Updated on 30th November 2022

THIS PRIVACY POLICY MUST BE READ BEFORE USING THE WEBSITE. THE USAGE OF ANY PART OF THE WEBSITE INDICATES ACCEPTANCE OF THIS PRIVACY POLICY.

This QONI website and/or platform (“Website”) is operated by HYPE DMC TRAVEL SDN. BHD. Please read this privacy policy (“Privacy Policy”) carefully before using this Website and accepting the services offered by HYPE DMC TRAVEL SDN. BHD., or its specified affiliated companies (collectively, “we”, “us”, “our” or “HDT”) or the third-party operators (the “Operator”) through this Website (the “Services”). The Services that HDT provides via the Website include making available the Website and the online platform “QONI”, as a platform for the marketing, advertising, and sale and purchase of travel and tourism related goods and services between corporate buyer(s) and vendor(s) who are registered users of this Website (individually as “Buyer” and “Vendor”). “You”, “your” and “User” when used in this Privacy Policy includes any corporate authorised personnel who accesses the Website, whether a registered user or otherwise; (ii) a Buyer or a person for whom the Buyer makes a purchase on the Website; and (iii) a Vendor or a person for whom the Vendor makes a sale on the Website.

By accessing and/or using any part of this Website, you acknowledge that you have read and understood, and agree to this Privacy Policy and other terms and conditions in relation to this Website. If you do not agree to be bound by this Privacy Policy, please immediately discontinue your access to this Website.

Scope

This Privacy Policy explains how we collect, use, disclose and process your data, through your corporate use of and/or interaction with the Website and/or the Services offered. This Privacy Policy also sets out your rights and who you can contact for more information.

Change to Privacy Policy

We may change or update this Privacy Policy at any time where this is necessary to comply with any law or regulation binding on us or to reflect a change to our operational practices, so please check this Privacy Policy from time to time as your continued use of this Website signifies your acceptance of any changed term. If you navigate away from this Website to a third-party site, you may be subject to alternative privacy policies, as may be specified on such site. In such an event, the privacy policy applicable to that site will govern your use of that site.

How information is obtained

Personal data means information that relates directly or indirectly to you, which allows you to be identified or identifiable as an individual from that information, or from that and other information. Depending on the particular circumstances, we may collect and hold different personal data about you. For example, this may include:

  • information collected when you register or update as a representative of corporate user account on the Website, which may include your name, gender, national identification details, date of birth, email address, passport number, frequent flyer details, delivering/billing address, and contact details;
  • information submitted when you submit any form(s) through the Website, for example to request for more information or services or submission of bookings, which may include your name and contact details;
  • information required to complete transactions (selling or purchasing any products and/or services) through the Website, including payment details/financial information such as bank account or credit card details;
  • information submitted when your authorised travel agent submits any form(s) through the Website, for example to request for more information or services or submission of bookings, which may include your name and emergency contact details;
  • your account security credentials, such as username and passwords;
  • information about how you use our products and/or services, such as personalisation preferences you select as you use the Website;
  • information submitted if you participate in an online survey, campaign and/or contest through the Website;
  • information in connection with communications you send us, for example to report a problem or to provide feedback to us; and
  • where necessary, additional information as part of our user authentication process.

Each time you use the Website, we may automatically collect the following types of aggregated information:

  • technical information such as internet protocol (IP) address, type of internet browser and the operating system, which we may use to help provide a good user experience on the Website;
  • log information such as the date, time, duration and location of your visit to the Website and other forms of traffic data including your searches, orders and the type of content you interact with on the Website, which we may use to help us understand how users use the Website and to improve user experience; and
  • like most websites, we use “cookies” to help us understand your use of the Site, so we can improve our Website and your user experience. Cookies mean that a website will remember your computer by storing some information on the computer you use to access our Website. You may be able to block cookies via your internet browser settings, but this may prevent you from access to certain features of the Website. For information about blocking the use of cookies, please refer to the instructions/settings on your internet browser.

We reserve the right at our sole discretion to require further documentation to verify any information provided by you. If you decide not to provide us certain information outlined above which we consider as necessary, or you object to us using, collecting or processing such information, the consequences are that we may be prevented from conducting business with you and we may be unable to provide our products and services through this Website to you.

If you disclose to us any personal data of another individual, we shall assume, without independent verification and in reliance on your representation herein to us, that you have obtained such individual’s consent for our collection, use, disclosure and processing of such information in accordance with the terms of this Privacy Policy.

