Privacy Notice
This is the privacy notice of Sphere Secure Services Sdn Bhd, registration number.RC00006947, (‘we’, ‘our’, or ‘us’).
Our registered office is at No 21, Simpang 591, Kampung Jerudong, Bandar Seri Begawan BG3122, Brunei Darussalam.
Introduction
We are committed to protecting your privacy. Our users (“Users”) include individuals who visit (“Visitors”) the website, as well as individuals who sign up to use the website and any related applications and services. This Privacy Statement applies to all Users and describes our privacy practices in relation to the use of the website and the services offered.
By visiting the website or using the services provided, you are consenting to the practices described in this Privacy Policy.
In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website
Personal data we process
1. How we obtain personal data
The information we process about you includes information:
• you have directly provided to us when interacting with the website such as making an inquiry and contacting us for customer service purposes
• as a result of monitoring how you use our website or our services
2. Types of personal data we collect directly
When you use our website, our services or contact us for inquiries, we ask you to provide personal data. This can be categorised into the following groups:
• personal identifiers, such as your first and last names, your title and your date of birth
• contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication
• account information, including your username and password
• payment information, such as a debit or credit card number and expiry date and bank account details
• records of communication between us including messages sent through our website, email messages and telephone conversations
In addition, we may also process:
• documentation that confirms your identity, such as an image of your passport or driver’s licence
• an image that shows your face, such as a passport photograph
• documentation that confirms the qualifications you advertise as holding
• documentation that confirms your employment, such as recent payslips
3. Types of personal data we collect from your use of our services
By using our website and our services, we process:
• your username and password and other information used to access our website and our services
• information you contribute to our community, including reviews
your replies to polls and surveys
• technical
• information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
• usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
• transaction information that includes the details of the products services you have bought from us and payments made to us for those services
4. Special personal data
Special personal data is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data.
It also includes information about criminal convictions and offences.
We may collect special personal data about you if there is a lawful basis on which to do so.
5. If you do not provide personal data we need
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract.
In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.
The bases on which we process information about you
There are six defined bases under which we may process different categories of your personal data.
If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
6. Information we process because we have a contractual obligation with you
In order to carry out our obligations under any contract we may have with you, we must process the information you give us. Some of this information may be personal data.
We may use it in order to:
• verify your identity for security purposes when you use our services
sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
7. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including [job opportunities and our products and services, you provide your consent to us to process information that may be personal data.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us through the email provided. However, if you do so, you may not be able to use our website or our services further.
We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.
8. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
• improving our services
• record-keeping for the proper and necessary administration of our organisation or business
• responding to unsolicited communication from you to which we believe you would expect a response
• preventing fraudulent use of our services
• exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
• insuring against or obtaining professional advice that is required to manage risk
• protecting your interests where we believe we have a duty to do so
9. Information we process because we have a legal obligation
Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal data.
10. Information we process to protect vital interests
In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests.
For example, we may inform relevant organisations if we have a safeguarding concern about a vulnerable person.
How and when we process your personal data
11. Your personal data is not shared
We do not share or disclose to a third party, any information collected through our website.
12. Job application and employment
If you send us information in connection with a job application, we may keep it for up to five years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for seven years before destroying or deleting it.
13. Service providers and business partners
We may share your personal data with businesses that provide services to us, or with business partners.
As examples:
• we may pass your payment information to our payment service provider to take payments from you
• we may use fraud prevention agencies and credit reference agencies to verify your identity and we may pass your information to those agencies if we strongly suspect fraud on our website
Use of information we collect through automated systems
14. Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.
They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.
They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of 1other visitors; and serve you advertisements that are relevant to your browsing history.
Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.
Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.
15. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Other matters
16. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
17. Communicating with us
When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
Complaining
If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.
When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.
19. Retention period
Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:
• to provide you with the services you have requested
• to comply with other law, including for the period demanded by our tax authorities
• to support a claim or defence in court
20. Review of this privacy policy
We shall update this privacy notice from time to time as necessary.
