Privacy Policy - Pickles Auctions Asia

Privacy Policy

This Privacy Policy (“Privacy Policy”) describes how Pickles Asia Sdn. Bhd. (“Pickles Asia”, “we” or “us”) processes your Personal Data.

In the event of any conflict between the English and other language versions of this Privacy Policy, the English version shall prevail. We have the right to modify, update or amend this Privacy Policy at any time. Any change will be effective immediately upon publication on any of our online platforms (i.e. our websites, applications and software which may be installed on a mobile device or computer as well as its web version) and your continued use of the online platforms following the change means that you accept and agree to the change. Please see the date published below to determine when the Privacy Policy were last revised. For the purposes of this Privacy Policy, “Services” means Pickles Asia’s websites, services, applications and tools including its onsite and online auction services.

The definitions of the capitalised words, terms and expressions herein shall bear the same meaning as the said words, terms and expressions in the Terms and Services save where specifically defined in this Privacy Policy.

Collection of Personal Data

1. “Personal Data” means information about you, from which you are identifiable, including but not limited to your name, IC number, photograph of your IC, contact details, company information, correspondence information such as email address and telephone numbers, nature of your business, bank account information, IP address, cookie information, CRN number and GST registration number (where applicable), information in connection with the Services and any information about you which you have provided to Pickles Asia in any correspondence, interactions with any of Pickles Asia’s physical branches or auction houses and any information about you that has been or may be directly or indirectly collected, stored, used and processed by Pickles Asia from time to time. Pickles Asia will also receive and store your Personal Data from your browser or mobile platform when you access or use the Services. Web traffic pattern and log information including but not limited to search activities, browser type, referring page, device used, login frequency and time of visit may be collected. Cookies may be used to remember visitor preferences when interacting with the website. Where registration is required, the visitor’s email and username will be stored on the server (for more information on Cookies refer to point 4).

2. In addition to the Personal Data you provide to Pickles Asia directly, Pickles Asia may also collect your Personal Data from a variety of sources, including when you access or use the Services, from inquiry forms, registration forms, Customer Surveys and/or other similar forms, corporate documents that may contain your Personal Data, when you interact and communicate with Pickles Asia at any event or when you make enquiries. Pickles Asia may also collect your Personal Data from third party sources such as its brokers and business referral partners (e.g. where you have indicated that you wish to sell your goods by auction) and third party advertising companies to serve ads. Pickles Asia also collects information from financial institutions and other third parties in relation to hirers (e.g. where you were previously a hirer of our consignors).

3. Provision of your Personal Data is mandatory. If you do not provide Pickles Asia with your Personal Data, Pickles Asia will not be able to (i) provide you the Services (e.g. accept deposits, bids, process payments and transfer ownership of the vehicles); (ii) process or approve your registration application, and set up your membership account and (iii) the website may not be able to perform the functions for which it was intended.

4. If you do not wish to have cookies placed on your computer while browsing the site, please set your browser to refuse cookies before using the site, with the drawback that certain features of the site may not function properly without the aid of cookies.

Purposes of Processing

5. Pickles Asia may use your Personal Data to process and approve your registration application to subscribe to the Services and for the purposes relating to the business and activities of Pickles Asia which shall include, without limitation to, the following (“the Purposes”):-

• to process your registration with Pickles Asia, the setting up of your user account and/or profile;
• to help Pickles Asia identify you and any accounts you hold with Pickles Asia, and to manage/update your accounts;
• to fulfil your orders, complete your transactions with us, provide you with any services you have requested and to perform our functions and comply with our obligations (e.g. process your online bids and purchases, payments for the items purchased, etc);
• to contact and correspond with you regarding various matters pertaining to your registration and the Services;
• to respond to questions, comments and feedback from you;
• for generating leads;
• to improve your experience when using the Services, gain an understanding of your preference and requirements in order for us to personalise the site content and provide information, goods and services that are of interest to you;
• for operating the auction (whether onsite or offsite/online) business, including depositing and withdrawing funds from bidder accounts, registration of bids and completing the transactions related to a sale and its associated fees or transfer of ownership;
• for internal administrative purposes, such as auditing, data analysis, and to improve our Services;
• for internal and external investigations whether within or outside of Malaysia;
• for purposes of detection, prevention and prosecution of crime and fraud whether within or outside of Malaysia;
• to enforce or defend Pickles Asia’s legal rights and/or to obtain legal advice;
• for Pickles Asia to comply with its obligations under law whether within or outside of Malaysia;
• for Pickles Asia to comply with its internal policies and business rules;
• in connection with a corporate transaction, such as a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up

and you agree and consent to Pickles Asia using and processing your Personal Data in the manner as identified in this Privacy Policy.

