GeneJunction

Last updated on September 2024.

We, GeneJunction Sdn Bhd and/or our related corporations (hereinafter referred to as "we", "our" or "us"), place great importance on the confidentiality, privacy and protection of your personal and transactional data. We handle all personal data provided to or collected by us in accordance with the standards prescribed by the Personal Data Protection Act 2010 ("PDPA") and any other applicable data protection related legislations.

This privacy policy applies to GeneJunction App, GeneJunction Website at www.genejunction.com and all web pages within the domain ("Platform") ("Privacy Policy"). This Privacy Policy explains how we process your Personal Data that you have provided to or collected by us when you interact with us. For the purposes of this Privacy Policy, "Personal Data" means any information or combination of information, relating, directly or indirectly to an identified or identifiable natural person, including Sensitive Personal Data (as defined herein). The Personal Data may include the information as stated in Paragraph 1 of this Privacy Policy, particularly information relating to Sensitive Personal Data as stated in Item (iii) of Paragraph 1 of this Privacy Policy.

By using and interacting with us on or through the Platform, including submitting any information to us and/or signing up for any products or services with us, you expressly agree and consent that we may collect, use, process, store and disclose your Personal Data in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms and Conditions of the Platform. If you disagree with all or any part of this Privacy Policy or any of the Terms and Conditions of the Platform, please do not use or continue using the Platform any further.

Types of Information Collected
Collection of Personal Data
Use of Personal Data
Disclosure of Personal Data
Payment Processing
Protection of Personal Data
Retention of Your Personal Data
Your Rights in Respect of Your Personal Data
Changes to This Privacy Policy
Exclusion of Liability
Severability
Contact Information
Conflict

Types of Information Collected

1.1

When you access the Platform to enjoy the products and/or services offered on our Platform, we may collect including but not limited to, the following information from you:

No.	Categories of Information	Examples of types of data we collect
(i)	Personal identification and contact information	name, gender, ethnicity, address, email address, photo, telephone number, height, weight, age, food habits and bank account information
(ii)	Access information	IP address, geographic location, operating system and browser type, username, password, device type, web traffic data, time spent on the Platform, number of webpages within the Platform that has been viewed, access from third party websites linked to our Platform, and advertising information (e.g. advertisements that were clicked and/or viewed)
(iii)	Medical and religion information ("Sensitive Personal Data")	(a) Information such as fat percentage, allergies, symptoms, physical and mental or other health conditions or medical records, genetic information (raw, report or result), radiology reports, general lab reports, specimen information and records, medical insurance information and records, history and other relevant health traits (b) Information such as your religious beliefs or other beliefs of similar nature
(iv)	Partners and third party information	Information which we may receive when you use certain services of our partners or third parties on our Platform such as payment and delivery service providers, data analytics providers, advertising networks and social networking sites. Information that we may collect from these third parties may include but are not limited to the information listed in items (i) and (ii) of Paragraph 1.1 above.
(v)	Information that you have voluntarily share with us	Feedbacks, opinions, comments or any information you may share with us via optional online surveys we may occasionally ask you to complete.

1.2

The products and services on this Platform include providing monetary or monetary equivalent credits for information received under Item (iv) of Paragraph 1.1 above, allowing users to earn monetary or monetary equivalent credits for assisting in new subscriptions and/or registrations, matching services between research and clinical trial providers and individuals, providing professional medical services, verifying health and genetic data, providing health testing services, providing genetic testing services, providing health insurance information, providing an e-marketplace for general merchandise and various health and medical related products and services ("Products and Services").

Collection of Personal Data

2.1

We collect Personal Data from you in the following ways:

(i)

when you access our Platform or when you create an account, register with us and/or submit any form to provide us or benefit from our Products and Services;

(ii)

when you disclose Personal Data in face-to-face meetings, email messages, telephone conversations with our teams (i.e. our marketing or customer service officers);

(iii)

when you sign up for our marketing and promotional communications and/or initiatives;

(iv)

when you volunteer and consent to participate in any research or surveys conducted by us;

(v)

when you interact or communicate with us via our Platform or on social media channels, pages, promotions and/or blogs;

(vi)

when you make available your Personal Data to us for any other reason; or

(vii)

through other data sources:

(a)	when we seek and receive your Personal Data in connection with your relationship with us, including for our Product and Services. For example, business partners, public agencies, referral intermediaries and the relevant authorities;
(b)	if you act as an intermediary or are supplying us with information regarding a third-party/other individual (such as a relative, friend or a colleague), you undertake that you have obtained all necessary consents from such third-party/other individual for processing of their Personal Data by us; and/or
(c)	any other information which we may collect from other sources.

