PRIVACY POLICY

ZEELA LEESA Ent, reg.no ( ) (“Zeela Leesa,” “we,” “us” or “our”) will process your personal data when you are visiting and using the services provided at ZeelaLeesa.com or purchase products in our stores. We strive to be transparent in what we do with our visitors’ and customers’ personal data and have therefore adopted this privacy policy. Below you will find information on what kind of personal data we process, why we do it, what we use it for and how we may share it. Zeela Leesa is the data user of any processing of your personal data, unless otherwise stated in this privacy policy.

By visiting ZeelaLeesa.com or purchasing products in our stores, or providing us with your personal information, you hereby consent to your personal information being collected, stored, used, processed and disclosed, as set out in Privacy Policy, including the transfer of your personal information to countries other than the country/region in which you originally provided it.

The Zeela Leesa subsidiary stated above will be the data user in respect of any processing of your personal data, except in relation to the processing described under “Browsing”, “Analysis of Data” and “Targeted Messages on Third Party Advertising Platforms” below, where Zeela Leesa Ent will be the data user. Please refer to Zeela Leesa Ent’s Privacy Policy for more information on how we manage your personal data.

WHAT PERSONAL DATA DO WE PROCESS?

We collect personal data when you (i) purchase watches, accessories, watch bands, gift cards or other associated goods and/or services, (ii) sign up for news, invites and offers, (iii) request support and (iv) are browsing our website. Such personal data will include your name, e-mail address, telephone number, delivery address, payment details, IP address, behavior on the website and other information that you voluntarily provide us. If we deliver a gift card (or other product) to you which is purchased by someone else than you, we process your contact details as provided by the purchaser.

Your provision of information is voluntary. However, if you choose not to provide information as requested, we may not be able to supply you with products or services as applicable.

PURPOSES FOR PROCESSING

We will only use your personal data for the purposes set out below. We will only retain your personal data for as long as it is necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. When we no longer need to use your personal data, we will remove it from our systems and records and / or take steps to promptly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

PURCHASES

Purpose of processing : When you purchase watches, accessories, watch bands, gift cards or other goods and/or services, we will process your personal data to fulfil our contractual obligations towards you (see Terms of Use).

Categories of personal data : Identity (first name and second name), delivery address/billing address, telephone number, e-mail address, order information, payment details, payment history, credit card information and payment reference number.

GIFT CARDS

If you purchase a gift card, we process your personal data as described under “Purchases” above. If you receive a gift card (or other product) which is purchased by someone else, we process your personal data as described below.

Purpose of processing : When you receive a gift card we will process your personal data to fulfil our contractual obligations towards the purchaser of the gift card and to be able to let you use your gift card for purchases of our products.

Categories of personal data : E-mail address (electronic gift cards only), shipping address and telephone number (physical gift cards only), first name and last name (optional for the purchaser to complete) and personal greeting (optional for the purchaser to complete).

DIRECT MARKETING

Purpose of processing : When you sign up for news, invites and offers (direct marketing), we will process your personal data to provide the services as requested by you. Our direct marketing may be based on profiling, which means that we will customize the information that you receive from us based on certain factors. We use the following types of personal data to compile a profile: your gender, your location, your previous purchases, your behavior on our website, and/or your previous behavior when receiving direct marketing from us.

Categories of personal data : Any data collected in connection with a purchase (see ”Purchase” above), e-mail address, location (based on the physical store or Zeela Leesa website that you use to sign up for our marketing communications), any communication sent to you, order history and the e-mails that you have clicked on and your interactions with our website if you have followed a link in any e-mails sent to you.

COMPETITIONS AND EVENTS

Purpose of processing : If you participate in a competition, lottery or event organized by us, we will process your personal data in order to be able to communicate with you (i) before or after participation in the competition, lottery or event (ii) for the purposes of identification and age control, or (iii) to elect a winner and to distribute the relevant benefit or price.

Categories of personal data : Depending on which type of competition, lottery or event that that you participate in, we may collect your name, e-mail address, location and date of birth, as well as your shipping address for the purposes of distributing the relevant benefit or price. More details on exactly what data we are collecting will be provided in connection with each such competition, lottery or event.

