you;
• Notify you of upcoming special offers/events we believe may be of interest;
• Conduct individual or market research;
• Conduct research and drive marketing analytics;
• Conduct online behavioral advertising;
• Tailor content, advertisements, and offers that may be of interest;
• Introduce new content, features, Products or Services;
• For other purposes disclosed at the time that you provide us your information; or otherwise with your consent.

C. Research and Development

We may use information to make non-directly identifying information, which we can use on its own or in combination with information from other sources, as described here, to:

• Help us to optimally deliver our existing Products and Services;
• To develop new Products and Services;
• To develop behavioral modeling;
• For research, and internal analysis;

For example, iLyF may use surveys to do research (both online and off) from time to time. We may hire third-party service providers to do these surveys for us (all responses to surveys are optional). The survey responses may be utilized to:

• Determine the effectiveness of our Products and Services,
• To develop new Products and Services;
• Perform various types of communications, advertising campaigns, and/or promotional activities.
• Learn more about our members and potential members and their individual and collective needs

If an individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analytics purposes.

D. Information Collected Automatically Through the use of Tracking Technology

We use information collected through the use of Tracking Technologies (e.g. cookies and web beacons) to:

• Remember information so that you will not have to re-enter it during your visit or the next time you visit our website or use our Services;
• Authenticate your access;
• Keep track of your in-app specified preferences or choices;
• Display a personalized browsing history;
• Provide custom, personalized content and information, including targeted content and advertising;
• Record your device’s location and movements;
• Identify and contact you across multiple devices;
• Provide and monitor the effectiveness of our Services and our marketing campaigns;
• Monitor aggregate metrics such as total number of visitors, members, traffic, and demographic patterns;
• Provide specific technical support (diagnose or fix technology problems reported by our members or engineers that are associated with certain IP addresses or User IDs);
• Detect or prevent fraud or other harmful activities;
• Automatically update our mobile application on your system and related devices; and
• Otherwise plan for and enhance our Services.

IV. INFORMATION WE DISCLOSE TO THIRD PARTIES

We disclose your information to select third-parties as well as our subsidiaries as set forth below.

We won't give your personal information to third parties without your permission, except in the ways that are described in this Privacy Policy.

We may also use and disclose your information for our protection and the protection of others to prevent fraud, misappropriation, infringements, identity theft, and other illegal activities and misuse of our Products and Services.

We may share this information within iLyF, with our subsidiaries, and with third parties for our or their purposes in a way that makes it hard for anyone to find out who you are, such as by making it anonymous or by putting it together with other people's information.

A. Disclosing to Others in Your iLyF Tribes

Depending on which tools and functionalities are enabled, you may choose to disclose your personal information to other members of your iLyF Tribe , including your:

• Full name;
• Email address;
• Precise location;
• Driving event data;
• Information about your use of our Service with members of your Tribes (e.g., whether you have logged in on a new device); and

To prohibit this data disclosure, you must ask your Tribe member to disconnect his or her account, or you can leave the Tribe shared with that member.

B. Third Parties that Provide Features You Use in Connection with our Services

We may disclose personal information, including contact information and location and movement data, mobile device information (such as information generated by the gyroscope and accelerometer in your device), application analytics (including IP address and device identifiers), technical and analytical data, and driving event data with third-party partners that provide certain features and services you elect to use through or in connection with our Products or Service, to the extent that they are available in your country or region of residence.

C. Information Posted to our Blogs, Community Forums or Other Public Websites

Any information or content that you voluntarily submit, or post to the iLyF websites or blogs, community forums, or comments you post to our Facebook page (or other social media pages) will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile app or link your reviews to third-party websites.

We are not responsible for any information you choose to provide on social media pages, or for any content or communications you receive as a result of sharing such information.

To request the removal of your information from our website or blogs, please contact us at [email protected]

D. Service Providers, Business Partners, and Advisors

We may share your personal information with our vendors and consultants who perform services on our behalf or help us provide our Services, such as accounting, management, technical, email or chat services, marketing or analytic services, fraud prevention, bot detection, and web hosting. We may also share your personal information with other third-party partners or service providers who have contractually agreed to process personal information only as needed to provide services or features to you.

At this time, we do not disclose personal information related to individuals who access our Services from the European Economic Area, Switzerland, the United Kingdom, or Korea to third parties for their independent marketing and/or monetization purposes. If we decide to give personal information of people who live in the EEA, Switzerland, the UK, or Korea to third parties for their own use in the future, we will first give those people the chance to say "yes."

Importantly, and for the avoidance of doubt, locations associated with your identity as reflected on iLyF.io website or iLyF app will not be sold to or monetized by third parties even in aggregated form.

We will never share your phone number (in a way that doesn't hide it) with any of our third-party business partners, vendors, or consultants for their own SMS marketing purposes unless you give us your explicit, opt-in permission.

E. Purchasers and Other Third Parties in Connection with a Business Transaction

We reserve the right to buy, sell, or otherwise get rid of the company or any part or combination of its products, services, assets, and/or businesses at any time. Personal information, such as member names and email addresses, and other member information related to our Services will likely be one of the items transferred in these types of transactions. We may also share, transfer, or give away this information as part of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, or other similar transactions or proceedings.

