Privacy Policy

1. Privacy Policy

JT International Trading Sdn. Bhd. ("JTI", "we", "our", "us") respects the privacy of our consumers.  

This Privacy Policy ("Privacy Policy") (together with our Website Terms of Use and any other documents referred to in it) sets out how we use and process personal data of customers of our products and services and other individuals, including the visitors of our website (www.ploom.my), online platforms, systems and applications that we are responsible for (our "Platforms") and accredited users of our Platforms (e.g. mentors and experts appointed by our contracted agencies) (“you”) in compliance with applicable data protection laws, in particular, the Malaysia Personal Data Protection Act 2010 (“Act”). For the purposes of this Privacy Policy, the terms “personal data” and “process” and/or “processing” shall have the meaning as prescribed in the Act. 

Please read this Privacy Policy together with any other document or information that we may provide to you from time to time in relation to specific initiatives and activities that we may undertake to understand our views and practices regarding your personal data.

2. Your duty to inform us of changes

It is important that the personal data we hold about you is accurate, complete, not misleading and kept up to date. Please keep us informed if any of your personal data changes during your relationship with us.

3. Information we may collect 

For the purposes as detailed in section 6 of this Privacy Policy, we may process the following categories of personal data:
 

• Full name; 
• Age;  
• Birthday; 
• Contact details (e.g. address, e-mail address and phone number); 
• Information in relation to our products/services you have purchased or used, including information about your account, purchase history, orders, customer  feedback, market research and other sales data; 
• Details of your interactions with us, including service messages and notes of your communications and conversations with us; 
• Details of your visit to a retail store or an event, how frequently you visit, which areas you visit and for how long, and which purchases you make; 
• Details of whether you have referred a friend to us; 
• Recordings of your voice that we make and store on our servers when you contact our Ploom Care Team; 
• Personal preferences and habits in relation to the products and services we provide; 
• Technical information about the use of our Platforms and contact center, including time and duration, the Internet Protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, traffic data, browser plug-in types and versions, operating system and platform and information about the use of cookies and tracking technologies. Strictly necessary cookies will always be switched on and you may also enable additional cookies as well. For more information on cookies and how to accept or refuse cookies, please see our Cookies Policy. 
• Marketing and communications information, including marketing preferences for receiving marketing communications from JTI and/or third parties. 
• Nickname, likeness, pseudonym, rights of publicity, live or recorded performance, autograph, photographs and your biographical information. 
• All other details provided by you to us from time to time and all other personal data we again collect from you on any subsequent occasion. 

Where you provide financial and credit card information on our Platforms, please note that we do not access or store this personal data. We use trusted third parties to process your payment and we have no access to your financial and credit card information. 

We will identify the categories of personal data that are mandatory to be provided by you in our forms (collectively, “compulsory personal data”). We may refuse to process the personal data for any of the purposes specified in this Privacy Policy if you fail to supply the compulsory personal data.

4. Where we obtain personal data directly from you 

We may obtain your personal data from you in a number of ways, including when you: 

• register to be a member of our databases (including loyalty programs), which will include performing age verification in person or online; 
• register directly with us to take part in our business initiatives and activities (e.g. surveys, offers, competitions, prize draws, campaigns, 14 Day Ploom Trial, Ploom Club, trade tools etc.) in person or online; 
• use our Platforms; 
• fill in any forms on our Platforms, or our associated platforms and micro-sites;  
• register a device with us; 
• register to receive email alerts or marketing; 
• participate in events organized by us; 
• sign up to the 14 Day Ploom Trial; 
• communicate with us via our Ploom Care Team, our Platforms, phone, e-mail, social media or otherwise (e.g. Trial SMS, Live Chat etc.). This includes information you provide when you register to use our Platforms, subscribe to our service, search for a product, place an order on our Platforms, enter a competition or survey, when you report a problem with our Platforms and when you post on our social media. 

5. Where we obtain personal data from other sources 

In addition to obtaining personal data directly from you, we may also collect your personal data indirectly through the following means: 

• when you use any of the other platforms that we operate or the other services we provide, which may be run by our platform providers and their related third parties; 
• from other third parties we work closely with (including, for example, other JTI group companies, hosting providers, payment service providers, delivery providers, retailers, customer services providers, product assistants, loyalty and review platform providers, customer relationship management services, consumer data platform providers, marketing automation providers,  information services providers, age verification providers, events organizers, consumer feedback providers, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies, marketing agencies); 
• from our trusted network of agents, customers and partners, including at events organized by our business partners, retail stores, agents, experts and mentors, where you interact with them online or offline.

In this Privacy Policy, we refer to all the methods by which you are in contact with us as "JTI touchpoints". JTI touchpoints include both physical (for example, retail outlets and events), and digital (for example, websites). 

As mentioned above, we may collect information about you automatically through the use of cookies and similar tracking technologies (such as web beacons/pixels) that you receive when you visit digital JTI touchpoints or get an electronic message from us. The specific cookies and other mechanisms used will depend on the touchpoint in question. To learn about these mechanisms used on a JTI touchpoint, including how you can accept or refuse cookies, please see the information made available on or through that touchpoint. These mechanisms may include Google analytics cookies (see www.google.com/policies/privacy/partners/.) 

Where permitted by law, we may acquire information about you from third parties. This may include information shared between JTI affiliates, publicly available profile information (such as your preferences and interests) on third party social media sites (such as Facebook and Twitter), marketing lists and supplementary information acquired from third party agencies. 

