Private Policy

updated:2018_10_23/WS

1. Scope

RAW Smart Solutions Sdn. Bhd. (1236430_D) (“RAW”) is committed to protect and respect visitors privacy.

This Privacy Policy (“Policy”) explains the basis on which RAW process any personal data collected, or that a visitor or any third party provide to RAW, not only from the use of the RAW website, such as www.raw-smartsolutions.com (RAW “website”), but also in connection with managing workforce, conducting business, through hardware products, software products, applications and services including cloud services, and from any other means. Please read the following carefully to understand RAW practices regarding how personal data is processed and how RAW will treat it.

RAW may revise this Policy from time to time without prior notice. The most current version of this Policy will govern the use of personal data. If RAW decide to change this Policy, RAW will post the updated Policy on this website. It is in the responsibility of the visitor of the website to verify for changes of this Policy.

“Personal data” means any information or set of information that relates to an identifiable individual, directly or indirectly. Personal data does not include information that is encoded or anonymized.

2. RAW Applications

For information about how personal data is processed by certain RAW Applications, please refer to the application specific websites.

3. Information RAW may collect from or about visitors of the website

Personal Data:
RAW may collect and process the following data:

  • Information provided by filling in forms on the website and information provided on independent partner sites that are   transferred to us. This includes information provided at the time of registering to use the website, subscribing to our services, downloading free or trial versions of our software, posting material or requesting further services. RAW may also ask for information when an issue is reported with any of the website, software or services, reporting suspected piracy or any other reason.
  • If access to our services is created by or at the request of an organization (an “Organization”) of which the requester is an employee, contractor, member, agent or other participant (each such user referred to as an “Organization User”) the “Organization’s Administrator” may provide us with certain personal data, such as name, email address, telephone number organization name and other contact data
  • RAW may keep a record of that correspondence in compliance with legal and regulatory requirements. When the requester provide a written application for deletion of the data. RAW will execute the request as long there is no legal or regulatory requirement that prohibit the deletion. RAW will provide a response when the data is deleted.
  • RAW may also ask to complete surveys that is used for research purposes, although it is not mandatory to respond.
  • Details of transactions and the fulfilment of orders, including the downloading and licensing of software.
  • Details of visits to the website including, but not limited to, traffic data, data regarding the site pages, weblogs, and other communication data, whether this is required for billing purposes or otherwise, and the resources that are accessed.
  • Information supplied to RAW in the course of general marketing and other business activities.
  • Information that is supplied to RAW during the visit of RAW facilities or while attending an event (either in person or online) at which RAW is the host, a participant or which is sponsored (in whole or in part) by RAW. RAW may also make video recordings and take photographs at events.
  • Information provided or disclosed on notice boards, newsgroups, community feedback sites, email systems, forum facilities, chat rooms, social media or similar features that RAW may establish on this website or linked websites that are not in the ownership and responsibility of RAW.
  • Device-specific information collected by RAW’s tools embedded within the software products. All personal data in such tools is anonymized by default.
  • Information that is provided to RAW by third parties such as business partners, in the course of RAW providing and supporting RAW’s products and services.
  • Information supplied to RAW or that is obtained/created in the course of application for employment or engagement (for example, salary, performance evaluations, benefits data, background checks). See paragraph 6 below for more information how RAW collect and process personal data from applicants.

IP addresses and other Technical Information:
When a visitor access the website, RAW may collect information about the computer, including where available, IP address, domain name, operating system and browser information, certain hardware or device information and other technical information.
This is information about browsing actions and patterns and the use of certain software products and applications, and does not identify any individual except where user settings are configured by the user to provide personal data or where RAW has expressly notified the visitor in the course of registering for, or accessing a service that personal data will be collected.

Website Cookies & Beacons:
The RAW website uses cookies (a small piece of information that is placed on visitors computer when visit certain websites) to distinguish a visitor from other users, to track the browsing pattern and to build a profile of how the visitor and other users use the RAW websites.

