Privacy Policy
At 27Gems LLP (t/a “Vicinity”) (“We”, “our”, “us”) one of our main priorities is protecting and respecting the privacy of our users. This Privacy Policy, together with our Terms of Use and any other documents referred to in it (set out on our website https://vicinity.centre/) set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
​
Vicinity strives to be an identity-blind app, meaning that Vicinity and other third-parties should not have access to your personally identifiable information (PII) (such as name, mobile phone number etc) unless identification is strictly necessary. One such verification use case is to verify in-app your identity as a member to a club which you are a member of.
​
Any personally identifiable information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. Once the reasons has been fulfilled, any submitted personally identifiable information will immediately not be accessible in-app by Vicinity and other third-parties, and you would be requested to submit again at another verification check.
​
By becoming a user of Vicinity, you will receive a Universal ID, and this Universal ID will be used as your identity in the app and app ecosystem.
​
​Please read the following carefully to understand our practices regarding your personal data and how we will treat it. If you have additional questions or require more information about our Privacy Policy, please do not hesitate to contact us. All your data will be held and used in accordance with the Personal Data Protection Act 2010 (“PDPA”) and any legislation that replaces it in whole or in part.
Consent
By using our website https://vicinity.centre (our “site”) and/or mobile application (our “app”), you hereby agree to the terms of our Privacy Policy.
Information We Collect
We may collect and process the following data about you.
​
Information you give us:
You may give us information about you by registering on our site or app or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to receive updates on our services, enter a competition, promotion or survey, make an enquiry, provide feedback and/or when you report a problem with our site or app. The information you give us may include your name, address, email address and phone number. The personal information that you are asked to provide and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
​
We may also collect:
-
Technical information, including the internet protocol (IP) address used to connect your computer to the Internet, any login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform;
-
Profile data, including your username and password, your interests, preferences, feedback and any survey responses;
-
Usage data, including information about how you use our website, products and services;
-
Marketing and communications data, including your preferences in receiving marketing from us and our third parties and your communication preferences;
-
Information we receive from other sources: We may also receive information about you if you use any other websites we may operate or other services we provide. We are also working closely with third parties, including Dataswyft Sdn Bhd, and may receive information about you from them.
Our site and app are not intended for children and we do not knowingly collect data relating to children. If you think that a child provided this kind of information on our site or app, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
How We Use Your Information
On information you give us, we will use this information to:
-
carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us or we have agreed to give you;
-
notify you about changes or developments to our site, app or services we provide;
-
communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to our site app, and/or services; and
-
provide you with information about other products and services we offer that are similar to those in relation to which you have already registered to receive information.
-
​
On information we collect about you, we will use this information to:
-
as part of our efforts to keep our site and your access safe and secure;
-
provide, operate, and maintain our site, app and the Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
-
improve and personalise our site and app to ensure the content is presented in the most effective manner for you and to expand our site, app and services;
-
understand and analyse how you use our site and app; and
-
develop new products, services, features, and functionality.
-
​
On information we receive from other sources, we may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
​
We will only contact you by email with information about products and services similar to those in which you have shown an interest, and you will be given an option to unsubscribe with each communication. If you do not want us to use your data in this way, please email us at vicinitycenter@gmail.com
​
In some circumstances, we may ask for your consent to process your information in a particular way.
​
We may share your personally identifiable information with selected third parties including:
-
The businesses which you subscribed as a member;
-
Dataswyft Sdn Bhd for the purposes of creating and administering your personal data account; and
-
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use (as set out on our site and app), or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud and scam protection.
-
​
We may share your non-personally identifiable information with selected third parties including:
analytics and search engine providers that assist us in the improvement and optimisation of our site.
Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
​
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where we have given you (or where you have chosen) a password which enable to access certain parts of our site or app, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
​
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
​
We will only retain your information for as long as necessary to fulfil its purposes, including for the purposes of satisfying any legal, accounting or reporting requirements. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept, the sensitivity of the data and the potential risk of harm from unauthorised use or disclosure.
CCPA Privacy Rights
Under the CCPA, among other rights, California consumers have the right to:
-
Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
-
Request that a business delete any personal data about the consumer that a business has collected.
-
Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
GDPR Data Protection Rights
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
​Children’s Information
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
​
Vicinity does not knowingly collect any Personally Identifiable Information from children under the age of 18. If you think that your child provided this kind of information to us, we strongly encourage you to contact us immediately.