Privacy Policy

When we collect your personal data

Types of personal data

How we use your personal data

Visit and provide your personal data on the websites we own and operate (including https://www.ttigroup.com/)

When you visit our websites, we will record each of your visits and automatically collect the following information:

• technical information, including the IP address used to connect your computer to the Internet, your login information, browser type and version, geo-location, time zone setting, browser plug-in types and versions, device types, operating system, time and date of consent and platform; and
• information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our websites (including date and time), products you viewed, searched for, filtered or purchased/redeemed, the hyperlinks you have clicked, the websites you visited before arriving at our websites, page viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse the websites.

This information will be stored by us to administer our websites and for internal management, including troubleshooting, data analysis, testing, research, statistical and survey purposes and controlling illegal acts.

Purchase products at our store

When you make an order with us, through our physical stores, online stores or otherwise, we will collect personal data such as:

• your personal details, including your name, company name, address, email address and phone number; and
• your billing details, including your credit card information and billing address.

This information will be used by us to process your order, including arranging for product delivery, updating you on the delivery progress, verifying payment status and registering for product warranty.

Apply for a job with us and in the course of your employment

When you apply for a job with us (through email, by post or submit an application through our websites), you may be asked to provide personal data such as your name, telephone number, email address and correspondence address. We may also collect your resume, transcripts and reference letters, which may contain your personal data such as academic record, employment history and professional qualification. When you provide personal data of your referees to us, such as their names, company names, titles and contact details, you should have obtained their consent to act as your referees and provide such data to us.

Should you be offered a job with us, you may be asked to complete a form for employment which may require you to provide other personal data such as your Hong Kong identity card number / passport number and vaccination status. Further, in the course of your employment, should an update to your personal data in our record be required, we may collect additional personal data from you.

We collect your personal data to evaluate your job application, and should you be offered an employment with us, maintain our human resources record and attend to various human resources functions and activities.

Visit our premises

When you visit one of our premises, you may be asked to provide personal data such as your name, identity card number / passport number and health data such as vaccination proof.

We collect your personal data to maintain the security of our premises and ensure the health and safety of our staff members.

Subscribe for our newsletters and register for our events or campaigns

When you submit a form on our websites to subscribe for our newsletters or register for our events or campaigns, we may collect your personal data such as your name, telephone number, email address and correspondence address.

We collect your personal data to send you our newsletters and regular updates on our events and campaigns. This includes, without limitation, registering you for our investor-related events, activities and materials.

During marketing and other business events

We organise marketing, business development and other corporate events from time to time. During these events, we may collect your personal data such as your name, date of birth, telephone number, email address and correspondence address. In addition, we may, for the purpose of ensuring the health and safety of our participants, collect your health data such as vaccination proof.

We collect your personal data to record attendance, facilitate the event arrangement, send you event materials, contact you for feedback, deliver to you information about the Company, our products, services, events and campaigns, develop plans for future events and ensure the health and safety of our participants.

During your enquiry with our representative

When you make an enquiry with us, through telephone call, email, social media or otherwise, our representative may collect your personal data such as your name, date of birth, telephone number, email address, correspondence address and identity proof.

Please note for security reasons, our representative will not require you to provide your payment information (such as credit card details) and your full identity card number over telephone call, email or social media.

We collect your personal data to assist you with your questions, verify your identity and communicate with you if follow-up is required.

Complete our surveys and submit contact forms on our websites

When you complete our surveys, we may collect personal data such as your name, email address and correspondence address.

We collect your personal data to improve our products and services, contact you for further feedback, address your enquiries and handle any complaints you may have.

Category

Transferee

Among TTI Group Entities

Your personal data may be transferred to relevant persons in another TTI Group Entity.

Persons/other offices within the Company

Your personal data may be transferred within the Company.

Product delivery

Your personal data may be transferred to delivery service providers for sending to you the goods you order.

Payment

Your personal data may be transferred to our banks, credit card issuers, payment gateways or payment service providers to verify your payment details and status.

Other professional service providers

Your personal data may be transferred to agents, contractors and other third-party service providers who provide telecommunications, collection, credit reference, security, financial or other professional services to us.

Advertising networks

Your personal data may be transferred to Google, Facebook, Rakuten Marketing and other advertising networks for matching of your personal data with their database in order to send you our direct marketing materials through your Google and/or Facebook account(s).

Data processor

Your personal data may be transferred to agents, contractors or other third-party service providers which provide data processing or data storage services to the Company. In that case, the Company will adopt contractual and/or other means to ensure the data processors will take all practicable steps to (i) protect the personal data they hold against unauthorized or accidental access, processing, erasure, loss or use; and (ii) ensure that personal data will not be kept longer than necessary.