Where permitted by law, we may infer information about you from information about you that we already have. For example, we may use aggregated information about people in certain geographical areas, that we acquire from third parties, to infer your preferences. 

We may also collect your personal data in other contexts made apparent to you at the time. 

6. Purposes for which we can use your personal data  

Your personal data is being or is to be collected and further processed by us for the following purposes:

• To comply with our legal obligations to verify your age and only sell age restricted products to adults. 
• To process and discharge our contractual obligations to you as a buyer of our products, including fulfilling orders, sending receipts, processing payments and providing warranty services. 
• To provide sales-related services including dealing with your queries and requests, general administration, troubleshooting and corresponding with you. We may also use your data for administering trial, warranty and loyalty programs. 
• To market our products and services to you (or provide you with information about third party products and services) by email, mail, telephone, SMS, social media or other online platforms. 
• To allow other third parties to directly contact you with marketing messages. 
• To determine which of our products and services may be of interest or relevance to you. 
• To personalise your customer experience on our website based on what we have learned about your interests, preferences and how you use our Platforms. 
• To undertake customer surveys and market research. 
• To invite you to participate in our events. 
• For internal management and administrative purposes.  
• For other purposes authorized by you or directly related or ancillary to the foregoing.

7. Direct Marketing 

We may send you direct marketing messages about our products and services via the communication channels (email, mail, telephone, SMS, social media or display pop-ups on other online platforms). 

We will always provide you with the opportunity to opt-out of receiving direct marketing communications from us in the future. You can do this through updating your Contact Preferences in your account, unsubscribing from email marketing by clicking on the unsubscribe link in the email you receive, following any opt-out instructions provided in the marketing communication or contacting us. Please note that it may take up to 30 days for us to process your request.

8. Links to other websites 

Our Platforms may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection, security and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and read the privacy policy applicable to the website in question before proceeding to visiting that website. 

9. Disclosure of your personal data to third parties 

We may share your personal data with third parties, where required, including: 

• with our third party service providers to support us provide you with our services and goods, carry out our business operations and comply with our legal obligations (e.g. hosting providers, payment service providers, delivery providers, retailers, customer services providers, product assistants, loyalty and review platform providers, information services providers, age verification providers, event's organizers, consumer feedback providers, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies, providers of customer relationship management services, consumer data platform providers, marketing automation providers, SMS service providers, cloud services and information technology services). 
• in order to provide you with a more tailored and effective customer service experience certain of our service providers may, on a secure basis, pool the information we provide to them with information provided by other companies to which you have also provided information. Our service providers analyze this information and provide technical data which enables you to receive an enhanced customer experience, including being contacted at times which are most convenient for you. If you wish to receive further information regarding the information collected for this purpose, please contact us using the Contact Us Form. 
• with our trusted network of agents, customers and partners, including retail stores, agents, experts and mentors. 
• with JTI group companies to provide you with our services and goods, carry out our business operations and comply with our legal obligations. 
• if you are referred as part of one of our referral programs we will share limited personal identity data with the person who referred you. 
• with regulatory authorities and government departments where required by law, including in response to a request from law enforcement authorities or other government officials. 
• when we consider disclosure to be necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. 
• in the context of organizational restructuring. 
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets. 
• if JTI or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. 
• in the event that we need to disclose your personal data to external professional advisers such as accountants, bankers, insurers, auditors and lawyers. 

10. Where might your personal data be sent? 

Depending on the nature of the personal data and the purposes of data processing, the personal data we collect may be transferred from Malaysia to other countries as part of our standard operations. 

Whenever we transfer your data abroad, we will limit access to your data only to those who need to see it, process your data in accordance with our internal data protection standards, protect it appropriately and only transfer information in compliance with applicable data privacy laws. When data is transferred, we will require the receiving party to keep your data confidential, delete it when it is no longer required and act in accordance with this Privacy Policy.  Accordingly, your personal data may be transferred outside of your jurisdiction and you hereby consent to such transfer.   

When using information as described in this Privacy Policy, your personal data may be transferred either within or outside the country or territory where it was collected, including to a country or territory that may not have equivalent data protection standards. 

In all cases, appropriate security measures for the protection of personal data will be applied in those countries or territories, in accordance with applicable data protection laws.

11. Your rights and how to contact us 

Subject to the Act, you have the following rights:

• Right to request access to your personal data.  
• Right to request correction of your personal data where the personal data is inaccurate, incomplete, misleading or not up-to-date.  
• Right to object to processing of your personal data for direct marketing purposes, as referred to above. 
• Right to limit the processing of your personal data including the right to withdraw consent previously given to us (in full or in part) to the processing of your personal data, subject to any applicable legal restrictions and a reasonable duration of time for such notice/request to be effected.

If you wish to exercise any of the rights set out above, or if you have any inquiries or complaints in respect of your personal data, please contact us at: 

Designation: Ploom Care Team 
Telephone number: 1800 228 338 
E-mail address: [email protected]

We may charge a reasonable fee to access your personal data. We may refuse to comply with your request in these circumstances and shall inform you of our refusal and reasons for our refusal in writing. 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

12. Changes to our Privacy Policy 

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy. By continuing to engage with us after the issuance of such amendment notice, you will be considered as having agreed to this Privacy Policy (as amended and updated). 

13. Language  

In the event of any inconsistency between the English version and the Bahasa Malaysia version of this Privacy Policy, the English version shall prevail over the Bahasa Malaysia version. 

UPDATED ON MAY 2024