2.2

If you are below the age of 18 years, please obtain, in addition to your own explicit consent, your parents, guardian or legal representative's consent before providing your Personal Data to us. If a parent, guardian or legal representative becomes aware that the Personal Data of a child or ward has been provided without the consent of the parent, guardian or legal representative, please contact our Data Protection Officer (contact details under Paragraph 8.2 of this Privacy Policy) and such Personal Data will be disposed of from our records.

2.3

Notwithstanding, we may collect Personal Data of child or ward below the age of 18 years from the parents, guardian or legal representatives directly. In such circumstances, you confirm that they have explicitly consent and appointed you to act for them and consent on their behalf to the processing of their Personal Data in accordance with this Privacy Policy.

Use of Personal Data

3.1

We collect, use, process, store and/or disclose your Personal Data for the following purposes:

(i)	to communicate with you;
(ii)	to verify your identity;
(iii)	to carry out a matching between your requirements and a suitable service provider, buyer or seller (as the case may be) so as to be able to provide you the Products and Services on and through the Platform;
(iv)	to carry out profiling and the maintenance of a database for the purposes of providing the Products and Services on the Platform;
(v)	to enable your device and/or software to access the Platform;
(vi)	for the smooth administration and improvement of the Platform, including troubleshooting, site analysis, testing, research, statistical and survey purposes and to obtain feedback so as to enable us to improve the operation of the Platform and offer you a better user experience;
(vii)	for audit, customer service, administrative support, market research and business development purposes;
(viii)	to contact or notify you about matters relating to your user account, your subscription, and updates and/or developments to the Platform, the Terms and Conditions of the Platform and this Privacy Policy;
(ix)	to respond to any queries, requests or reports which you may have submitted;
(x)	to recommend and/or display content and advertisements on the Platform that may be of interest to you;
(xi)	to comply with requirements under any applicable law or requests from any competent authority, including but not limited to relevant governmental authorities, law enforcement agencies and regulatory bodies;
(xii)	to facilitate any payment processes;
(xiii)	to facilitate and enable our healthcare professionals and service providers or partners who provide various services whom we have contractual arrangements with to provide you with the Products and Services offered on and through the Platform;
(xiv)	where required in any civil or criminal suit or for the protection and/or enforcement of our legal rights and obligations;
(xv)	in the event we sell or buy any business or assets, where necessary for the purposes of the sale or purchase;
(xvi)	to enable any third parties to perform any of the above where necessary and/or applicable, including but not limited to law enforcement agencies, regulatory bodies, our business partners, affiliates, suppliers and sub-contractors; and/or
(xvii)	to conduct research, analysis, study, assessment, survey and/or prepare reports or statistics to operate.

Disclosure of Personal Data

4.1

We may need to share your Personal Data with the following parties which may be located within or outside Malaysia in order to fulfil the purposes as set out in Paragraph 3 above from time to time:

(i)	our related corporations;
(ii)	third party service providers as may be deemed necessary to facilitate your dealings with us such as processing your Personal Data;
(iii)	governmental agencies, governmental authorities and other regulatory bodies;
(iv)	third parties appointed by us, including our auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our business;
(v)	third party reward, loyalty, co-branding and privileges programme providers; and
(vi)	selected third parties such as our healthcare professionals and service providers or partners who provide various services whom we have contractual arrangements with to provide you with the Products and Services offered on and through the Platform.

4.2

By you using the Platform, you are deemed to have consented to the transfer of your Personal Data to the parties as set out in Paragraph 4.1 above. We will take steps to ensure that your Personal Data transferred to the parties as stated in Paragraph 4.1 above continues to be handled in accordance with the standards prescribed by the PDPA or its equivalent or similar data protection legislations.