Data analytics and hackathon service providers and agencies

Your personal data may be transferred to data analytics and hackathon service providers and agencies to assist us in analysing user behaviour and activities and facilitate our event management. In most cases, only anonymized data will be transferred to these service providers.

Marketing (including digital marketing) and website analytic agencies

Your personal data may be transferred to marketing and website analytic agencies for display of advertising materials on our websites and other websites that you may visit, and analysis of your online behaviour and usage of our websites.

Parties and their representatives in a transaction

In the event the Company and/or any of the TTI Group Entities is involved in a merger, acquisition or due diligence exercise, your personal data may be transferred to a relevant outside party to the extent such data is reasonably required to decide on matters relating to the acquisition or merger. Examples of relevant outside party include the counterparty, their financial advisors, bankers and lawyers. Your personal data may also be transferred to new owners of the business.

Government departments, regulatory bodies and courts

Your personal data may be transferred to government departments, law enforcement, regulatory bodies and courts, to the extent permitted or required by applicable laws, rules, regulations, codes of practice or guidelines or pursuant to a court order.

Malaysia

This additional notice applies to all visitors in Malaysia and is presented in compliance with the Personal Data Protection Act 2010 (“PDPA”).

YOUR RIGHTS UNDER THE PDPA

As a data subject, you are entitled to assert the rights of a data subject at any time. In particular, you have the right to:

1. obtain information about whether or not and if applicable to what extent we process personal data concerning you;

2. access information, in particular, the following information: stored data concerning you, purpose(s) of the processing, categories of data, recipients to whom we disclose data or duration of storage in the case of processing of personal data concerning you;

3. require us to correct any personal data without undue delay which is inaccurate or incomplete;

4. ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us;

5. require us to delete or cease the collection, processing or use of your personal data without undue delay;

6. withdraw your consent given vis-à-vis us concerning the processing of your data at any time; and

7. require the processing of your personal data be restricted.

HOW DO I GET IN TOUCH WITH YOU

If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch with our Data Privacy Officer by phone or email:

Senior Executive, Digital & Marcom
marketing@milwaukeetool.my 
+603-7866 0668

Language

Pursuant to section 7(3) of the PDPA, this Policy is written in both English and Bahasa Malaysia versions. In the event of any inconsistency between the English version and the Bahasa Malaysia version of this Policy, the English version shall prevail.

Please click here for the Bahasa Malaysia version.

Last updated: 14 November 2022

Singapore

This applies to visitors within the ambit of the Singapore Personal Data Protection Act 2012 (“PDPA”).

By accessing or using or website and services, you hereby consent to the collection, use and disclosure of your personal data in accordance with this Policy, for the purposes set out in the When do we collect your personal data? section and the following additional general purposes:

(a) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;

(b) maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;

(c) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of TTI and/or of any TTI Group Entity; and

(d) record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of TTI and/or of any TTI Group Entity.

(collectively, the “Purposes”).

TTI may/will need to disclose your personal data to third parties, whether located within or outside Singapore, for one or more of the Purposes, as such third parties, would be processing your personal data for one or more of the Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties (whether located within or outside Singapore) for one or more of the Purposes and for the said third parties to subsequently collect, use, and/or disclose your personal data for one or more of the Purposes. Without limiting the generality of the foregoing, such third parties include the parties listed in the Who will we share this data with, where and when? section.

WHAT RIGHTS DO I HAVE?

The following rights listed under the What rights do I have? section may not be available to you under the PDPA:

1. The right to require us to delete or cease the collection, processing or use of your personal data without undue delay.

2. The right to require the processing of your personal data be restricted; and

The right to receive the personal data concerning you which you had provided to us in a structured, standard and machine-readable format, and to transmit these data to another controller.

Last updated: 14 November 2022

South Korea

This is an appendix to this Policy and should be read in conjunction with this Policy. It applies only to visitors who reside in South Korea. This Appendix may be amended or updated from time to time.

Items of Personal Information Collected, the Purposes of Collection and Use, and Retention Period

1. Types/items of personal data collected and the purposes of collection and use

The following table sets out the types/items of personal data collected and the purposes of collection and use.

Where we collect your personal data

Types/Items of personal data collected

Purpose and collection and use

Visit and provide your personal data on the websites we own and operate (including https://www.ttigroup.com/)

When you visit our websites, we will record each of your visits and automatically collect the following information:

• technical information, including the IP address used to connect your computer to the Internet, your login information, browser type and version, geo-location, time zone setting, browser plug-in types and versions, device types, operating system, time and date of consent and platform; and
• information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our websites (including date and time), products you viewed, searched for, filtered or purchased/redeemed, the hyperlinks you have clicked, the websites you visited before arriving at our websites, page viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse the websites.

