Updated as at 3 April 2023

  1. Introduction

We love our community at Rebonics Sdn Bhd [202301006118 (1500038-M)] a Carousell Group company. It is extremely important to us that you not only have a pleasant experience buying and selling, but also that you feel comfortable and safe while doing so.

This Privacy Policy supplements Our Terms of Use  and explains how Rebonics Sdn Bhd, its subsidiaries and affiliates (“ Laku6 ” or “ Us ” or “ We ” or “ Our ”) that link to this Privacy Policy, handle information collected and received in the course of your use of Our websites, mobile applications and services (collectively, the “ Services ”). It also governs the collection, use and disclosure of your information.

For the purposes of this Privacy Policy, “ Personal Data ” shall have the meaning defined in the Personal Data Protection Act 2010 of Malaysia (“ PDPA ”), and shall include any Personal Data of any individual that you submit to Us via the use of the Site and Services.

General

By accessing and/or using the Services, you acknowledge you have read Our Terms of Use and this Privacy Policy, and that you expressly agree to the Terms of Use and expressly consent to Laku6’s collection, use, disclosure, and processing of your Personal Data in accordance with this Privacy Policy. If you do not agree to the Terms of Use and/or do not consent to such collection, use, disclosure and processing of your Personal Data, please do not access or use Our Services.

By providing Personal Data to Us, you consent (or if you are providing Personal Data of another person, you represent that you have the requisite authorisation and consent on that person’s behalf) to Laku6 collecting that Personal Data and using, disclosing and processing it in accordance with this Privacy Policy or as permitted or required by law. If you do not consent to such collection, use, disclosure or processing, please do not provide the Personal Data.

We reserve the right to amend this Privacy Policy at any time in accordance with the relevant laws and regulations.

  1. Data Collection and Use

We collect and use your Personal Data to provide you with the Services, and to customise and improve the Services to make your experience more secure and convenient. We only collect Personal Data about you that We consider reasonably necessary for achieving these purposes.

Information we collect and receive

  1. We may collect and receive the following information from you, which include but are not limited to:
  1. Your particulars.  Your name, identification/passport number, data of birth, gender and nationality. We are required to collect, verify and maintain the above information to comply with requirements from regulators.  
  2. Your contact details.  Your email address, telephone number and postal address;
  3. Your payment information.  Your credit card, bank account details and other payment information;
  4. Your account data and electronic identification data. Your Laku6 account (if you have registered for an account with Us) and other electronic identification data (such as IP address, IP domain, location) and the data you add to your Laku6 account (such as your password, your date of birth, your age, your gender, and other information you may share with Us);
  5. Information relating to your use of the site and Services.  Your viewed pages, your clicked links and your viewed content; and
  6. Your online purchases.  Data from your purchases from Us, such as purchase date, purchase amount, purchased product, payment method, payout option, delivery method, and any information you may provide regarding your online purchases.
  7. Your reviews and communication information.  Product reviews, Services reviews, feedback, experiences, testimonials, preferences and interests that you publish or share with Us online or through Our social media, including any requests or complaints you may have submitted together with any data that We receive via emails, online, or through Our social media.
  8. Other information . Any Personal Data as We may deem essential or appropriate from time to time to provide the Site or Services to you.

Please note that not all of our Services collect all of the information listed above.

  1. We may collect and receive information from you in the following situations:

  1. When you register for an account with Us (“ Account ”).
  2. When you use the features and functions available on Our/through Services, for example by selling your mobile device and using Our diagnostics scan services, participating in a Trade-In with Us and Our Partners;
  3. If you contact us, for example, with a query or to report a problem, whether by electronic means or otherwise.
  4. When you use the features and functions available on Our Services, for example, by creating listings, interacting with other users through Our chat feature, or transacting with other users.
  5. When you register or opt-in for a survey, campaign, contest and/or lucky draw.
  6. When you interact with Us offline or through an external third party.
  7. When you voluntarily submit your Personal Data to Us for any other reason or purposes as may be notified to you.

You are under no obligation to provide the information to Us. However, if you choose to withhold the information or to revoke permission for Us to receive the information, We may be unable to provide certain aspects of Our Services to you.