F. Law Enforcement, Regulators, and Other Parties for Legal Reasons

We may disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) when required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, this Privacy Policy, to take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of iLyF, our employees, members or others.

G. De-Identified Information

We may share with third parties, including advertisers and service providers, anonymized, aggregated, and/or anonymous data we collect about you and other members, such as de-identified demographic information, de-identified location information, and information about the computer or device from which you access our Services, or the results of hashing your email address.

V. YOUR CHOICES ABOUT YOUR INFORMATION

We believe in transparency and providing you with the opportunity to make important decisions about how your information is used, processed, stored, and shared, as outlined in this Section V (Your Choices about Your Information).

A. Modifying, Correcting, Reviewing, and Deleting Your Information

You may modify your account information, update or amend your personal information (e.g. name, email address, or phone number), or change your password by logging in to your App, clicking on “Settings” and then “Account” (for iLyF) or “Manage Account”

You can look at the information we collect or share about you, as well as the sources of that information, the business or commercial reason we're collecting it, and the types of third parties we share it with. You can also ask for your information to be deleted by filling out the form below. Please note that the information provided via the in-App links described in this section does not include technical information or support records. If you would like to request information related to your support records, please contact us directly at [email protected]
In the iLyF app, you may:

• Exercise your right to Opt In or Opt Out of App-based personal information sales or sharing by clicking on the “Do Not Share My Personal Information” link in your in-App Privacy & Security settings and adjusting the personal information sales toggle.
• Request a copy or deletion of your personal information under the “Additional Data Rights” page, then, select “Request Your Personal Information” or “Delete Your Account” to submit your request. We will process your request and send a confirmation email.

You can also ask for your account to be closed and deleted by sending us an email at [email protected]. Please include your full name, mobile number associated with your Account, the service you are using, and a detailed description of your deletion request. Please be aware that we will only retain the information required by applicable law, as detailed below in Section VII(F) (Data Retention).

B. Communications from iLyF

We may periodically send you promotional newsletters and emails. You have the ability to opt-out of these by following the unsubscribe instructions provided in the emails you receive or under Notification setting in-app. Certain communications, like billing information and Service updates, are necessary for you to receive; you will not be able to opt out of those communications. For more information about the types of communications iLyF may send, and for detailed instructions on how to opt-out please see the following (note, some jurisdictions may require your consent prior to receiving promotional messages)

C. Location and Movement Data Collection and Sharing in the iLyF App

As described in Section 2, we collect precise location data and driving event and movement data from your device to provide the iLyF Services and may share your personal information, including location and movement data, with other iLyF members in Tribes you belong to and with third parties for crash detection, research, analytics, attribution, and tailored advertising purposes. You have many options to control this data collection and sharing activity through the app settings.

If you no longer want to continue using the Products and/or Services, uninstalling the iLyF, and logging out from our Service will also stop us from collecting your location.

D. Web-Based Personal Information Sales

You may also exercise your opt In and opt out rights related to web-based personal information sales or sharing via all of our websites, please click the “Do Not Share My Personal Information” link in the footer of the website and adjust the toggles as applicable.

Please note that these settings must be completed for each browser on each device you use and for each of our websites (iLyF.io) separately, and will not affect app-based settings. If you clear your cookies or your browser is set to do so, you will have to exercise the choice again. If you wish to modify how data is collected through the iLyF, you must do so separately by following the instructions above. If you have not visited our sites, no action is required.

VII. HOW WE PROTECT YOUR INFORMATION

iLyF cares about the security of your information and we take great efforts to protect your personal information. We cannot guarantee and you cannot reasonably expect that our databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

A. Security

We have implemented appropriate standards to reduce the risk of unauthorized or unlawful access to your personal information. No security system is impenetrable, and we cannot absolutely guarantee the security of our systems and your information.

We will never send you unsolicited messages or contact you by phone to request sensitive information. This may include account ID, password, payment, or national ID numbers. Please note that e-mails and other communications you send to us are not encrypted, and we strongly advise you not to share any sensitive information through these means.

If any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify the impacted individuals and take steps in accordance with any applicable laws and regulations.

B. Accuracy and Confidentiality of Your Mobile Number and Password

You are in charge of keeping any account authentication a secret and making sure the mobile number linked to your account(s) is correct. We use your mobile number to contact you about service updates, changes to our policies, and account activities such as requests for your information. If you think your account has been hacked, please contact as immediately

If a member gives the wrong phone number or email address, iLyF is not responsible for any information or data that gets sent to a third party

C. Onward Transfer

When information is sent to third-party agents working on our behalf, iLyF is still responsible if its agents handle the information in a way that goes against local principles or other laws. We might have to give out personal information in response to legal requests from public authorities, such as to protect national security or enforce the law.