SUPPORT

Purpose of processing : When you request support through our live chat or our other support channels, we will process your personal data to be able to assist you with the relevant matter.

Categories of personal data : Your name, e-mail address and other contact details, order details, purchase amount, purchase history, place of purchase, invoice, payment method, our correspondence with you, technical data about devices and operating system used. At your initiative, we may also process personal data such as ID, bank account details, work place, phone number, health data (such as allergy reactions or other health data that you provide us with), pictures attached by you or social status, if mentioned by you in our dialogue.

CUSTOMER EXPERIENCE SURVEYS

Purpose of processing : If you have made a purchase from us, we are interested to hear about your experience of our website, the product, our service or any other experience you may have had while interacting with us. For this reason, you may receive an email from us where you are invited to answer some questions and give us feedback. You can also choose if you want us to contact you based on the feedback you have provided. Participating in the survey is voluntarily.

Categories of personal data : email address, order number, purchased products, gender (optional) and age (optional).

REPAIR SERVICE

Purpose of processing : When you use our repair services, we will process your personal data to fulfil our contractual obligations towards you (see Repair Service Terms and Conditions).

Categories of personal data : Identity (first name and second name), e-mail address, delivery address, any order information relating to the initial purchase, credit card information, payment reference number and photos of the product to be repaired (if requested by us in order to evaluate the possibility of performing the repair).

CHECKOUT REMINDER

Purpose of processing : If you have initiated a purchase at our website and if you have provided your e-mail address in connection therewith but have not completed the final step of your purchase, we will send you an e-mail with a link to your shopping cart for the purposes of reminding you of your uncompleted purchase.

Categories of personal data : Any details that you have entered in your shopping cart in connection with the uncompleted purchase (please refer to “Purchases” above for more details on what details we collect in connection with any purchase).

BROWSING

Purpose of processing : When browsing our website, we will process your personal data to improve our website and for marketing purposes.

Categories of personal data : IP-address, user generated data from cookies (e.g. clicks, page viewed, page visits, time spent, products viewed and clicked on, orders, average order value).

FRAUD PREVENTION

Purpose of processing : We will process your personal data for the purposes of carrying out risk analysis, fraud prevention and risk management.

Categories of personal data : Identity (first name and second name), delivery address/billing address, telephone number, e-mail address, order history, payment history, purchase- and user generated data (clicks and user history), information about how our digital services are used.

VIDEO SURVEILLANCE

Purpose of processing : When you visit one of our stores, we may conduct camera surveillance (if so, there are signs in the store informing of the surveillance) and thereby process moving pictures of you gathered through our surveillance cameras for the purposes of (i) preventing and investigating crime on property and towards employees and (ii) fire prevention.

Categories of personal data : Images and video recordings related to visitors of our stores and the date, time and place thereof.

ANALYSIS OF DATA

Purpose of processing : We will analyze your personal data, in order to compile aggregated tracking data (including to analyze visitors’ use of our sites by tracking information such as page views, traffic flows, search terms and click throughs) for the purposes of to continuously being able to offer a more user-friendly experience.

Categories of personal data : IP-address, user generated data from cookies (e.g. clicks, page viewed, page visits, time spent, products viewed and clicked on, orders, average order value), geographic location (country only), correspondence and feedback relating to our products and services, technical data (e.g. language, IP-address, device type, browser settings, time zone, operating system, platform), information about how you have interacted with us, i.e. how you have used our services, response times, page errors, how you reach and how you leave the site etc.

TARGETED MESSAGES ON THIRD PARTY ADVERTISING PLATFORMS

Purpose of processing : We use third-party advertising platforms, such as Facebook, Google, YouTube, Instagram, etc. to send you messages that are targeted at you, based on your behaviour and browsing pattern, at specific times and locations of these platforms to increase the efficiency of our advertising campaigns. Your personal data is shared with the third-party advertising platforms, and they will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from Zeela Leesa. We also need to analyse necessary information to understand the impact of our advertising. If you don’t accept that we track your data for this purpose, you may still see Zeela Leesa advertisements on other platforms at random.

