Daekyo Malaysia Sdn Bhd (Co. Reg 619106-W)

This privacy statement (the "Statement") sets out how Daekyo Malaysia Sdn Bhd, a company registered in Malaysia (hereinafter referred to as "we", "us" or "our"), collects, uses, and discloses your personal data, as defined by the Malaysian Personal Data Protection Act 2010 ("PDPA"). This Statement is prepared in accordance with section 7 of the PDPA.

Daekyo Malaysia enforces strict protocols in respect of data protection. We are committed to protecting your personal data and will ensure that any processing of your personal data is done in compliance with the PDPA.

This Statement is provided in both English and Bahasa Malaysia. In the event of any conflict between the English and other language versions, the English version shall prevail. We may modify, update or amend the terms of this Statement from time to time by placing the updated Statement on our website, (www.myeyelevel.com) (“Website”). You are encouraged to review this Statement periodically to be informed of any changes. While we may send you a notice when there are material updates to this Statement, your continued use of our services shall signify your acceptance of such modifications, updates or amendments.

UNDERSTANDING THE DAEKYO STRUCTURE

Daekyo Malaysia is a private limited company registered in Malaysia and which is wholly owned by Daekyo Co. Ltd. (“our parent company”). “Eye Level” is a program developed and owned by our parent company. Each Eye Level center is owned and independently operated by a franchisee of the Eye Level program. This relationship is important to understand as it may determine the type of data we may collect and use.

For the purposes of this Statement, students of an Eye Level center shall be described as a “Student(s)”.

Any communication with us regarding this Statement can be referred to us via email to privacy.my@myeyelevel.com.

COLLECTION OF PERSONAL DATA

“Personal Data” means information about you which you have provided to us, such as your name, address, telephone number, NRIC, email address, particulars of your spouse or family members (including but not limited to your child or children, or child or children for whom you act as a guardian, legal or otherwise (“your Child”)) and any information which may identify you, your spouse or family members that has been or may be collected, stored, used and processed by us from time to time.

In the event your Child is registered as a Student, we may receive data such as results of internal assessments and externally set tests, pupil and curricular records, characteristics, such as special educational needs, exclusion information, details of any medical conditions, including physical and mental health and attendance information.

In addition to the Personal Data you provide to us directly (i.e. through enquiries or registration on our Website, during your communications with us and/or when you engage us to provide services), we may also collect your Personal Data from a variety of sources, including without limitation at any events, conferences, seminars or talks organized or sponsored by us and/or from the cookies used on the Website.

We may also collect image or video data from CCTV or other forms of security data of individuals, including Students and at Eye Level centers.

Sensitive data

If the need arises, we will obtain explicit consent from you before or when we process Sensitive Personal Data. Sensitive Personal Data adopts the definition in section 4 of the PDPA. We may process Sensitive Personal Data without your consent only in limited circumstances as permitted by law.

The provision of your Personal Data is voluntary. However, if you do not provide your Personal Data, we may not be able to (i) communicate with you; (ii) provide you or your Child the services required; (iii) respond to an enquiry or query you have made;  (iv) permit access to certain sections of the Website or other digital services provided by us where log in is required (v); and/or permit physical access to Eye Level centers.

Cookies

Our websites may transmit to your computer a “cookie”, which enables us to store information on your computer when you visit our websites. A cookie is a package of data that allows our server to identify and interact more effectively with your computer without having to spend time on identifying each customer, thereby also providing additional login convenience. You may configure and personalize your current browser to refuse, reject or delete such cookies.

Cookie further enables us to recognise you during your repeated visits. The type of information gathered is anonymous and non-personal (e.g. the IP address of the visitor’s computer, the date and time of the visitor’s visit, which pages the customer browsed and whether the pages have been delivered successfully). Apart from merely establishing basic connectivity and communications, we may also use this data in aggregated form to develop customised services which are tailored to your individual interests and needs. Should you choose to do so, it is possible (depending on the browser you are using), for you to be prompted before accepting any cookies, or to prevent your browser from accepting any cookies at all. This may however cause certain features of our Website not to be accessible. For more information on our cookies, you may refer to the Cookie Policy here.

PURPOSES OF COLLECTION AND PROCESSING

We may collect and process Personal Data for the following purposes:

• to refer the provider of Personal Data provided to us to a suitable Eye Level center based on the said Personal Data provided;
• to communicate with parents/guardians of Students who are enrolled in our education programs;
• to manage administrative matters, including but not limited to, billing and fee collection, Student records, and program evaluation;
• for us to comply with our obligations under law, including compliance with laws relating to evidence;
• to conduct performance analytics of Students and development of the Eye Level program; and
• for any other purposes that are necessary or incidental to the above purposes.