This helps RAW to provide the visitor with a good experience when browsing the website and also allows RAW to improve the website. If the visitor has an online account with RAW, RAW also uses cookies to identify the user to pre-fill forms that save time. RAW does not mandate Cookies to access our websites, and the visitor may freely set the browser to reject all Cookies or prompt to accept or reject them. Some of the cookies RAW uses are session cookies and only last until the browser will be closed, others are persistent cookies which are stored on the computer of the visitor.
RAW may collect information through web-beacons about the web browsing activities such as the address of the page visiting, the address of the referrer page previously visited, the time viewing the page, browsing environment, display settings and others that can be obtained from the system of the visitor.
RAW collect this information in order to optimize and improve the browsing experience, the use of web-based services and provide relevant information on RAW products and interest based advertising. A visitor of the website shall be aware if cookies are blocked, features and functionality may not work as when cookies are enabled.
If a visitor of the website choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated.

Free & Trial Versions of Software or Functionality:
If a visitor is requesting the use of a free or trial version or any of the software products or services or accessing other free functionality within the products, RAW will use the personal data provided for setting up an account as registered user (which is required to download or access the functionality) to contact the visitor about the user experience with the products and to inform about other products and services. The registered user can opt-out of receiving marketing information by updating his account settings or request it in written form. In case a registered user would like his data removed from the RAW database he has to provide a written request. RAW will maintain or delete all data of a registered user according to the legal requirements as long as there are no legal requirements to keep the data. Data related to business transactions, invoices, debit and credit notes that are to be kept according to IFRS.

4. Where RAW store and access Personal Data

RAW is a company registered in Malaysia and as such personal data will be collected and stored according to Malaysian Act 709, PERSONAL DATA PROTECTION ACT 2010.. Whenever a visitor is accessing the website or communicating electronically with RAW, various communications will necessarily result in an digital data transfer of information across international borders.

Accordingly, by visiting the RAW website and/or communicating electronically with RAW (including the in the process of providing information, software or services), the visitor acknowledge that personal data may be processed in a country other than the one in which the visitor reside.

5. How RAW use information about visitors

In general, RAW will only process personal data where the processing is in the legitimate business interests or required to perform a contract with a visitor, registered user or a corporate client. RAW use personal data in the following ways:

  • To ensure that content from the website is presented in the most effective manner.
  • To provide information, products or services requested from RAW or provided by RAW based on interest.
  • To carry out our obligations arising from any contracts entered into between visitors and RAW.
  • To allow visitors to participate in interactive features of RAW services, when visitors choose to do so.
  • In order to better service visitors with respect to RAW products and services that are available from time to time.
  • To notify visitors about changes to services, updates to websites, new product offerings or special events hosted or sponsored by RAW or its business partners.
  • In order to enforce or apply the terms of use of the website, software licenses, hosted services, and other agreements.
  • To protect the rights, property, or safety of RAW, the customers of RAW, or others. To provide visitors with updates on any events visitors have registered to attend or are interested in.
  • If a visitor attend or speak at any of RAW events or events where RAW is a sponsor, RAW may record videos of such events for use in promotional and educational material.
  • Visitors of the RAW office or site shall be aware about CCTV footage for the safety and protection of RAW premises.

If a visitor is an applicant for a position or for an engagement at RAW, RAW use personal data about the applicant to determine the suitability of employment, job assignments and responsibilities in accordance with paragraph 6 of this document.
For employees, RAW use personal data for various employment-related purposes, primarily relating to establish and manage the employment relationship.

RAW may provide information to the applicant in the form of emails, mailings, website displays or other correspondence methods.

RAW is interested in the views of the applicant, value feedback, may therefore set up notice boards, newsgroups, community feedback sites, email systems, forum facilities and/or chat rooms on the website. Any information that applicants disclose via such facilities will be used in accordance with the terms of service for the particular forum. However, RAW can of course not control and not be made responsible for other parties’ use of the personal data which the applicant make available through such facilities and otherwise on the websites. RAW encourage the applicant to be careful about what personal data is shared.
RAW will offer individuals the opportunity to choose (opt-out) whether they receive communications from RAW or its authorized resellers concerning RAW products and services (as described further below).

