This is the Personal Data Protection Policy of COD Express Delivery SDN BHD (“CODexpressdelivery”) (“Policy”). In accordance with the Personal Data Protection Act 2010 of the Laws of Malaysia (the “PDPA”), this Policy sets out how CODexpressdelivery manages, collects, uses and discloses Personal Data (as defined below) belonging to you. This Policy also sets out the purposes for which CODexpressdelivery collects, uses and discloses such Personal Data. You must only submit to us, our authorised agent or the CODexpressdelivery’s platform, information which is accurate and not misleading and you must keep it up to date and inform us of changes (more information below). We reserve the right to request for documentation to verify the information provided by you.
We will only be able to collect your personal information if you voluntarily submit the information to us. If you choose not to submit your personal information to us or subsequently withdraw your consent to our use of your personal information, we may not be able to provide you with our services. You may access and update your personal information submitted to us at any time as described below.
If you provide personal information of any third party to us, we assume that you have obtained the required consent from the relevant third party to share and transfer his/her personal information to us.
What does CODexpressdelivery do?
CODexpressdelivery is a third party logistics service provider. Our main business activity involves performing deliveries on behalf of both online and offline retailers / merchants (“Shippers”) to individuals, like yourself, who have purchased goods / products from these Shippers (“Individual Recipients”).
What Personal Data does this Policy cover?
When you create a CODexpressdelivery account, or otherwise provide us with your personal information through the CODexpressdelivery’s platform, the personal information we collect may include:
1. Name (including first and last);
2. Delivery Address (including residential and workplace);
3. Email Address;
4. Telephone Number;
5. Information concerning the products purchased (including product description, quantity and billing information);
6. Any other information that may be reasonably required to facilitate the delivery of products to you and other Individual Recipients. (Collectively, the “Personal Data”)
How does CODexpressdelivery obtain Personal Data?
Because CODexpressdelivery is a third party logistics service provider, we receive your Personal Data and Personal Data of other Individual Recipients from Shippers or other third party service providers that have engaged our services.
CODexpressdelivery may also, from time to time, contact you by email, over the phone or in person, to request for additional information that is reasonably required to facilitate the delivery of products to you. In such cases, by providing any Personal Data whether directly or indirectly from Shippers or other third party service providers that have engaged our services, you shall be deemed to have consented to the terms of this Policy, including the purposes set out in this Policy for which CODexpressdelivery collects, uses and discloses your Personal Data.
What does CODexpressdelivery require of our Shippers?
For every Shipper or third party providers that engages CODexpressdelivery’s services and, in the process of such engagement, provides CODexpressdelivery with Personal Data belonging to you and other Individual Recipients, CODexpressdelivery requires a warranty from the Shipper that the Shipper acts in full compliance with the Personal Data Protection Act 2010 of the Laws of Malaysia.
Specifically, CODexpressdelivery highlights the following that is required of Shippers before providing CODexpressdelivery with any Personal Data:
1. Obtain the consent of the Individual Recipient before collecting, using or disclosing his/her Personal Data;
2. Notify the Individual Recipient that his/her Personal Data will be used by a third party logistics provider, such as CODexpressdelivery, for the purpose of delivering products from the Shipper to the Individual Recipient; and
3. Ensure that Personal Data collected is accurate and complete so as to facilitate timely and successful deliveries for the benefit of the Individual Recipient.
How does CODexpressdelivery use Personal Data?
