OUR PRIVACY PROMISE
1) We respect your privacy and your choices.
2) We make sure that privacy and security are embedded in everything we do.
3) We do not send you marketing communications unless you have asked us to. You can change your mind at any time.
4) We never offer or sell your data.
5) We are committed to keeping your data safe and secure. This includes only working with trusted partners.
6) We are committed to being open and transparent about how we use your data.
7) We do not use your data in ways that we have not told you about.
8) We respect your rights, and always try to accommodate your requests as far as is possible, in line with our own legal and operational responsibilities.
For more information about our privacy practices, we set out in this Privacy Policy the types of Personal Data that we may collect/receive from you directly or from your interaction with us, how we may use it, who we may disclose it to, how we protect and secure it, and your rights around your Personal Data in our possession. While the information in this Privacy Policy may not fully apply to you, this Privacy Policy intends to provide an overview of one or more possible situations which may apply to you based on your interactions with us.
The more you interact with us, the more you let us know about you and the more we are able to offer you tailored services.
If this Privacy Policy changes in any way, it will be updated on this page. Regularly reviewing this page ensures you are updated on the information which is collected, how it is used and under what circumstances, if any, it is shared with other parties.
When you share personal data with us or when we collect personal data about you, we use it in line with this Privacy Policy. Please read this information and our Q&A page (if any) carefully. If you have any questions or concerns about your personal data, please contact us via the contact details set out in the “Contact” section below.
Please note that you must be at least eighteen (18) years old, or have obtained your parent’s or legal guardian’s consent, to use our services.
WHAT IS PERSONAL DATA?
“Personal data” means any information or pieces of information that could identify you either directly (e.g. your name) or indirectly (e.g. through pseudonymized data such as a unique ID number) and / or information which makes you identifiable. This means that personal data includes things like email/home addresses/mobile phone, usernames, profile pictures, personal preferences and shopping habits, user generated content, financial information, and welfare information. It could also, in certain circumstances, include unique numerical identifiers like your computer’s IP address or your mobile device’s MAC address, as well as cookies.
WHAT DATA DO WE COLLECT FROM YOU AND HOW DO WE USE IT?
We believes that you, the consumer, are at the heart of what we do. We love hearing from you, learning about you, and creating and delivering products that you enjoy. And we know that many of you love talking to us. Because of this, there are many ways that you might share your personal data with us, and the way that we might collect it.
How do we collect or receive your data?
We might collect, record, hold, store, use, disclose, receive and/or process (collectively referred to as “Process”) data from you via our websites, forms, devices or the our pages on social media or otherwise. Sometimes you give this to us directly (e.g. when you create an account, when you contact us, when you purchase from our websites or stores), sometimes we collect it (e.g. using cookies to understand how you use our websites) or sometimes we receive your data from other third parties.
When we collect data, we indicate the mandatory fields via asterisks where such data is necessary for us to:
– Perform our contract with you (e.g. to deliver the products you have purchase on our websites);
– Provide you with the service you have asked for (e.g. to provide you with a newsletter); or
– Comply with legal requirements (e.g. invoicing).
If you do not provide the data marked with an asterisk, this may affect our ability to provide the products and services to you.
We set out further details in the table below, explaining:
1) When do we collect or use your Personal Data? This column explains what activity or situation you are involved in when we use or collect your data. For example, whether you are making a purchase, signing up to a newsletter, or browsing a website.
2) What personal data may we receive from you directly or resulting from your interaction with us? This column explains what types of data we may Process about you depending on the situation.
3) How and why we may use it? This column explains what we may do with your data and the purposes for Processing it.
4) What is the legal basis for using your personal data? This column explains the reason we may use your data.
Depending on the purpose for which the data is used, the legal basis for the processing of your data can be:
• Your consent;
• Our legitimate interest, which can be:
Improvement of our products and services: more specifically, our business interests to help us better understand your needs and expectations and therefore improve our services, websites / devices, products and the Brands for our consumers’ benefit.
Fraud prevention: to ensure payment is complete and free from fraud and misappropriation .
Securing our tools: to keep tools used by you (our websites/devices) safe and secure and to ensure they are working properly and are continually improving.
• The performance of a contract: more specifically to perform the services you request from us;
• Legal grounds where a processing is required by law.
