PRIVACY POLICY
This policy sets out general terms on how the Zazen Group (“Company” “we”, ”us” or “our”) collect, use and protect the privacy of your personal data under the Personal Data Protection Act 2010 (“PDPA”) as well as the European Union’s General Data Protection Regulations (“GDPR”). Please note that the Privacy Statement is streamlined to common principles of data privacy in most jurisdictions although there may be some slight variations due to local requirements.
The Zazen Group consists of the group of companies that include at present :
- Zazen Worldwide Sdn Bhd (551668-D)
- Zazen Design & Production Sdn Bhd (644275-H)
- Society for the Teachings of Dhyan Vimal, Malaysia (1317-09-SEL)
- Friends to Mankind Society of Malaysia (2022-09-SEL)
- Dhyan Vimal Institute for Higher Learning, Inc Canada (BC0792263)
- DV Retreat Center AB (559142-2042)
Which owns and manages the following websites:
- INFORMATION WE COLLECT FROM YOU
We may collect and process the following personal data about you
(a) Information that you provide by filling in forms on any of the websites indicated above or subsequent URL which may replace it and includes news, blogs, events, advertisements and any other contents (“Website”). This includes information provided at the time of registering to use the Website, subscribing to our service, posting material including queries, comments and photos, requesting further services or participate in our online programmes, or use other features of the Website. We may also ask you for information when you report a problem with the Website.
(b) If you contact us, we may keep a record of that correspondence.
(c) If you telephone us, we may keep details of the call.
(d) We may also ask you to complete surveys or provide feedback that we use for research purposes, although you do not have to respond to them.
(e) Details of transactions you carry out through the Website and of the fulfilment of your orders.
(f) Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
(g) Information that you provide through our social media sites, mobile app or other means of communications (whether electronically or otherwise).
(h) Any information about you through referrals from our affiliates and business associates whether in or outside Malaysia.
(i) Any identity verification information that you may provide when registering for a specific programme/transaction (if any) (such as images of your government issued ID card, passport, or driving license, as permitted by applicable law) or other authentication information for fulfilment of transaction, programmes and to help create and maintain a trusted environment.
(j) Any materials that you have distributed voluntarily (whether electronically or otherwise).
- IP ADDRESSES AND COOKIES
2.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to help diagnose problems with our server. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
2.2 For the same reason, we may obtain information about your general internet usage by using cookies. A cookie is an element of data that a website can send to your browser, which may then store it on your system. We use cookies in some of our pages to store your preferences and record session information. They help us to improve the Website and to deliver a better and more personalised service.
2.3 You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Website.
2.4 It is important that you prevent unauthorised access to your password and your computer. You should always log out after using a shared computer.
2.5 We use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of the Website. This software does not enable us to capture any personal passenger information.
- STORING AND SECURITY
3.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Union. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
3.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- USES MADE OF THE DATA
4.1 We use information held about you in the following ways:
(a) To enable you to access and use the Website.
(b) To provide you with information and update relating to our products, services and/or programs and other information that we think may be of interest to you.
(c) To facilitate your participation in our online or offline programs.
(d) To carry out our obligations arising from any contracts entered into between you and us.
(e) To notify you about changes to our services, products and/or programs.
(f) For financial purposes such as credit or other payment card verification, accounting, billing and audit.
(g) For business development purposes such as statistical and marketing analysis, systems testing, maintenance and development, customer surveys, customer relations or to help us in any future dealings with you, for example by identifying your requirements and preference.
(h) To comply with any legal or regulatory requirements.
(i) To enforce our terms of services and other policies and/or contract signed.
(j) For all other purposes ancillary to any of the purposes stated above.
- DISCLOSURE OF YOUR DATA
5.1 We may disclose your data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries or one of our affiliate companies.
5.2 We will not trade or sell your Personal Data to third parties. We may disclose your personal information to the following third parties appointed or authorised by the Company, who may be located within or outside European Union for the fulfilment of the purposes set out in Clause 4 above:
(a) In fulfilling our obligations of your order or facilitating your participation in our online or offline programs, in which case we may disclose your data to our staff operating in or outside European Union or by one of our service providers. Such staff or service providers maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details, the provision of support services and the facilitation of the programs.
(b) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions of use and other agreements; or to protect our rights, property, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
(c) In order to ensure the adequate performance of our contract with you, we will need to share need to share your personal date with our third party service providers to help us provide services related to the Website. Service providers may be located inside or outside of European Union. For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the our services through third party platforms and software tools (e.g. through the integration with our APIs), or (vi) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this policy.
(d) In jurisdictions where the Company facilitates or requires a registration, notification, permit, or license application with a local governmental authority in accordance with local law, we may share your personal data with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the your full name and contact details, accommodation address, identification number etc.
5.3 In the event that we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets.
5.4 If our assets or substantially all of our 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.
5.5 Information you share publicly on the Website may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
5.6 We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
- Third Party Partners and Integrations
The Website may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). We do own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, us, or both. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
- YOUR RIGHTS
You may exercise any of the rights described in this clause by sending an email to legal@dvinstitute.com. Please note that we may ask you to verify your identity before taking further action on your request.
7.1 Managing Your Information
You may access and update some of your information through your Account settings. You are responsible for keeping your personal information up-to-date.
7.2 Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Account).
7.3 Data Access and Portability
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
7.4 Data Retention and Erasure
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information, you can request that we erase your personal information and close your Account. Please note that if you request the erasure of your personal information:
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Account for fraud or safety reasons, we may retain certain information from that Account to prevent that member from opening a new Account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
- Information you have shared with others (e.g., comments, reviews, forum postings) may continue to be publicly visible on the Website, even after your Account is cancelled. Additionally, some copies of your information (e.g., log records) may remain in our database.
- Because we maintain the Website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
7.5 Withdrawing Consent and Restriction of Processing.
Where you have provided your consent to the processing of your personal information by us you may withdraw your consent by sending a communication to legal@dvinstitute.com specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Clause 6.6 and pending the verification whether the legitimate grounds of DV override your own.
Please note that it is obligatory for the Company to process your Personal Data for the purposes stated in Clause 4 above, without which we will not be able to keep you updated about our future, new and/or enhanced services, products and programs and/or for the performance of the contract between you and us.
7.6 Objection to Processing
In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by clicking the ‘unsubscribe’ button.
- ACCESS TO INFORMATION
Please note that depending on the information requested, a nominal fee may be charged. We will endeavour to provide the information back to you as soon as practicable. However we also reserve the right to validate all requests for the authenticity of the request. We may refuse to comply with data access request in circumstances as provided by the law. If we are not able to comply with your request, we will notify you of the reasons.
- SECURITY
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the Contact Us section below.
- CHANGES TO OUR PRIVACY POLICY
We reserve the right to modify this policy at any time in accordance with this provision. If we make changes to this policy, we will post the revised policy on the website. We will also provide you with notice of the modification on the website and Continued use of the website will constitute your agreement. If you disagree with the revised policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the website will be subject to the revised Privacy Policy.
- CONTACT US
If you have any questions or complaints about this Privacy Policy or our information handling practices, you may email us or contact us at: legal@dvinstitute.com