The personal information we collect from you or the Shipper(s) will be used, or shared with third parties (including related companies, third party service providers, and third party sellers), including purposes of serving you, ensuring timely and successful deliveries to you, and improving our service quality to you and for some or all of the following purposes (where applicable):
1. Managing the administrative and business operations of CODexpressdelivery and complying with internal policies and procedures;
2. Performance of your delivery service;
3.Tracking and analytics of your delivery;
4.Notifying you regarding the status of your order or delivery and updating you on the progress of the same;
5.Contacting you for feedback after or during delivery;
6.Responding to and handling your queries and requests;
7.Conducting investigations relating to disputes, billing or fraud;
8.Resolving complaints, problems or disputes;
9.Facilitating any correspondence between the Shipper and you;
10.Monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation;
11.Providing media announcements and responses;
12.Conducting research and analytics to enable us to better understand your location, preferences, demographic, and to improve our service delivery and your customer experience at our respective touchpoints;
13.Processing any insurance claims and payments that may arise under CODexpressdelivery’s policies;
14.Legal purposes (including but not limited to obtaining legal advice and dispute resolution);
15.Accounting, risk management, compliance and record keeping purposes;
16.Meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on CODexpressdelivery;
17.Purposes which are reasonably related to the aforesaid;
19.To process orders you submit through the Platform, whether the products are sold by CODexpressdelivery or a third party seller. Payments that you make through the Platform for products, whether sold by CODexpressdelivery or a third party seller, will be processed by our agent;
20.To deliver the products you have purchased through the Platform, whether sold by CODexpressdelivery or a third party seller. We may pass your personal information on to a third party in order to make delivery of the product to you (for example to our courier or supplier), whether the product is sold through the Platform by CODexpressdelivery or a third party seller;
21.To update you on the delivery of the products, whether sold through the Platform by CODexpressdelivery or a third party seller, and for customer support purposes;
22.To compare information, and verify with third parties in order to ensure that the information is accurate;
23.Further, we will use the information you provide to administer your account (if any) with us; audit the downloading of data from the CODexpressdelivery’s platform; improve the layout and/or content of the pages of the CODexpressdelivery’s platform and customise them for users; identify visitors on the CODexpressdelivery’s platform; carry out research on our users’ demographics and behaviour; provide you with information we think you may find useful or which you have requested from us, including information about our and services, provided you have indicated that you have not objected to being contacted for these purposes;
24.When you provide us with your personal information through the CODexpressdelivery’s platform, we will also use your personal information to send you marketing and/or promotional materials about our services from time to time. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies; and
25.In exceptional circumstances CODexpressdelivery may be required to disclose personal information, such as when there are grounds to believe that the disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes, or for fulfillment of legal and regulatory requirements and requests. When using your Personal Data for the above purposes, we may contact you via regular mail, fax, e-mail, SMS, telephone or any other electronic means.
How is your Personal Data protected from unauthorized disclosure?
At CODexpressdelivery, we take all reasonable steps to protect your Personal Data against unauthorized disclosure. We do not disclose your Personal Data to third parties except when required by law or to the following for the same purposes listed in the preceding section:
1. Our subsidiaries, affiliates and employees to provide and fulfil our services and obligations to you;
2. Our agents, contractors or third party service providers who provide operational services and support so as to assist in the fulfilment and performance of our services and obligations to you;
3. Our consultants and professional advisors, such as lawyers, auditors and bookkeepers;
4. Relevant regulatory bodies, statutory boards or law enforcement agencies in compliance with applicable law; and
5. Any other party to whom you have provided your consent for such disclosure.
In the event your Personal Data is disclosed to third parties as per the above, CODexpressdelivery will ensure that these third parties conform to this Policy, the PDPA and confidentiality requirements.
In addition, CODexpressdelivery implements strict standards of security across our operations to prevent any leakage, loss, damage, or unauthorized copying of your Personal Data in our systems.
As we can only ensure absolute data protection with your help, we invite you to contact our Data Protection Officer at any time should you have any concerns, queries or feedback regarding our use, management and protection of your Personal Data. We would love to hear from you should you wish to:
1.Access your Personal Data in our systems;
2. Amend, correct or edit your Personal Data in our systems;
3. Withdraw consent to our use of your Personal Data;
4. Report an unauthorized use of your Personal Data by any of our employees, agents or contractors;
5. Provide feedback on Shippers providing your Personal Data without consent; or
6. Voice out any other concerns and questions regarding your Personal Data.
You may contact our Data Protection Officer at firstname.lastname@example.org and we will get back to you within 48 hours.
Changes to this Policy
CODexpressdelivery reserves the right to amend this Policy from time to time, in accordance with the prevailing law. The amended Policy shall at all times be available on our website.
CODexpressdelivery’s Personal Data Protection Policy is governed by the laws of Malaysia and any dispute relating to this Policy shall be submitted to the exclusive jurisdiction of the courts of Malaysia.
YOU ACKNOWLEDGE AND AGREE THAT CODexpressdelivery HAS THE RIGHT TO DISCLOSE YOUR PERSONAL INFORMATION TO ANY LEGAL, REGULATORY, GOVERNMENTAL, TAX, LAW ENFORCEMENT OR OTHER AUTHORITIES OR THE RELEVANT RIGHT OWNERS, IF CODexpressdelivery HAS REASONABLE GROUNDS TO BELIEVE THAT DISCLOSURE OF YOUR PERSONAL INFORMATION IS NECESSARY FOR THE PURPOSE OF MEETING ANY OBLIGATIONS, REQUIREMENTS OR ARRANGEMENTS, WHETHER VOLUNTARY OR MANDATORY, AS A RESULT OF COOPERATING WITH AN ORDER, AN INVESTIGATION AND/OR A REQUEST OF ANY NATURE BY SUCH PARTIES. TO THE EXTENT PERMISSIBLE BY APPLICABLE LAW, YOU AGREE NOT TO TAKE ANY ACTION AND/OR WAIVE YOUR RIGHTS TO TAKE ANY ACTION AGAINST CODexpressdelivery FOR THE DISCLOSURE OF YOUR PERSONAL INFORMATION IN THESE CIRCUMSTANCES.