How the information is used

In addition to providing our products and/or services to you, we may use or disclose personal data that we collect about you for purposes including, but not limited to, the following:

  • to provide you with the products, services and information that you request from us;
  • to assist with and process your transactions or communications with third parties via the Website;
  • to provide your journey data and other associated reporting to the assigned business contact for your company information;
  • to administer your user account on the Website and your access to our Services;
  • to carry out know your customer processes, for purposes of verification and authentication of your identity, and evaluation of your credit and risk profile;
  • to assist you with enquiries, or to improve our customer service;
  • to communicate with you and provide customer service to you;
  • to allow other users of the Website to interact or connect with you for purposes of the products and services offered through the Website;
  • for our billing and account purposes;
  • to maintain our business relationships where you are a user of our Website and Services, or a customer;
  • to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical, audit and survey purposes;
  • as part of our efforts to keep the Website safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of the Website about services that may interest you or them;
  • to develop and improve our products and services;
  • to update our records;
  • to allow you to participate in interactive features of the Website, when you choose to do so;
  • to enforce any of our QONI Terms of Use or other terms and conditions applicable to your use of the Website or our Services;
  • to comply with any legal and regulatory obligations;
  • to deal with and/or facilitate a business asset transaction or a potential business asset transaction;
  • to provide you with a safe, smooth, efficient, and customised experience; and
  • to ensure that the content on our Website is presented in the most effective manner for you and your computer.

In limited circumstances, we may disclose collected information, including personal data, to certain third parties in connection with providing the Services or as required by law.

We may use non-personal data in a variety of ways, including, by way of example, to evaluate the performance of the Website and Services and the general preferences of users, or to generate anonymous statistics for our benefit or for our business partners. Because non-personal data is entirely anonymous, and therefore can never be used by us to identify you, this policy does not limit our ability to use or disclose non-personal data.

Information shared with third parties

As a necessary part of providing our products and services, we may disclose information collected from you to the following categories of third parties for the purposes outlined in this Privacy Policy:

  • we may disclose certain personal data about you to our affiliates, third-party service providers, agents and contractors (e.g., our third party payment processors), if this is necessary to provide you with our products and services, respond to your inquiries or for any other related purposes and so long as they are only using the personal data to provide services to us. We will ensure that if we share information with, or provide access to, third party service providers or affiliates, any such disclosure or access is at all times in compliance with applicable data protection legislation;
  • under certain limited circumstances, we may cooperate with legal investigations and/or we may be subject to legal requirements to disclose information collected through the Website or the Services, such as, by way of example, to a court or a governmental agency, and our policy is to provide such cooperation and comply fully with all such legal requirements;
  • we may also disclose personal data to protect or defend the rights or property of HDT (or its licensor(s)) or users of the Services and/or to investigate any violation or potential violation of the law, this Privacy Policy, or the QONI Terms of Use. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction; and
  • we may also share your personal data with third parties who support our information technology or handle mailings on our behalf and our professional advisers.

The disclosures contemplated by this paragraph (“Necessary Disclosures”) are necessary if you wish to use our products and services. We may use and disclose non-personal data without restriction. If you do not want us to make such Necessary Disclosures, or to use non-personal data without restriction, you must not use the Services.

Security

We use a number of mechanisms and take the necessary precautions, both administrative and technical, to protect the security and integrity of personal data. Unfortunately, no data transmission over the internet can be guaranteed as completely secure. Once any personal data comes into our possession, we will take reasonable steps to protect that information from misuse, theft, loss, unauthorised or accidental access, alteration, modification, destruction or disclosure. There are corporate security policies and procedures in place which among others confines access to your personal data to authorised personnel only on a strictly need-to-know basis. A username and password may be essential for you to use some sections of this Website. For your own protection, we require you to keep these confidential and to change your password regularly (if required).

Links

This Website may, from time to time, contain links to other websites which may be of interest to you. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy policies. We are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website.

How long we retain your information

We will only keep the information we collect about you for as long as required for the purposes for which it is collected or for business purposes, or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

If you choose to unsubscribe from our services or close a user account you have with us, please note that we may still keep your information to the extent required and/or permitted by law.

Access to your information

From time to time, this Website may allow you to register to use this Website or sections of it. If you are a registered user of this Website, you may be able to access and update the information on your user account in the applicable section of this Website, subject to any authentication and authorisation considerations, which exist to protect your security.

If you wish to request access to or correction of any other personal data which we hold about you as a result of our information collection practices outlined in this Privacy Policy, please refer to the “Contact Details” section below.

Contact details

Please contact our Privacy Officer using the details set out below if you wish to:

  • ask any questions or provide feedback about this Privacy Policy;
  • make a request for access or correction to any personal data that we may hold about you;
  • withdraw consent to our use of your information for any particular purpose;
  • make a complaint about the way in which we have handled your personal data; or
  • make any other queries relating to your personal data.

Any information that we provide in response may be limited to the extent permitted by any applicable law. In withdrawing your consent for our use of your information as requested, we may not be able to offer you with the relevant services and/or fulfil your requests or respond to your enquiries. If this is the case, we will inform you of the consequences in further detail depending on the specific category of personal data.

For any questions or comments on our Privacy Policy please contact our Privacy Officer at [email protected].

Prevailing language

This Privacy Policy is prepared in English and Bahasa Malaysia. The prevailing language of this Privacy Policy is English and any dispute arising from this Privacy Policy will be settled to the extent permitted by law based on the English version of this Privacy Policy.