RAW will only use and share personal data in ways that are relevant for the purposes for which the information was collected or subsequently authorized by the applicant.

6. Job Applicants

In sending a Resume or CV, the applicants are allowing RAW to store it with all provided contact details in the job applicant database. RAW will only share personal details with the RAW HR team members, talent acquisition, third-party facilitators and consultants engaged to support the recruitment process, and RAW Interview Panel Members for positions that an applicant has applied for.

RAW may need to share personal data with external third parties such as the local labor authorities, courts and tribunals, regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.

RAW might ask candidates for a reference check (RAW will always ask applicants first before contacting anyone for personal references). For certain positions where RAW has the opinion a background check is required, RAW might share personal details (Email ID) with a third party service provider who support this process.

7. Transfer and disclosure of information about visitor of this website

To Other Third Parties. RAW may transfer or disclose personal data to other third parties who agree to process such personal data in accordance with the instructions of RAW and provide appropriate technical and organizational security measures. Such third parties may include:

 

  • Authorized resellers and business partners for the limited purposes of offering RAW products and associated services.
  • Trusted businesses or persons to process it for RAW, solely on behalf.
  • In the event that RAW sell or buy any business or assets, in which the disclosure of personal data to the prospective seller or buyer of such business or assets is required.
  • If any RAW entity, or substantially all of its assets are acquired by a third party, in which case personal data held about customers will be one of the transferred assets.
  • If RAW is under duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply the terms of use of the website and other agreements; or to protect the rights, property, or safety of RAW, customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • Government agencies or other third parties as authorized by applicable law: (i) to comply with legal, regulatory, or reporting requirements (such as reporting to tax authorities and employment regulators), (ii) in the event RAW is required to respond to a court order, subpoena, discovery request, or other legal process, or if, in our good faith opinion, such disclosure is required by law, (iii) at the request of governmental authorities conducting an audit or investigation, (iv) to verify or enforce compliance with applicable employee policies, laws, rules, or regulations, (v) in connection with corporate restructurings or potential acquisitions, mergers, or sales, or (vi) whenever RAW believe disclosure is necessary to limit the legal liability, or to protect or enforce the rights, interests, or safety, of visitors, the Company, other employees, or third parties. It is RAW’s policy not to sell personal information to list brokers or similar entities for commercial gain.

8. Visitors can Opt-Out of E-Mail Correspondence and Access and Correct the Information RAW collects.

Visitors have the right to ask RAW not to process personal data (“opt-out”). RAW will inform before collecting personal data) about the intended use of that data. If a visitor prefer to opt-out please contact as set out below.
Visitors may also opt-out of future marketing correspondence by updating their preferences using the link on the footer of e-mail correspondence.

Upon request, RAW will provide reasonable access to personal data of the requester only in RAW possession, and will take reasonable steps to permit access that allow a valid and identified requester to correct, amend, or delete personal data.

RAW may reject requests that are fraudulent, unreasonable, repetitious, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), or would be extremely impractical (for example, requests concerning information residing on backup tapes or archives).

Where RAW can provide access to personal data and correction, it will be granted at no cost to the requester, except where it would require a disproportionate effort and the requester has valid proof and authority to access the personal data. RAW protect information from accidental or malicious alteration or destruction according to state of the art security systems and technology. After a requester has deleted the personal data, RAW may not delete residual copies from active servers or remove information from our backup or archive systems.

9. Data Integrity

RAW will take reasonable measures to ensure that personal data that is processed is authentic and of high quality for its intended use, accurate, complete, and up-to-date. Visitors are responsible to provide accurate personal data as requested by RAW. RAW will use reasonable efforts to maintain the accuracy and integrity of the personal data RAW obtain, and to keep it updated.

10. Security

RAW has implemented, and will maintain state of the art, reasonable physical, technical, and organizational security measures for the purpose of protecting the personal data in its possession from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

Where a visitor or registered user has obtained or chosen a password, which enables access to protected parts of the website, the owner is responsible for keeping this password confidential and safe. RAW will never ask to share or provide a password.