Why we collect the information and how we use it

  1. We may use the information collected and received from you for the following purposes, including but not limited to:

  1. to provide the Services and customise the content shown to you;
  2. to verify your identify, confirm the creation of your Account, update Our records and generally maintain your Account with Us;
  3. to record, monitor, process, facilitate, arrange, and fulfill sales transactions, consignments, payment, shipping and/or delivery services;
  4. for communication and administrative purposes (for example by confirming or providing updates or notifications in relation to any of your transactions with Us);
  5. for customer service and maintenance (for example to process, respond to, or resolve any complaints, disputes, or query arising from any transactions with Us);
  6. to carry out polls, surveys, analysis and research on how Our Services are being used and how We can improve them;
  7. to detect or monitor any frauds or other prohibited content, businesses or activities;
  8. to comply with and fulfill any legal requirements and relevant regulatory guidelines such as the Secondhand Goods Dealers regulations;
  9. to customise your online experience;
  10. to analyse and understand Our customers’ behaviour and preferences;
  11. if you consent and sign up to do so, to send you marketing and advertising materials, and to inform you of certain promotions which may be of interest to you. You can choose to unsubscribe for these marketing communications via the link in the email received by you and/or by sending Us an email at dpo@thecarousell.com
  12. perform functions or services as otherwise notified to you at the time of collection such as to publish and/or use for Our marketing purposes, your feedbacks and stories;
  13. to develop, operate, improve, deliver and maintain Our Services.
  1. If you have requested for any Services which can only be fulfilled upon the collection, use, disclosure or processing of your Personal Data, you will be deemed to have consented to such collection, use, disclosure or processing.
  2. We may collect, use, disclose or process your Personal Data without your consent under circumstances which are permitted by the PDPA and other applicable laws.

  1. Sharing with and Disclosure to Third Parties

  1. Certain Services require your Personal Data to be disclosed to third parties. However, We will only disclose your Personal Data to third parties to the extent that it is necessary to enable Us to provide goods or services to you, or for purposes to which you have consented.

  1. We may disclose your Personal Data to third parties for the following purposes, including but not limited to:

  1. performing certain aspects of the Services provided to you, such as processing and fulfilling transaction requests, including to facilitate payment processing, collection, shipping and delivery, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks;
  2. protecting, proving or enforcing Our legal rights;
  3. where required for any legal proceedings; and
  4. conducting due diligence and investigations, such as identity verification and checking for fraud.
  1. We may disclose your Personal Data to the following third parties which may include but are not limited to:

  1. Our related and associated companies and affiliates, for the purposes stated above;
  2. Our third party service providers (including insurance companies, storage companies, logistic service providers, data centre and cloud service providers, service providers which host, maintain, or manage the site and/or data from the site, and other technology service providers) to enable Us to provide Services to you;
  3. business partners who provide ancillary services, trade-ins, promotions, rewards, and incentives you may receive in relation to the Services;
  4. marketing agencies where you have consented to receive marketing materials from;
  5. banks, credit, debit and charge card companies, and any other entities processing payment instructions given by you or for your benefit through the provision of Our Services;
  6. legal advisors, consultants, auditors, and any other agents or subcontractors acting on Our behalf; and/or
  7. government or regulatory authorities, whether within or outside of Singapore, to the extent required in the normal course and scope of Our business in the provision of the Site and Services, the courts where required during legal proceedings, and where required by applicable law, statute, regulation or by-law, regulatory or governmental order or court order.
  1. We will make all reasonable efforts to ensure that no unnecessary disclosure of Personal Data to third parties takes place.

  1. Though We strongly encourage all third parties We work with to comply with the Personal Data protection requirements under the PDPA and/or other relevant laws, We cannot be responsible for and hereby excludes all liability for any third party’s non-compliance with the PDPA and other relevant laws.
  2. You may, from time to time, through receiving services from Us encounter links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Laku6 does not accept any responsibility or liability for these policies, or any acts or omissions of such third parties. Please check these policies before you submit any information to these websites.

  1. Protecting your information

  1. The security of your information is important to Us. We put in place reasonable security arrangements to protect your privacy and Personal Data, in such manner and to such extent as We deem reasonably appropriate to prevent unauthorised access, collection, use, disclosure, processing, copying, modification, disposal or similar risks.  However, there is no such thing as "perfect security" and while we strive to use commercially acceptable means to protect your information, We do not guarantee absolute security in any way, and you should not expect, that your Personal Data or private communications will always remain private and/or safe from any unauthorised access or misuse by third parties.

  1. Your Personal Data to be used by Us is stored on Our and/or its data centre providers’, and cloud service providers’ and other service providers’ servers located in Singapore.  We use such procedural and technical safeguards as We deem reasonably necessary to protect your privacy and to protect your Personal Data against loss, theft and unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, or similar risks.  Such safeguards include but are not limited to the use of encryption and firewalls. We will also employ appropriate security techniques to reasonably protect your Personal Data against loss, theft, and unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, or similar risks.

  1. We do not represent or warrant that there will not be, and hereby disclaims any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, collection, use, disclosure, processing, copying, modification, disposal or similar actions with regard to any data held or maintained by Us.

  1. It is important that you protect against unauthorised access of your Account and information by choosing your password carefully, and keeping your password and Account secure (e.g. by signing out after using our Services).

  1. Transfer of information

By using our Services, you authorise Us to use your information in Singapore, Indonesia and other countries where Laku6 operates for the purposes mentioned above. If there is a need to transfer your Personal Data out of Singpore, We will ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable laws on personal data protection (including, but not limited to, the PDPA).

