Privacy Policy

Released on December 28, 2020
Last updated on 06 01, 2021

Welcome to the privacy policy of Epoch Blooming Toys Sdn Bhd. (“EPOCH”).

EPOCH respects your privacy and is committed to protecting your personal data in compliance with applicable laws. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how EPOCH collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our fan club or newsletter, or take part in a competition.

Controller

EPOCH is the controller and responsible for your personal data (hereinafter referred to as the Company, "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details:

Full name of legal entity: Epoch Blooming Toys Sdn Bhd
Name or title: William Loo Tze Yang
Email address: william@epochbt.my
Postal address: 22, Jalan BA 2/1, Kawasan Perindustrian Bukit Angkat, 43000 Kajang, Selangor, Malaysia.
Telephone number: +603 873 44 188

Update of your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Categories of personal data we collect

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different categories of personal data about you.

These categories are:

• Identity Data: first name, last name, username or similar identifier, gender, and date of birth;
• Contact Data: email address and telephone numbers;
• Financial Data: payment information when you make transactions with us;
• Transaction Data: detail and history of your purchase of our products and/or services;
• Interaction Data: detail of your messages and inquiries to us, our responses and other interaction between you and us either on this website, over the telephone, via email, on our social media, or any other media or channels;
• Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
• Profile Data: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data: information about how you use our website, products and services.
• Marketing and Communications Data: your preferences in receiving marketing messages from us or our partners and your communication preferences.

Sensitive personal data

We do not collect any sensitive personal data about you (this includes details about your, religious or philosophical beliefs, political opinions, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Failure to provide personal data

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 the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have ordered. We will notify you if this is the case at the time.

3. How we use your personal data

Lawful grounds of processing personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where you have consented to our processing your personal data. This is typically the case where we send you marketing messages, or where we use cookies on this website for advertising, analytics or other purposes that is not strictly necessary to deliver our services you requested. You have the right to withdraw consent at any time by either following the relevant links on any marketing message, by directly contacting us, or by changing your cookie settings;
• Where we need to process your personal data in order to perform our contract with you, or in order to take steps at your request prior to entering into such contract;
• Where we need to process your personal data in order to comply with legal or regulatory obligation we are subject to; and
• Where we need to process your personal data in order to establish, exercise, or defend our legal rights.

Resources where we collect your personal data & Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful grounds we rely on to do so. In the case the lawful basis for processing is your consent, it is voluntary that you provide your personal data.

Resources/ Purpose/ Activity	Type of data	Lawful basis for processing
To register you as a new customer or member of the fan club.	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including managing payments, fees and charges.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to establish, exercise, or defend our legal rights
To manage our relationship with you including: notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation
To enable you to partake in a prize draw, competition or complete a survey.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical	(a) Necessary to comply with a legal obligation (b) Necessary to establish, exercise, or defend our legal rights
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Your consent
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.	(a) Technical (b) Usage	Your consent
To make suggestions and recommendations to you about goods or services that may be of interest to you.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Your consent
To facilitate your interaction with us on social media, e.g. X, Facebook, Instagram.	(a) Identity (b) Interaction	Your consent

Children’s personal data

We collect and use personal data of children under 18 years of age only where consent thereof is given or authorized by the holder of parental responsibility. We do not condition our service to the children on the provision of personal data that is not strictly necessary for delivery of our service.

Cookies

Cookie is a small text file that our website sends to your terminal device for the purpose of keeping certain records. By using cookies:

• Your terminal devices (e.g. browsers) remember your preferences (e.g. language used) and activities (e.g. login status, items in cart, etc.) on our website, so that we can deliver a personalized and better user experience on our website (essential cookies);
• We keep track of your interaction with our website, giving us useful and important insight for improving our website (performance cookies); and
• Based on your consent, our advertising partners keep track of your browsing records across internet, so that we can deliver personalized advertisement that is more likely to be of your interest (advertising cookies).

The cookie identifies your terminal device, typically your web browser. You can choose whether to allow us or third-parties (our advertising or analytics partners) to set cookies. When we use cookies for the purpose of personalizing our advertisement or analyzing web access, we request your prior consent thereto.

For more information and to change your cookie settings, including withdrawal of your consent, visit our Cookie Setting from link at the bottom of each webpage.

We do not set and use cookies for the purpose of advertisement or web access analytics for our users under 18 years of age. To ensure this policy, we request you to declare you are 18 years of age or older when we obtain your consent to our setting cookies for these purposes.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We do not, and will not, disclose or share any of your personal data to any third party. However, we share your personal data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this notice:

• Companies in the EPOCH GROUP, as sometimes different parts of our group are responsible for essential activities that support the provision of our services (e.g. information technology infrastructure, website management, finance, logistics, etc.);
• Our contractors that provide us with services such as logistics, delivery, warehouse, payment service, IT service, etc.;
• Our partners that deliver advertising or web analytics service for us, only on your prior consent;
• Professional advisers including lawyers, bankers, auditors and insurers; and
• Competent public authorities, e.g. those in charge of tax, custom, regulation, investigation, justice, etc. we are required to provide personal data to in certain circumstances according to statutory obligations we are subject to.

We require all these third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

4. International transfers

Our disclosure or sharing of your personal data described above involves transferring your data to countries outside of Malaysia, most notably to Japan where the EPOCH GROUP’s head quarter is located. By using this website, we presume that you consent to our transferring your personal data to the entities described above that are located outside of Malaysia.

5. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. Your legal rights

Under certain circumstances, you have the following legal rights:

• Right to access personal data
• Right to correct personal data
• Right to withdraw consent for processing personal data
• Right to request that the processing of personal data be stopped when there is a possibility of damage
• Right to stop the use of personal data for direct marketing

If you wish to exercise any of the rights set out above, please contact us. We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.