The privacy and personal data policy and practices of SmartCity Solutions Sdn Bhd (SmartCity) set out in this Privacy Policy and Personal Data Notice apply to SmartCity’s services available under the domain www.smartcityparking.com.my and SmartCity Mobile App (SmartCity Parking Solution) via any mobile device or computer of any kind. By visiting or using SmartCity’s website/SmartCity Mobile App, you agree to be bound by the terms and conditions of this Privacy Policy and Personal Data Notice. If you do not agree to such terms and conditions, please do not use or access SmartCity’s website/SmartCity Mobile App.

SmartCity’s collection of your personal data is part of its normal operation of SmartCity’s services. SmartCity has developed this Privacy Policy to inform you about SmartCity’s policy and practices on personal data and privacy matters and because SmartCity believes that you should know as much as possible about such matters so that you can make informed decisions.

Notice

This written notice serves to inform you that your personal data is being processed by or on behalf of SmartCity. For the purpose of this written notice, the terms “personal data” and “processing” shall have the meaning assigned to them in the Personal Data Protection Act 2010 (hereinafter referred to as the “PDPA”).

Description of your personal data

Your personal data processed by SmartCity includes:-

1. your personal details (such as name, gender, identification support documents including partial NRIC or passport number, credit card details) and contact details (such as e-mail address, and phone numbers);
2. parking payment and credit top-up transaction details from e-Payment (SmartCity website/SmartCity Mobile App/other platforms) and credit top-up agents;
3. your feedback information gathered from multiple sources such as e-mail, phone, write-in (mail or official feedback form);
4. your visit(s) to SmartCity’s website/SmartCity Mobile App - name of internet service provider, the website from which you visit SmartCity website/SmartCity Mobile App, the pages and content which you view, the date and duration of your visit, cookies to track usage patterns, etc from the analytics tools such as Google Analytics and others;
5. your personal interests and preferences to help SmartCity design the offering of its services;
6. Information given voluntarily by you during any on-ground promotions or digital activities, tie-ups, contests, etc; and

Purposes for the processing of your personal data

SmartCity may process your personal data collected from you or from any of the class of third parties stated in this Privacy Policy, for any one or more of the following purposes (hereinafter referred to as the “Purposes”) :-

1. To verify your identity;
2. To communicate with you and deliver information that is requested by you to you and/or, in some cases, is targeted to your interests, such as targeted banner advertisements, administrative notices, product offerings, and communications relevant to your use of SmartCity’s website/SmartCity Mobile App;
3. To process any communication you send to SmartCity (for example, answering any queries, dealing with any complaints and/or feedbacks);
4. To notify and/or invite you to events or activities organized by SmartCity, its subsidiaries, partners or sponsors;
5. To notify you about benefits, changes to the features, promotions, alerts, newsletter, updates, promotional materials and special privileges;
6. To send you festive greetings and parking-related content;
7. To run SmartCity’s customer loyalty programmes where applicable;
8. To establish and better manage any business relationship SmartCity may have with you;
9. To help SmartCity monitor and improve its services to you, SmartCity’s overall service, SmartCity’s staff training, SmartCity’s quality assurance, SmartCity’s customer service teams, SmartCity’s website & SmartCity Mobile App and other SmartCity related assets;
10. To conduct marketing activities (for example, market research and surveys);
11. To maintain records required for auditing, security, claims and/or other legal purposes;
12. To investigate and resolve any issues, queries, complaints or other enquiries that you may submit to SmartCity regarding SmartCity’s products and services through SmartCity’s customer service team or staff;
13. To investigate, respond to, and/or defend claims made against, or involving SmartCity and/or its relevant subsidiaries;
14. For compliance with and/or any purposes required by any relevant law, directives, guidelines, orders, rules, regulations and requirements of any governmental or statutory authority or administrative or regulatory or supervisory body (including disclosure thereunder); and
15. Any other purposes relating or incidental to any of the above.