Direct Marketing

We may process your Personal Data to send you information, promotions and updates including marketing and advertising materials in relation to our products and/or services and those of our preferred merchants and strategic partners which may be of interest to you. In line with this:

• We may disclose your Personal Data to our strategic partners where you have subscribed for particular products and/or services which require such disclosure and/or where you have consented to such disclosure.
• With your consent, we and/or our strategic partners may send you marketing communications about products and/or services based on your preferences and interests.

If you do not intend to continue receiving any such marketing communications from us and/or strategic partners, you can opt-out of such direct marketing by contacting us at our provided email address. Please note that if you opt-out, we may still send you non-marketing communications.

Analytics

We may also generate or maintain profiles of yourself or your Child using internal data sources including your Personal Data or personal data obtained from third parties associated with or in collaboration with us. Any information we generate, collect or analyse for this purpose is highly aggregated, anonymous and categorised into common demographic attributes like region, age bracket, gender or behaviour. Information generated in common demographic attributes that we may establish does not contain Personal Data. The purpose of this analysis is primarily for marketing and advertising.

Academic performance data which is analysed may contain Personal Data. This analysis is purposed specifically with enhancing the Students’ performance within the Eye Level program and developing the Eye Level program further.

If we share data for analysis with third parties for any form of processing, we shall ensure that the data shared is highly aggregated and anonymous. You should be aware that these third parties may combine it with other information to conduct more comprehensive analysis for us.

By consenting to this this Statement you consent to our processing of any of your information for the above stated analytics purposes. If you do not agree with your information being processed by way of analytics for marketing, advertising or for a Student’s performance purposes, you may opt-out by contacting us at our provided email address. Please note, however, that analytics may be used for other purposes which are necessary for our products and/or services or our business relationship with you. Should you decide to opt-out of analytics for any purposes other than marketing or advertising, we may not be able to provide you with certain, products and/or services.

DISCLOSURE OF PERSONAL DATA

In processing Personal Data, we may engage individuals and/or companies and/or service providers to perform functions on our behalf, and consequently may provide access or disclose your Personal Data to the third parties such as those described below (not exhaustive):

• Companies and organizations that assist us in the performance of any contract entered with you or providing you with any services that you have requested or subscribed for any other third party related to or incidental to the performance of our contract with you, the provision of products and/or services to you, or in respect of maintaining our business relationship with you;
• Our parent company, subsidiaries, partners, franchisees, associated companies and strategic partners;
• Companies and organizations for compliance with any legal and/or regulatory obligations including but not limited to the detection or prevention of crime and/or fraud to which we are the subject, in addition to any obligation imposed under our contract with you;
• Companies and organizations that act as our payment channels including and without limitation, financial institutions for purposes of maintaining financial records, assessing or verifying credit/debit card details and facilitating payments of any amount due to us;
• Companies and organizations that act as our agents or contractors for the purposes of recovering any amount due to us;
• Our dealers and agents that work with us to provide or market and sell our products and/or services;
• Our professional advisers including lawyers, accountants, tax advisors and auditors;
• Any third party (and its advisers/representatives) in connection with any proposed or actual reorganization, merger, sale, consolidation, acquisition, joint venture, assignment, transfer, funding exercise or asset/share sale relating to all or any portion of our business or in the unlikely event of insolvency, bankruptcy or receivership, where your Personal Data will be transferred.

As our information technology, data processing services and storage facilities and/or servers may be located in jurisdictions outside Malaysia and so your Personal Data may be transferred to, stored, used and processed in such a jurisdiction. Your consent to the terms of this Statement will include your consent to the transfer of your Personal Data out of Malaysia as described herein.

While these entities may be established in countries that might not offer a level of data protection that is equivalent to the level of protection in Malaysia, we take appropriate steps to ensure that your Personal Data is adequately protected and not be processed in a manner which would be in contravention of the applicable data protection laws in Malaysia.

LIMITING PROCESSING OF PERSONAL DATA

We do not collect data that is unnecessary for the provision of our services to you.  We are committed to ensuring that your personal data is stored securely. You have the right at any time to request us to limit the processing and use of your personal data (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes). If you do not wish for your Personal Data to be processed, please contact us at our provided email address.

You should be aware that certain data is critical to the provision of our services to you and if you request to limit such data, it may affect our ability to deliver our services to you.

ACCESS AND CORRECTION OF PERSONAL DATA

You may request access to or correction of your personal data by contacting us at our provided email address. We may charge a fee for processing your request to cover the administrative costs involved in processing your request to access your Personal Data. We do not keep Student information indefinitely and adhere to an internal retention and destruction policy which is in line with prevailing standards. Presently Student information is retained for a maximum of one (1) year from the date the Student leaves the Eye Level program.

To submit a request for access to your personal data, please contact us at our provided email address at privacy.my@myeyelevel.com or submit a request form by clicking here with your specific request.