You can learn more about how our advertising partners help us achieve this purpose by visiting their sites (the relevant links can be found in our Cookie Settings (see link below under “Cookies”)).

Categories of personal data : IP-address, user generated data from cookies (e.g. clicks, page viewed, page visits, time spent, products viewed and clicked on, orders, average order value), geographic location (country only).

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Only the people who need to process personal data for the purposes mentioned above have access to your personal data. We may need to share your personal data with our group companies. We further may need to allow our suppliers access to your personal data when they perform services on our behalf, mainly to provide support and maintenance of IT systems, storage services and marketing. Any transfer of data outside Malaysia is made in line with data protection laws. Our international transfers of personal data (including transfers to our group companies and suppliers outside the EU/EEA) are based on the EU Commission’s standard contractual clauses. The standard contractual clauses may be found here.

We do also share your personal data with other data users of personal data. Such data users could be authorities (police, tax authority or other authorities), if we are obliged to share it according to law or suspected criminal activities, and transport companies in order for them to handle and deliver your order. When your personal data is shared with other data users, they will be responsible for your personal data and we refer to them for more information on how they process your personal data.

YOUR RIGHTS

You are entitled to the following rights under applicable laws:

  • The right to access : you may at any time request to access your personal data. Upon request, we will provide a copy of your personal data in a commonly used electronic form.
  • The right to rectification : you are entitled to obtain rectification of inaccurate personal data and to have incomplete personal data completed.
  • The right to erasure (“right to be forgotten”) : under certain circumstances (including processing on the basis of your consent), you may request us to delete your personal data. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.
  • The right to object : to certain processing activities conducted by the us in relation to your personal data, such as our processing of your personal data based on our legitimate interest. The right to object also applies to processing of your personal data for direct marketing purposes.
  • The right to restriction of processing : you may under certain circumstances request from us to restrict the processing of your personal data, including personal information relating to other persons who may be identified from your personal information. Please note that this right is not unconditional. Therefore, an attempt to invoke the right might not lead to an action from us.
  • The right to data portability : you are entitled to receive your personal data (or have your personal data directly transmitted to another data user) in a structured, commonly used and machine-readable format.

Finally, you also have the right to lodge a complaint with the supervisory authority in Malaysia, which currently is Personal Data Protection Department (PDPD) in Malaysia.

COOKIES

As part of our approach to providing personalized services on our website, we use cookies to store and sometimes track information about you. A cookie is a small data file sent to your browser from a web server and stored on your hard drive that allows easier access the next time the same page is visited. For example, a cookie is sent when you sign-up to download products or information on our website. If you do not want your personal information to be stored by cookies, you can configure your browser so that it notifies you whenever a cookie is received. This way you can decide each time to accept cookies or not. However, the use of cookies may be necessary to provide certain features and choosing to reject cookies may reduce the functionality of our website. Your browser should include precise instructions explaining how to control the acceptance of cookies.

To be transparent, we have summarized the cookies used on our website below.

By clicking on the “cookie settings” button below, you will find a detailed list of the cookies we use on our website. Our website is scanned with our cookie scanning tool regularly to maintain a list which is as accurate as possible. We classify cookies in the following categories:

• Strictly Necessary Cookies • Performance Cookies • Targeting Cookies • Functional Cookies • Social Media Cookies

You can opt-out of each cookie category (except strictly necessary cookies) by accessing our Cookie Settings .

DATA SECURITY

We employ appropriate technical and organizational security measures to help protect your personal data against loss and to guard against access by unauthorized persons. Appropriate security measures we have taken include implementing secure private connections, traceability, disaster recovery and access limitations. We regularly review our security policies and procedures to ensure our systems are secure and protected.

CONTACT INFORMATION

If you have any questions relating to our handling of your personal data or our use of cookies or if you would like to invoke any of your rights under applicable privacy legislation, please contact our Data Protection Team at: info@zeelaleesa.com and/or our Customer Service at the toll-free number +60 19 293 9255.

CHANGES TO THIS WEBSITE PRIVACY POLICY

If we change how we handle your personal data or how we use cookies, we will promptly update this website privacy policy and publish it on this website. By continuing to use this website, you agree to the updated privacy policy as of its effective date.