Information overview on your interactions with us and their consequences on your data
When do we collect or use your Personal Data
What personal data may we receive from you directly or resulting from your interaction with us?
How and why we may use your data ?
What is the legal basis for using your personal data?
Account Creation and management
Information collected during the creation of an account on Urban Label websites, through a social media login, or in store. Depending on how much you are interacting with us, those data may include:
Name;
Gender;
Email address;
Address;
Phone number;
Birthday or age range;
username, and password;
Personal description or preferences;
Order details;
Social media profile (where you use social login or share this personal data with us).
To:
Manage your orders;
Manage any competitions, promotions, surveys or contests you choose to enter;
Respond to your questions and otherwise interact with you ;
Offer you a loyalty program;
Allow you to manage your preferences;
Performance of a contract:
To provide you with the service you requested (e.g. create an account, complete a survey, or purchasing a product).
Send you marketing communications (where you have asked us to) which may be tailored to your “profile” (i.e. based on the personal data we know about you and your preferences);
Consent
To send you direct marketing communications.
Offer personalized services based on your beauty characteristics;
Monitor and improve our websites ;
Run analytics or collect statistics
Secure our websites and protect you and us against fraud;
Legitimate Interest
To ensure our websites remain secure, to protect them against fraud, and to help us better understand your needs and expectations and therefore improve our services, products and the Brands.
Newsletter and commercial communications subscription
Depending on how much you are interacting with us, those data may include:
Email address;
Name;
Personal description or preferences;
Social media profile (where you use social login or share this personal data with us).
To:
Send you marketing communications (where you have asked us to) which may be tailored to your “profile” based on the personal data we know about you, and your preferences (incl. location of your favourite store);
Consent
To send you direct marketing communications.
Run analytics or collect statistics.
Legitimate Interest
To tailor our marketing communications, understand their effectiveness, and ensure you receive the most relevant experience; to help us better understand your needs and expectations and therefore improve our services, products and the Brands.
Keep an up to date suppression list if you have asked not to be contacted.
Legal grounds
To keep your details on the suppression list if you have asked us not to send you any direct marketing anymore.
Purchases and order management
Information collected during the purchase process made on Urban Label website social pages or in store
Depending on how much you are interacting with us, those data may include:
Name;
Email address;
Address (delivery and invoicing);
Phone number;
Personal description or preferences;
Social media profile (where you use social login or share this personal data with us);
Transaction information including purchased products and store location;
Payment and information; or
Purchase history
To
Contact you to finalize your order where you have saved your shopping cart or placed products in your cart without completing the checkout process;
Inform you when a product you wanted to purchase is available;
Process and follow your order including delivering the product to the address you indicated;
Manage the payment of your order. To be noted, payment information (credit card number / Paypal information / bank account details) are not collected by us but directly by payment service providers;
Manage any contact you have with us regarding your order;
Performance of a contract:
To provide you with the service you requested (purchase)
Secure the transactions against fraud. To be noted, we use a third party provider’s solution to detect fraud and ensure the payment is complete and made by you or someone authorized by you;
Enrich your profile if you place a purchase using your account information; Measure satisfaction;
Manage any dispute relating to a purchase;
For statistics purposes;
To protect you and us from fraudulent transaction and to ensure the payment is complete and free from fraud and misappropriation.
Legitimate interest
Online browsing
Information collected by cookies or similar technologies (“Cookies”*) as part of your browsing on our website and/or on third-party website.
For information on specific Cookies placed through a given website/app, please consult the relevant cookie table.
* Cookies are small text files stored on your device (computer, tablet or mobile) when you are on the Internet.
Depending on how much you are interacting with us, those data may include:
Data related to your use of our websites:
Where you came from;
Login details;
Pages you looked at;
Videos you watched;
Ads you click on or tap;
Products you search for;
Your location;
Duration of your visit;
Products you selected to create your basket.
Technical Information:
IP address;
browser information;
device information.
A unique identifier granted to each visitor and the expiration date of such identifier. We use Cookies, where relevant, with other personal data you have already shared with us (such as previous purchases, or whether you’re signed up to our email newsletters) or the following purposes:
To allow proper functioning of our website:
– proper display of the content;
– creation and remembering of a cart;
– creation and remembering of your login;
– interface personalisation such as language;
– parameters attached to your device including your screen resolution, etc;
– improvement of our websites, for example, by testing new ideas.:
To ensure the website/app is secure and safe and protect you against fraud or misuse of our websites or services, for example through performing troubleshooting.