This information will be stored by us to administer our websites and for internal management, including troubleshooting, data analysis, testing, research, statistical and survey purposes and controlling illegal acts.

Purchase products at our store

When you make an order with us, through our physical stores, online stores or otherwise, we will collect personal data such as:

• your personal details, including your name, company name, address, email address and phone number; and
• your billing details, including your credit card information and billing address.

This information will be used by us to process your order, including arranging for product delivery, updating you on the delivery progress, verifying payment status and registering for product warranty.

Apply for a job with us and in the course of your employment

When you apply for a job with us (through email, by post or submit an application through our websites), you may be asked to provide personal data such as your name, telephone number, email address and correspondence address. We may also collect your resume, transcripts and reference letters, which may contain your personal data such as academic record, employment history and professional qualification. When you provide personal data of your referees to us, such as their names, company names, titles and contact details, you should have obtained their consent to act as your referees and provide such data to us.

Should you be offered a job with us, you may be asked to complete a form for employment which may require you to provide other personal data such as your Hong Kong identity card number / passport number and vaccination status. Further, in the course of your employment, should an update to your personal data in our record be required, we may collect additional personal data from you.

We collect your personal data to evaluate your job application, and should you be offered an employment with us, maintain our human resources record and attend to various human resources functions and activities.

Visit our premises

When you visit one of our premises, you may be asked to provide personal data such as your name, identity card number / passport number and health data such as vaccination proof.

We collect your personal data to maintain the security of our premises and ensure the health and safety of our staff members.

Subscribe for our newsletters and register for our events or campaigns

When you submit a form on our websites to subscribe for our newsletters or register for our events or campaigns, we may collect your personal data such as your name, telephone number, email address and correspondence address.

We collect your personal data to send you our newsletters and regular updates on our events and campaigns. This includes, without limitation, registering you for our investor-related events, activities and materials.

During marketing and other business events

We organise marketing, business development and other corporate events from time to time. During these events, we may collect your personal data such as your name, date of birth, telephone number, email address and correspondence address. In addition, we may, for the purpose of ensuring the health and safety of our participants, collect your health data such as vaccination proof.

We collect your personal data to record attendance, facilitate the event arrangement, send you event materials, contact you for feedback, deliver to you information about the Company, our products, services, events and campaigns, develop plans for future events and ensure the health and safety of our participants.

During your enquiry with our representative

When you make an enquiry with us, through telephone call, email, social media or otherwise, our representative may collect your personal data such as your name, date of birth, telephone number, email address, correspondence address and identity proof.

Please note for security reasons, our representative will not require you to provide your payment information (such as credit card details) and your full identity card number over telephone call, email or social media.

We collect your personal data to assist you with your questions, verify your identity and communicate with you if follow-up is required.

Complete our surveys and submit contact forms on our websites

When you complete our surveys, we may collect personal data such as your name, email address and correspondence address.

We collect your personal data to improve our products and services, contact you for further feedback, address your enquiries and handle any complaints you may have.

Other than the specific purposes of collection and use of your personal data set out in the table above, personal data provided by you may also be used for the following general purposes, for other purposes as shall be agreed between you and us or as required by law from time to time:

• to provide our services to you, including responding to any questions you may have and recommending our products or services;
• to carry out our obligations arising from contracts entered between you and us;
• to monitor the use of, and to improve and protect our websites, products, contents and services;
• to investigate complaints and suspicious transactions; to prevent and detect crimes;
• to satisfy our legal obligations, including responding to requests by government or law enforcement authorities conducting an investigation;
•  to understand your preferences and behaviors in order to offer you a better user experience by the use of cookies and data sorting and analysis; and
• to provide marketing materials to you (including regular communications from us with details of our products, services and relevant benefits and information), if you have given the necessary consent regarding direct marketing (please refer to the section “DIRECT MARKETING” of the Policy).

2. The retention period of personal information

We aim to retain your personal information no longer than is necessary for the fulfilment of the purposes of collection unless a longer retention period is required or permitted by the applicable laws, including the following regulations: 

The Act on the Consumer Protection in Electronic Commerce, Etc. of South Korea

• Records about cancellation of an order or termination of a contract: 5 years
• Records about payments or provision of products: 5 years
• Records about consumer complaints and disputes: 3 years

The Protection of Communications Secrets Act of South Korea

• Log or access records: 3 months.

Matters relating to Operation of a Mechanism for Automatically Collecting Personal Information

The websites of our TTI Group Entities use cookies which, among other things, help us to improve your experience of our websites and to ensure that they perform as you expect them to. For detailed information on how we use cookies and the purposes for which we use then, please refer to our Cookies Policy.