Payment Processing

5.1

If you use a credit card or debit card as a payment method on the Platform, the information or data that you provide will be transferred to the relevant financial service provider. At all times, your payment data is stored with the respective financial service provider responsible for your payment information. You may review the respective privacy policy from the relevant financial service provider to learn more on how your payment information and data is used and processed.

6.	Protection of Personal Data
6.1	We will implement technical and administrative security measures to ensure that your Personal Data is protected against unauthorised or accidental access, use, alteration or loss. All of our employees who deal with Personal Data have the necessary information and knowledge to handle and protect the Personal Data.
6.2	Further, to safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our partners, authorised third party service providers and agents only on a need-to-know basis.
6.3	Notwithstanding, you should be aware that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your Personal Data and are constantly reviewing and enhancing our information security measures.
6.4	You further agree and acknowledge that we shall not be liable for any loss or damage which may be incurred by you as a result of the collection and/or disclosure of your Personal Data from external applications, sites or resources that may not be linked to us. The external applications, sites or resources may have their own privacy policies and we recommend that you review their privacy policy carefully to understand more about how these external applications, sites or resources use and process your Personal Data.

7.	Retention of Your Personal Data
7.1	We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
7.2	We will cease to retain your Personal Data, or remove the means by which the Personal Data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.

Your Rights in Respect of Your Personal Data

8.1

You may have access to, review, correct, update, change or delete your Personal Data stored in your account or profile at any time. You may do so by logging into your account or profile to make the necessary changes.

8.2

You may also write to us to our Data Protection Officer at the following contact details to request, access, review, correct, update or change your Personal Data or to remove your Personal Data that you have provided to us:

Address	\|	Unit 209, Block D, Kelana Square, 17, Jalan SS 7/26, Ss 7, 47301 Petaling Jaya, Selangor
Tel No.	\|	+60 18-977 7989
Email	\|	[email protected]

8.3

We reserve the right to verify your identity before providing you with a copy of your updated or corrected Personal Data. Access to or correction, updating or deletion of your Personal Data may be denied or restricted by us if it would violate another person's rights and/or to comply with the applicable laws.

8.4

You have the right to limit in part or wholly any of the processes by which your Personal Data is subjected to in terms of the operations allowed to be performed upon it, the period of time allowed or alternatively the deadline of the consent given.

8.5

You may at any time withdraw your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period.

8.6

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of your request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. Please note that we may not be in a position to continue providing our Products and Services on and through the Platform to you and we shall, in such circumstances, notify you before completing the processing of your request.

Changes to This Privacy Policy

9.1

We reserve the right to change or vary this Privacy Policy from time to time at our sole and absolute discretion. The most updated Privacy Policy will be made available promptly on the Platform. It is your responsibility to keep yourself updated and aware of the latest version of this Privacy Policy. If any change is unacceptable to you, you should immediately cease all further use of the Platform. If you continue to use the Platform after the changes take effect, you will be deemed to have accepted the changes.

10.

Exclusion of Liability

10.1

You hereby agree and acknowledge that we shall not be liable for any purported violation, breach or non-compliance with any precepts of privacy or the protection of your Personal Data in the following instances:

(a)	where an act of nature or event outside our control results in the damage or malfunction or destruction in any equipment or machinery used to secure, store or process Personal Data;
(b)	where Personal Data is readily available or able to be found in the public domain; and
(c)	where despite our best efforts, there is unauthorised access, modification, alteration, misuse, tampering or abuse of Personal Data caused by the malicious or fraudulent or criminal acts or conduct of a third party not being under our control or direction.

11.	Severability
11.1	Each paragraph of this Privacy Policy shall be and remain separate from and independent of and severable from all and any other paragraphs of this Privacy Policy except where otherwise expressly indicated or indicated by the context of this Privacy Policy.
11.2	The decision or declaration that one or more of the paragraphs are null and void shall have no effect on the remaining paragraphs of this Privacy Policy.

12.	Contact Information
12.1	If you have any feedback or queries about this Privacy Policy, you may contact our Data Protection Officer (contact details as provided in Paragraph 8.2 above) and we shall endeavour to respond to your queries accordingly.

13.	Conflict
13.1	In the event of any inconsistency between the English version and the Bahasa Malaysia version of this Privacy Policy, the English version shall prevail over the Bahasa Malaysia version.