To run statistics:
– To avoid visitors being recorded twice;
– To know users’ reaction to our advertising campaigns;
– To improve our offers;
– To know how you discovered our websites .
Legitimate interest:
to ensure we are providing you with websites, advertising and communications that are working properly and are continually improving for cookies that are (i) essential for the functioning of our websites, (ii) used to keep our websites safe and secure.
To deliver online behavioural advertising:
– to show you online advertisements for products which may be of interest to you, based on your previous behaviour;
– to show you ads and content on social media platforms.
To tailor our services for you:
– to send you recommendations, marketing, or content based on your profile and interests;
– to display our websites in a tailored way like remembering your cart or login, your language, the user-interface customization cookies (i.e. the parameters attached to your device including your screen resolution, font preference, etc).
To allow sharing of our content on social media (sharing buttons intended to display the site).
Consent
For all other cookies.
Promotional operations
Information collected during a game, contests, promotional offer, sample requests, surveys. Depending on how much you are interacting with us, those data may include:
Name;
Email address;
Phone number;
Birth date;
Gender;
Address;
Personal description or preferences;
Social media profile (where you use social login or share this personal data with us);
Other information you have shared with us about yourself (e.g. via your “My Account” page, by contacting us, or by providing your own content such as photos or a review, or a question via the chat function available on some websites, or by participating in a contest, game, survey).
To complete tasks that you have asked us to, for example to manage your participation in contests, games and surveys, including to take into account your feedback and suggestions.
Performance of contract
To provide you with the service you requested.
For statistics purposes.
Legitimate Interest
To help us better understand your needs and expectations and therefore improve our services, products and the Brands.
To send you marketing communications (where you have asked us to)
Consent
To send you direct marketing communications.
User Generated Content
Information collected when you submitted some content on one of our social platforms or accepted the re-use of content you posted on social media platforms by us.
Depending on how much you are interacting with us, those data may include:
Name;
Email address;
Personal description or preferences;
Social media profile (where you use social login or share this personal data with us);
Other information you have shared with us about yourself (e.g. via your “My Account” page, by contacting us, or by providing your own content such as photos or a review, or a question via the chat function available on some websites).
In accordance with the specific terms and conditions accepted by you:
– To post your review or content;
– To promote our products.
Consent
To reuse the content you posted online.
For statistics purposes.
Legitimate interest
To help us better understand your needs and expectations and therefore improve and promote our services, products and the Brands.
Automated Decision Making
For purposes of securing transactions placed through our websites against fraud and misappropriation, we use third party provider’s solution(s). The method of fraud detection is based on, for example, simple comparisons, association, clustering, prediction and outlier detections using intelligent agents, data fusion techniques and various data mining techniques.
This fraud detection process may be completely automated or may involve human intervention where a person takes the final decision. In any case, we take all reasonable precautions and safeguards to limit access to your data.
As a result of automatic fraud detection, you may (i) experience delay in the processing of your order / request whilst your transaction is being reviewed by us; and (ii) be limited or excluded from the benefit of a service if a risk of fraud is identified. You have the right to access information on which we base our decision. Please see “Your Rights and Choices” section below.
Profiling
When we send or display personalised communications or content, we may use some techniques qualified as “profiling” (i.e. any form of automated processing of personal data consisting of using those data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s personal preferences, interests, economic situation, behaviour, location, health, reliability, or movements). This means that we may collect personal data about you in the different scenarios mentioned in the table above. We centralize this data and analyse it to evaluate and predict your personal preferences and/or interests.
Based on our analysis, we send or display communications and/or content tailored to your interests/needs.
You have the right to object to the use of your data for “profiling” in certain circumstances. Please see “Your Rights and Choices” section below.
Who may access your Personal data?
We may share your personal data within Urban Label Group to comply with our legal obligations, to prevent fraud and/or to secure our tools, to improve our products and services, or after having obtained your consent to do so.