F. Data Retention

iLyF retains the information we receive as described in this Privacy Policy for as long as you use our Products or Services or as otherwise necessary to fulfill the purpose(s) for which it was collected, to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business interests, enforce our agreements, and to comply with applicable laws. Our decision about how long to keep information is based on the amount, type, and sensitivity of the information, the reasons why we use it, any legal requirements, and our own legitimate interests. Different types of information may need to be kept for different lengths of time based on the reasons we use them.
You also have the following rights with regards to your personal information as follow:

• The right to opt-out of personal information sales and shares for cross-context behavioral advertising;
• The right to limit our use of your sensitive personal information;
• The right to correct inaccurate personal information about you;
• The right to delete certain information we have about you;
• The right for us to provide you with information about the financial incentives that we offer to you, if any;
• The right to not receive discriminatory treatment for exercising these rights.

Certain information may be exempt from such requests under applicable law. For example, we may retain certain information for legal compliance and to secure our Services. We may need certain information in order to provide our Services to you; if you ask us to delete it, you will no longer be able to use our Services.

A. Categories of Personal Information Collected

Depending on your use of our Services, the following categories of personal information may have been collected in the preceding 12 months (as these processing activities are defined under applicable privacy laws, such as the Malaysia Consumer Privacy Act “CCPA” and the Malaysia Privacy Rights Act “CPRA”):

• Identifiers; such as a real name, user name, account name, account information, ID verification information, telephone number, email address, online identifiers, device identifiers, IP address, mobile device identifiers, shipping address;
• Purchase information; such as payment card number, payment account details, billing address, and other payment information;
• Characteristics of Protected Classifications under state or federal law; such as age, gender, ethnicity, and race;
• Commercial Information; such as products or services interaction, motion, and fitness information, and purchase history;
• Internet or Electronic Network Activity information; such as browsing history, search history, and information regarding interactions with our Products and Services, websites, mobile apps, and/or advertisements;
• Geolocation Information; such as location data derived from IP address or device settings;
• Inferences; such as consumer preferences drawn from the above.

B. Legal Basis for Processing

Our legal basis for processing your personal information varies depending on the type of information we collect and the context in which we collect it, as well as our records of your country of residence. Depending on where you live, we may process your information using different legal bases.

We will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and/or where we have a legal obligation to process your information. For example, we typically rely on:

• Necessity to meet an actual contractual obligation when you create an iLyF account to enable us to provide you with our Products and Services.
• Consent when placing cookies on your device on the web (through our cookie consent manager), to send you email marketing, or to deliver third-party targeted advertising to you related to our Products and Services;
• Our legitimate interests to process your information when providing you with customer service support, to serve targeted marketing of our Products and Services, for fraud prevention and security purposes;
• To fulfill our contractual obligations; and
• Necessary for compliance with a legal obligation to which we are subject.

IX. LINKS TO OTHER WEBSITES AND SERVICES

Our Services may contain links to websites and services that are owned or operated by third parties. Any information that you provide on or to a third-party service, or that is collected by a third-party service, is provided directly to the owner or operator of the third-party service and is subject to the owner’s or operator’s privacy policy. Please remember that when you use a link to go from the iLyF Services to another website or app, or engage with a third-party service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction, on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies, and iLyF is not responsible for the practices employed by those apps, websites, or services, nor the information or content contained therein.

X. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, so please review it frequently. We'll notify you of material changes thirty days before they go into effect. If we are required by applicable data protection laws to give you enhanced notice or seek out consent to any such changes, we will do so. Otherwise, changes to this policy will be effective when posted.

If you object to any of the changes to this Privacy Policy, you must cease using our Products and/or Services, and may request us to erase your personal information. Any information that is collected through your use of our Products or Services is covered by the Privacy Policy in effect at the time such information is collected.

XI. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS

If you have any questions about our privacy practices, this Privacy Policy, our Products, or

A. Authorized Agents

You may authorize another person (your “agent”) to contact us on your behalf. Authorized agents must submit the request via email to [email protected] and include a signed letter from the iLyF member confirming the agent has permission to submit the request on the member’s behalf. In certain circumstances, we may need to request additional information to verify the identity of the member about whom the request is being made and/or to verify that the member has provided the authorized agent permission to submit the request, and it may take additional time to fulfill agent-submitted requests. Please note that for privacy and security reasons, we will direct future communications to the iLyF member on whose behalf the request was made. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.

B. Right to Contact a Data Protection Authority

You also have the right to contact your local Data Protection Authority if you prefer. We are subject to the investigatory and enforcement powers of the Malaysian authorities

XII. HUMAN RESOURCE INFORMATION

We collect information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a Curriculum Vitae (CV) or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin, veteran or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.

We acquire, hold, use, and process human resources data for a variety of business purposes including: workflow management, including assigning, managing and administering projects; Human Resources administration and communication; payroll and the provision of benefits; compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs; job grading activities; performance and employee development management; organizational development and succession planning; benefits and personnel administration; absence management; helpdesk and IT support services; regulatory compliance; internal and/or external or governmental compliance investigations; internal or external audits; diversity and inclusion initiatives; restructuring and relocation; emergency contacts and services; employee safety; compliance with statutory requirements; processing of employee expenses and travel charges; and acquisitions, divestitures, and integrations.