Unfortunately, the transmission of information via the internet is not fully secure. Although the website has security measures integrated to protect personal data, RAW cannot guarantee the security of data transmitted from and to the websites; any transmission is at the risk of the visitor.

11. Limitation on Scope of Privacy Principles

Adherence by RAW to this privacy policy may be limited to the extent required to meet a legal, governmental, national security, or public interest obligation.

12. Compliance and Enforcement

RAW will conduct periodic internal compliance audits of the relevant privacy practices to verify adherence to this privacy policy and national data protection acts. RAW encourage individuals covered by this Policy to raise any concerns if there are, about the way RAW process or store personal data by providing a written request.

RAW commits to resolve questions and complaints about personal data, privacy and its collection or processing. Individuals who believe that RAW is not complying with the terms of this Policy, can contact RAW by email at rawprivacy@raw-martsolutions.com. RAW will answer any questions and to investigate any concerns or complaints within a reasonable timeframe. RAW will do the best to internally resolve any complaints and disputes about the use and disclosure of personal data brought to attention.

13. Unlawful Use of RAW Software

RAW regards software piracy as a crime, and RAW act on offenders accordingly. RAW doesn’t tolerate the unlawful use of RAW software products, and pursue all those identified breaching laws with all legal means available, including public and private surveillance resources. As part of these efforts, RAW utilizes data monitoring and scouring technologies to obtain and transmit data on unauthorized use of software. Such data may be transferred and processed in a country other than where the software is being used or accessed. If an individual or legal entity is using any unauthorized or unlicensed copy of software developed and/or sold by RAW, cease using it immediately and contact RAW to obtain a legally licensed copy. By using any unauthorized or unlicensed copy of RAW software, an individual or legal entity should be aware that RAW will collect, use, and transfer personal data internationally for the purposes of identifying users of such software. This personal data may include online identification, such as IP address, MAC address and geolocation.

14. RAW doesn’t knowingly collect information from children or underage (the age of this group of individuals differs depending on country or region)

The website is not directed to children or underage. RAW doesn’t knowingly collect personal data from children or underaged on any of the websites and will delete any such information when it is identified to be from children or underage, unless RAW has received consent to collect such personal data from the child or underage custodian.

In the event a custodian believes that his/her child or underage has provided information to RAW and wishes the data to be removed or corrected, please contact RAW in written as described below.

15. Other Sites

The website may, from time to time, contain links to and from the websites of our authorized resellers, business partners, industry forums, consultants, analysts and to other sites that are relevant to our products and services.

Additionally, for some of the functions within the website RAW link third party suppliers for example, when visit a page with videos embedded from or links to YouTube, slide-share or other websites.

If a visitor follow a link to any of these websites, please note that these websites have their own privacy policies and that RAW do not accept any responsibility or liability for these policies and their content.

16. Visitors rights

  • If a visitor or registered user wish to access, correct, update or request deletion of personal data, please feel free to contact RAW in written form at any time by using the contact details.
  • In addition, a visitor or registered user can object to processing of personal data. Request to restrict processing of personal data or request portability of personal data. Again, a visitor or registered user can exercise these rights by contacting RAW in written form by using the contact details provided.
  • When RAW has collected and processed personal data from visitors or registered users with consent, the consent can be withdrawn at any time. This may mean that access to certain services is restricted or denied as a result. Withdrawing of the consent will not affect the lawfulness of any processing we conducted prior to the withdrawal, nor will it affect processing of personal data conducted in reliance on lawful processing grounds other than consent.

RAW will respond to all requests received from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

17. Data retention

Personal data will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this privacy policy or as otherwise required by applicable law.

18. Changes to RAW Privacy Policy

This Policy may be amended from time to time. Any changes RAW may make to this privacy Policy will be posted on the website and, where appropriate, notification by e-mail will be provided. When amendments are made, RAW will revise the “last updated” date at the top of this Policy.

19. How to Contact Us

If a visitor has any questions or concerns about the use of personal data, personal information or this Privacy Policy, please contact us at the following e-mail address:

rawprivacy@raw-smartsolutions.com.