Depending on the purposes for which they were collected, and only on a need-to-know basis some of your personal data may be accessed by Urban Label entities worldwide, where possible in a pseudonimized way (not allowing direct identification), and where necessary to provide you with requested services.
We only share your personal data with third parties for direct marketing purposes with your consent. In this context, your data is Processed by such third party, acting as a data user, and its own terms and conditions and privacy notice apply. You should carefully check their documentation before consenting to the disclosure of your information to that third party.
Your personal data may also be Processed on our behalf by our trusted third-party providers (whether within or outside of Malaysia).
We rely on trusted third parties to perform a range of business operations on our behalf. We only provide them with the information they need to perform the service, and we require that they do not use your personal data for any other purpose. We always use our best efforts to ensure that all third parties we work with keep your personal data secure. For instance, we may entrust services that require the Processing of your personal data to:
Third parties that assist and help us in providing digital and e-commerce services such as social listening, store locator, loyalty programs, identity management, ratings and reviews, CRM, web analytics and search engine, user generated content curation tools;
Advertising, marketing, digital and social media agencies to help us to deliver advertising, marketing, and campaigns, to analyse their effectiveness, and to manage your contact and questions;
Third parties required to deliver a product to you e.g. postal/delivery services;
Third parties that assist and help us in providing IT services, such as platform providers, hosting services, maintenance and support on our databases as well as on our software and applications that may contain data about you (such services could sometimes imply access to your data to perform the required tasks);
Payment service providers and credit reference agencies for the purpose of assessing your credit score and verifying your details where this is a condition of entering into a contract with you;
Third parties that assist us for customer care and customer vigilance purposes.
We may also disclose your personal data to third parties (whether within or outside of Malaysia):
In the event that we sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets. If Urban Label or a part of its assets is acquired by a third party, personal data held by it about its customers relating to those assets is one of the transferred assets. Where appropriate, in such case, the buyer acting as the new data user Processes your data and its privacy policy governs the Processing of your personal data.
If we are under a duty to disclose or share your personal data in order to comply with a legal obligation, or in order to enforce or apply our terms of use/sales or other terms and conditions you have agreed to; or to protect the rights, property, or safety of Urban Label, our customers, or employees.
If we have your consent to do so
Or if we are permitted to do so by law.
We may disclose your personal data to our partners (whether within or outside of Malaysia):
Information that Facebook collects and shares with us
All Facebook features and services available on our website are governed by the Facebook Data Policy, in which you can get more info about your privacy rights and settings options.
By using this website, you may:
– Sign-up with your Facebook login. If you do so, you consent to share some of your public profile information with us;
– Use the Facebook social plug-ins, such as “like” or “share” our content on the Facebook platform;
– Accept cookies from this website/app (also identified as “Facebook Pixel”) that will help us understand your activities, including information about your device, how you use our services, the purchase you make and the ads you see, whether or not you have a Facebook account or are logged into Facebook. When you are using those Facebook features, we collect data that help us to:
– Show you adds you might be interested in on Facebook (or Instagram, Messenger or any other Facebook services);
– Measure and analyze the effectiveness of our website/app and ads.
We may also use the personal information you gave us on this website (such as your name and surname, email, address, gender and phone number) to identify you and/or those who have similar profile like yours in Facebook (or Instagram, Messenger or any other Facebook services) in order to show you and the others, ads that are even more relevant for you and the others. While doing this, Facebook will not share your personal information and will delete the information promptly after the match process is complete.
We do not offer or sell your personal data.
Is Your Personal Data Secure?
We are committed to keeping your personal data secure and taking all reasonable precautions to do so. We contractually require that trusted third parties who handle your personal data for us do the same.
We always do our best to protect your personal data and once we have received your personal data, we use strict procedures and security features to try to prevent unauthorised access. As the transmission of information via the internet is not completely secure, we cannot guarantee the security of your data transmitted to our site. As such, any transmission is at your own risk.
Links to Third Party Sites and Social Login
Our websites may from time to time contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we are not responsible or liable for these policies. Please check these policies before you submit any personal data to these websites.
We may also offer you the opportunity to use your social media login. If you do so, please be aware that you share your profile information with us depending on your social media platform settings. Please visit the relevant social media platform and review its privacy policy to understand how your personal data is shared and used in this context.