  1. Accessing and updating your Personal Data

  1. If you wish to:

  1. access, update or otherwise change or remove any Personal Data that you provide for Our use;

  1. you would like to understand how We have used or disclosed your Personal Data; or

  1. withdraw consent you previously provided to Us to use, collect or disclose the information We hold about you,

please contact Our Data Protection Officer using the contact details set out at the end of this Privacy Policy for assistance.

However, if you remove any Personal Data which is necessary for Us to provide you with the Site or Services, Our provision of the site or Services to you may become impossible, impeded or deficient. Please note that the above right to access, update, change or remove does not apply to any data which is not Personal Data.

  1. Where you provide personal information about yourself to Us, you are responsible for providing accurate, not misleading, complete and up-to-date information about yourself and any other person whose personal information you provide Us, and to update this personal information as and when it becomes inaccurate, misleading, incomplete or out-of-date.

  1. In certain circumstances, you may need to provide to Us personal information about someone other than yourself. If so, We rely on you to inform these individuals that you are providing their personal information to Laku6, to make sure they consent to you giving Us their information and to advise them about where they can find a copy of this Privacy Policy.

  1. Please allow Us a reasonable period of time to respond to any request and effect any change. We may ask to verify your identity and for more information about your request. Where We are legally permitted to do so, We may refuse your request and may give you reasons for doing so.
  2. Where you have requested for a copy of the information We hold about you, We may charge a reasonable administrative fee to cover the costs of responding to your request. If We decide to do so, We will provide you with a written estimate of such a fee beforehand.

  1. Tracking technologies

  1. We use tracking technologies on Our Services. These enable Us to understand how you use Our Services which, in turn, helps Us to provide and improve our Services. However, the tracking technologies do not access, receive or collect information which can be used to identify you. We have listed below some examples of the tracking technologies used on our Services:

  1. Cookies.  A cookie is a small data file sent from a website to your browser that is stored on your device. Cookies are used for a number of purposes, including to display the most appropriate content based on your interests and activity on our Services, estimate and report our Service's total audience size and traffic, and conduct research to improve our Services.

The following cookies may be used:

  1. Functional cookies . These are used to remember the selections you make on the Site so that your selections are saved for your next visits;
  2. Analytical cookies . These allow Us to improve the design and functionality of the site by collecting data on how you access the site, for example data on the content you access, how long you stay on the site, etc;
  3. Targeting cookies . These collect data on how you use the site and your preferences. This allows Us to personalise the information you see on the site for you; and
  4. Third-Party cookies . These are created by a website other than Laku6’s. We may use third-party cookies to ascertain your preferences and tailor advertisements around your interests.

If you engage in activities or transactions on the Site which cannot take place without cookies that collect, use, disclose or process Personal Data, you are deemed to have consented to such collection, use, disclosure or processing if you had voluntarily provided the Personal Data for that activity or transaction, and it is reasonable that you would do so.

  1. Clear gifs.  We employ a software technology called clear gifs (a.k.a. web beacons or web bugs) to help Us better manage content on Our Services by informing Us what content is effective. Clear gifs are tiny graphics with a unique identifier similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence.

Data collected in this way is anonymous to Us, which means We cannot see the personal data of individual users. However, this data is saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/ . You can allow Facebook and its partners to place ads on and outside of Facebook. A cookie can also be saved on your device for these purposes.
Please click here if you would like to withdraw your consent https://www.facebook.com/settings/?tab=ads#_=_

  1. Flash cookies.  We use Flash cookies (a.k.a local shared objects or LSOs) to store some of your viewing preferences on our Services. These are used to collect and store information, but differ from browser cookies in the amount, type and manner in which data is stored.

  1. Changes to this Privacy Policy

Laku6 reserves the right to amend its prevailing Privacy Policy at any time and will post any such amendments on the Site or notify you of such amendments by email. You are responsible for reviewing the changes We make to this Privacy Policy. Your continued use of our Site and Services constitutes your acceptance of the updated Privacy Policy.

  1. Governing Law

This Privacy Policy is governed by and shall be construed in accordance with the laws of Malaysia. By accessing this Site or using the Services, and providing Personal Data or information requested, you agree to submit to the exclusive jurisdiction of the courts of Malaysia.

  1. Conflict

Please kindly note that where this Privacy Policy has been translated to any other non-English language, in the event of any inconsistencies in the meaning of any provision of the English language text of this Privacy Policy, the English language text shall prevail.

  1. Contact Us

If you have any questions, complaints, concerns or comments on Our Privacy Policy, We welcome you to contact Us by sending an email to dpo@thecarousell.com. Your indication at the subject header would assist Us in attending to your email speedily by passing it on to the relevant staff in Our organisation. For example, you could insert the subject header as "Accessing Personal Data".  

Laku6 does not: (a) offer goods or services to, or monitor the behaviour of, European Union data subjects; and (b) process and/or hold the personal data of data subjects residing in the European Union.

 

Last updated on 3 April 2023