Source of your personal data

Your personal data is collected directly from you when you:-

1. interact and communicate with SmartCity and/or its related subsidiaries, partners or sponsors at any of its events or activities;
2. communicate with SmartCity (for example when you purchase credit top up and monthly passes via SmartCity channels, or when you contact SmartCity for any enquiries including by getting in touch with SmartCity’s customer service through any available SmartCity channels);
3. register or subscribe for a specific service or publications of SmartCity (for example, newsletters or register as a SmartCity Website Member);
4. participate in any of SmartCity’s surveys, polls or other similar vehicles used to improve the content of SmartCity’s website/SmartCity Mobile App, or used for SmartCity’s marketing purposes;
5. enter or participate in any competitions, contests or loyalty programmes organized by SmartCity and/or its subsidiaries;
6. register your interest and/or request for information through SmartCity online portals or other available channels;
7. respond to any marketing materials that SmartCity sends out;
8. visit or browse SmartCity’s website, SmartCity apps and any other SmartCity owned platforms;
9. lodge a complaint with SmartCity; and
10. provide feedback to SmartCity (for example via SmartCity’s website or in hard copy).
11. Other than the personal data obtained from you directly as stated above, SmartCity may also obtain your personal data from third parties which SmartCity deals with or are connected with you, and from such other sources where you have given your consent for the disclosure of your personal data and/or where otherwise lawfully permitted.

Your rights

You have the following rights in relation to your Personal Data:-

1. to make a data request in writing to SmartCity for information of your personal data that is being processed by or on behalf of SmartCity (Section 30(2) of PDPA);
2. to correct any of your personal data which is inaccurate, incomplete, misleading or not up-to-date at any time; and
3. to limit the processing of your personal data including the personal data relating to other persons who may be identified from your personal data (Section 7(1)(f) of PDPA);
4. to unsubscribe to our marketing materials and/or correspondence by clicking the unsubscribe link contained in the emails and/or newsletters SmartCity sends to you and following the instructions therein;
5. to request for your personal data to be removed from SmartCity’s database by writing in e via email to support@SmartCity-solutions.com.

If you have any request in relation to the abovementioned rights under 7(a) or 7(c) above or any inquiries or complaints in respect of your personal data, please write us via email at support@SmartCity-solutions.com

SmartCity may refuse to comply with your data access request under the circumstances specified in the PDPA and if SmartCity does so, SmartCity will inform you of its refusal and the reason(s) for its refusal.

Class of third parties to Whom SmartCity may disclose your personal data

This is the class of persons to whom SmartCity may disclose your personal data:-

1. Service provider(s) for:-
   1. the management of communications on SmartCity’s behalf;
   2. the arrangement and conduct of SmartCity events, activities and services;
2. Any third party or company that SmartCity engages or appoints to conduct statistical analysis;
3. Lawyers for the enforcement of SmartCity’s legal rights; and
4. Such other authorities, bodies or parties when required by law.

Your obligations

1. It is obligatory for you to supply SmartCity with your personal data and your failure to do so will result in SmartCity being unable to process your personal data for any of the Purposes.
2. You will take reasonable steps to ensure that your personal data is accurate, complete, not misleading and kept up-to-date (Section 11 of PDPA).

Security of your personal data

SmartCity, when processing your personal data, takes practical steps to protect your personal data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction including but not limited to the use of procedural and technical safeguards such as encryption, "firewalls" and secure socket layers. If you are aware of any security breach, please let us know as soon as possible.

However, "perfect security" does not exist on the internet, so SmartCity does not give an absolute assurance that your personal data that you provide to SmartCity will be secure at all times, and SmartCity will not be responsible for any event arising from unauthorised access to or theft of your personal data. SmartCity will not be held responsible for events arising from third parties gaining unauthorised access to or third parties’ theft of your personal data.

Retention of your personal data

SmartCity will keep your personal data for the duration that is necessary to carry out the purpose for which your personal data was collected and also for the other purposes set out in this Privacy Policy and Personal Data Notice.

Amendment to this Privacy Policy and Personal Data Notice

SmartCity reserves the right to amend this Privacy Policy and Personal Data Notice at any time by posting an amended Privacy Policy and Personal Data Notice containing such amendments on SmartCity’s website/SmartCity Mobile App or by any other mode SmartCity deems suitable.

Users under the age of 18

The SmartCity website/SmartCity Mobile App and its related services are not directed at persons under 18 years of age. If you are under 18 years of age, you are required to obtain your parent/guardian's permission before you provide your personal data to SmartCity and/or its related companies.

Inconsistency or conflict

In the event of any inconsistency or conflict between the English language version and the Bahasa Malaysia version, the English language version shall prevail.

Others rights

For avoidance of doubt, nothing in this Privacy Policy and Personal Data Notice shall limit such other rights of yourself or SmartCity under the PDPA.

Links to other websites

When you use a link from SmartCity’s website or SmartCity’s Mobile App to another third party website, this Privacy Policy is no longer in effect. Once you have used such link, SmartCity does not have any control over that other third party website and SmartCity cannot and shall not be liable or responsible for the protection and privacy of any personal data which you provided whilst visiting such website(s). Your browsing of and interaction on any other third party website(s) will be subject to that websites’ own rules and policies.