Marketing and promotional purposes

6. Unless you have indicated otherwise, Pickles Asia may also use and process your Personal Data for marketing and promotional purposes such as to:-

• send you communication and mailers regarding our Services and Pickles Asia’s latest promotions or new product launches and services, including any promotions or information in relation to Pickles Asia’s partners and the Services they offer;
• to match online ads to your interests, to arrange for Pickles Asia’s and other third parties’ ads to reach you after you have left our sites and to help advertisers show you ads that are relevant to your interests;
• to update you about new business operations or service offerings relating to Pickles Asia’s Services;
• to send you Pickles Asia’s newsletter or any newsletters pertaining to the Services provided by Pickles Asia;
• to contact and inform you about events or activities which may be of interest to you;
• to conduct market research or surveys and offer contests and sweepstakes

by email (“Marketing Purposes”).

If you do not consent to Pickles Asia processing your Personal Data for the Marketing Purposes, please notify Pickles Asia using the contact details stated below. You may also unsubscribe by following the instructions included in any emails that you may receive.

Transfer of Personal Data

7. Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than Malaysia, such as in the following circumstances:

• where Pickles Asia’s administrative functions are being performed outside of Malaysia;
• where Pickles Asia’s and/or its service providers’ servers or back-up servers are located outside of Malaysia;
• where personal information is required to be disclosed to various law enforcement agencies outside of Malaysia;
• where Pickles Asia’s service providers, contractors, agents or partners are located outside of Malaysia;

and you understand and consent to the transfer of your Personal Data out of Malaysia as described herein.

Disclosure to Third Parties

8. Your Personal Data may be transferred, accessed or disclosed to third parties (who may be located overseas) for the Purposes and/or for the Marketing Purposes. Further, Pickles Asia may engage other companies, service providers or individuals to perform functions on Pickles Asia’s behalf, and consequently may provide access or disclose to your Personal Data to such service providers or third parties. The third parties referred to in this section include (without limitation):-

(a) Pickles Asia’s affiliated and related companies;
(b) Pickles Asia’s business partners (such as marketing, sweepstakes, newsletters and contest partners);
(c) Sellers/vendors (owners of the goods being sold) and brokers (agents and intermediaries between sellers and buyers);
(d) Advertising and Marketing agencies;
(e) Pickles Asia’s professional advisors, including our legal advisors, auditors, accountants and consultants;
(f) Service providers such as Pickles Asia’s printing, information technology (IT) and cloud service providers; and
(g) Third parties where the Personal Data is related to Pickles Asia’s primary purpose of administering or facilitating the purchase of a goods or services by you;
(h) Regulatory and governmental authorities within and outside Malaysia, in order to comply with statutory and government requirements.

Your Personal Data may also be shared in connection with a corporate transaction involving Pickles Asia, such as a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up.

Access & Correction Requests and Inquiries

9. Subject to any exceptions under applicable laws, you may request for access to and/or request correction of your Personal Data, request to limit the processing of your Personal Data for Marketing Purposes and/or make any inquiries regarding your Personal Data by contacting:-

Customer Service Representative
Email: info@pickles.my
Telephone number:

10. Pickles Asia may impose a fee in order for you to gain access your Personal Data.

11. Please note that if you withdraw your consent for Pickles Asia to process your Personal Data for the Purposes, Pickles Asia may consequently not be able to transact or contract with you and may be unable to provide you the products or services which you have requested. In such instance, we may also terminate your account with Pickles Asia.

12. In respect of your right to access and/or correct your Personal Data, Pickles Asia has the right to refuse your requests to access and/or make any correction to your Personal Data for the reasons permitted under law, such as where the expense of providing access to you is disproportionate to the risks to your or another person’s privacy.

Personal Information from Other Individuals

13. In some circumstances, you may have provided Personal Data relating to other individuals and in such circumstances, you represent and warrant that you are authorised to provide their Personal Data to Pickles Asia and you have obtained their consent for their Personal Data to be processed and used in the manner as set forth in this Privacy Policy and they have been alerted to the contents of this Privacy Policy.

Third Party Links and Apps

14. Use of any third party applications or any links to any other third party websites may be subject to the terms of use and privacy policies of such third parties. You should review such terms of use and privacy policies and we do not guarantee that they comply with our rules or Privacy Policy. Pickles Asia is not responsible for the privacy policies or practices in connection with other third party applications or websites.

Acknowledgement and Consent

15. By registering with Pickles Asia, communicating with Pickles Asia, engaging Pickles Asia or using Pickles Asia’s Services, you acknowledge that you have read and understood this Privacy Policy and agree and consent to the use, processing and transfer of your Personal Data by Pickles Asia as described in this Privacy Policy.

Revised 24 Sept 2017