Social Media and User Generated Content
Some of our websites allow users to submit their own content. Please remember that any content submitted to one of our social media platforms can be viewed by the public, so you should be cautious about providing certain personal data e.g. financial information or address details. We are not responsible for any actions taken by other individuals if you post personal data on one of our social media platforms and we recommend that you do not share such information.
YOUR RIGHTS AND CHOICES
We respects your right to privacy: it is important that you are able to control your personal data. You have the following rights:
Your rights
What does this mean?
The right to be informed
You have the right to obtain clear, transparent and easily understandable information about how we use your personal data, and your rights. This is why we are providing you with the information in this Policy.
The right of access
You have the right to access to the personal data we hold about you (subject to certain restrictions).
We may charge a reasonable fee taking into account the administrative costs of providing the information.
Requests may in certain circumstances, be refused in accordance with the requirements prescribed under law.
To do this, please contact us at the details below.
The right to rectification
You have the right to have your personal data rectified if it is incorrect or outdated and/or completed if it is incomplete.
To do this, please contact us at the details below. If you have an account, it may be easier to correct your own data via your “My Account” function.
The right to erasure/right to be forgotten
In some cases, you have the right to have your personal data erased or deleted. Note this is not an absolute right, as we may have legal or legitimate grounds for retaining your personal data.
If you would like us to delete your personal data, please contact us at the details below. Please note that if you wish to delete your personal data, depending on the personal data deleted, we may not be able to provide you with the requested services as described within this Privacy Policy.
The right to object to direct marketing, including profiling
You can unsubscribe or opt out of our direct marketing communication at any time.
It is easiest to do this by clicking on the “unsubscribe” link in any email or communication we send you. Otherwise, you can contact us using the contact details below.
If you would like to object to any profiling, please contact us at the details below.<
The right to withdraw consent at any time for data processing based on consent
You can withdraw your consent to our Processing of your data. The withdrawal of consent shall not affect the lawfulness of Processing before the withdrawal of consent.
If you would like to withdraw your consent, please contact us at the details below. Please note that if you withdraw your consent, we may not be able to provide you with the requested services as described within this Privacy Policy.
The right to data portability
You have rights to move, copy or transfer data from our database to another. This only applies to data that you have provided whereby the Processing is carried out by automated means.
For further details, please contact us at the details below.
The right to restriction
You have the right to request restriction of our Processing of your data. This right means that our Processing of your data is restricted, so we can store it, but not use nor Process it further.
It applies in limited circumstances as follows:
the accuracy of the personal data is contested by the data subject (i.e. You), for a period enabling the data user to verify the accuracy of the personal data;
the Processing is unlawful and the data subject (i.e. You) opposes the erasure of the personal data and requests the restriction of their use instead;
the data user no longer needs the personal data for the purposes of the Processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
If you would like to request restriction or limitation of your data, please contact us at the details below.
The right to deactivate Cookies
You have the right to deactivate Cookies. The settings from the Internet browsers are usually programmed by default to accept Cookies, but you can easily adjust it by changing the settings of your browser.
Many cookies are used to enhance the usability or functionality of websites; therefore disabling cookies may prevent you from using certain parts of our websites as detailed in the relevant Cookie Table.
If you wish to restrict or block all the cookies which are set by our websites (which may prevent you from using certain parts of the site), or any other websites, you can do this through your browser settings. The Help function within your browser should tell you how. For more information please consult the following links: http://www.aboutcookies.org/;
To deal with your request, we may require proof of your identity.
CONTACT
If you have any questions or concerns about how we treat and use your personal data, or would like to exercise any of your rights above, you may contact us via e-mail at info@pmtgroup.com.my or via telephone line at +603-8075 8008 (9:00am to 5:00pm, Monday – Friday [excluding weekends and public holidays]) or by writing to us at CHL Euro Sdn Bhd, No. 12, Jalan BK 1/12, Bandar Kinrara Industrial Park, Bandar Kinrara, 47180 Puchong, Selangor Darul.
If you would like to unsubscribe from receiving text messages, emails or phone communications from Urban Label, you may email us at info@pmtgroup.com.my or by clicking the “unsubscribe” link at the bottom of each communication from us.
In the event of any discrepancies between this Privacy Policy, this Privacy Policy shall prevail.
(Updated as of: September 2023)