Sharing of Personal Information

Personal information you provide to us may be disclosed or transferred (whether in South Korea or abroad) to one or more TTI Group Entities and/or third parties through information communication network at the time of collection, etc.  Please refer to the Who Will We Share This Data With, Where And When? section for details.

Delegation (and Overseas Transfer) of Processing of Personal Information

Personal information you provide to us may be provided to and accessed by agents, contractors or other third-party service providers who provide data processing, data storage or other professional services to us through information communication network at the time of collection, etc. Please refer to the Who Will We Share This Data With, Where And When? section for details.

Security Measures

All personal data you provide to us will be securely stored with restricted access by authorized personnel only. We utilize encryption/security software for data transmission so as to protect your data via encrypting it in a secure format to ensure its privacy and security from unauthorized access or disclosure, accidental loss, alteration or destruction.

In addition, we will adopt contractual or other means to prevent any personal data transferred to our data processors (i) from being kept longer than is necessary for processing of the data; and (ii) from unauthorised or accidental access, processing, erasure, loss or use, if we are to engage any data processor.

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 our websites; 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.

Destruction of Your Personal Information

The process and means of destroying your personal data are as follows.

1. Procedure

For personal data that is requested to be deleted, the data will be destroyed immediately upon request.

If we achieve the purposes of collection and use of your personal data, we will destroy these records (paper or electronic) after a certain period pursuant to our internal policy or applicable laws and regulations (please refer to the provisions on retention and use period).

Such personal data will not be used for any purpose other than the purpose permitted under the applicable laws and regulations.

In case any item(s) of personal data is required to be retained for a period beyond the period of retention and use as prescribed by applicable law, to the extent technically possible, such information item(s) will be stored or maintained separately from other items of personal data.

2. Method

The personal data that has been printed on paper will be shredded through the use of document shredder or incinerated.

The personal data stored in electronic file form will be deleted by using technical means that will not allow data recovery.

Users’ Rights and Methods to Exercise

As a data subject, you are entitled to assert the rights of a data subject at any time. In particular, you have the right to:

1. obtain information about whether or not and if applicable to which extent we process personal data concerning you;

2. access information, in particular, the following information: stored data concerning you, purpose(s) of the processing, categories of data, recipients to whom we disclose data or duration of storage in the case of processing of personal data concerning you;

3. require us to correct any personal data without undue delay which is inaccurate or incomplete;

4. ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us;

5. require us to delete or cease the collection, processing or use of your personal data without undue delay;

6. withdraw your consent given vis-à-vis us concerning the processing of your data at any time;

7. require the processing of your personal data be restricted; and

8. receive the personal data concerning you which you had provided to us in a structured, standard and machine-readable format, and to transmit these data to another controller.

All requests for access to or correction of personal data should be in writing and addressed to our Legal Department (please refer to the contact details below).

Contact Information

If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch with us via post or email:

Address:29/F, Tower 2, Kowloon Commerce Centre, 51 Kwai Cheong Road, Kwai Chung, New Territories, Hong Kong

Attention: Legal Department

Email: privacy@tti.com.hk

Last updated: 14 November 2022

Taiwan Region

HANDLING OF DISPUTES OVER THE ACCURACY OF PERSONAL DATA

In the event of a dispute regarding the accuracy of the personal data, TTI will, on our initiative or upon your request, cease processing or using the personal data, unless the processing or use is either necessary for the performance of an official or business duty or has been agreed to by you in writing, and the dispute has been recorded.

PURPOSE OF COLLECTION NO LONGER EXISTS

When the specific purpose of data collection no longer exists, or upon expiration of the relevant time period, TTI will, on our initiative or upon your request, erase or cease processing or using the personal data, unless the processing or use is either necessary for the performance of an official or business duty, or has been agreed to by you in writing.

OTHERS

If you would like to exercise any right to your personal date, including those set out in the appendix as well as in the section “WHAT RIGHTS DO I HAVE” of this Policy above, you can contact our Data Privacy Officer by post or email set out in the Policy above.

If any failure to correct or supplement any personal data is attributable to TTI, we will notify the persons who have been provided with such personal data after the correction or supplement is made.

Last updated: 14 November 2022

Thailand

INFORMATION WE COLLECT

We are required to notify you of the personal data to be collected and the period for which the personal data will be retained.  Please refer to the sections What information do we collect? and How long will my data be kept?

CATEGORIES OF PERSONS OR ENTITIES TO WHOM THE PERSONAL DATA MAY BE DISCLOSED

We may disclose your personal data to third parties for a variety of business purposes. Please refer to the Who will we share this data with, where and when? section for details.

DATA CONTROLLER

The data controller is [name of company].  For contact information, please refer to the section HOW DO I GET IN TOUCH WITH YOU.

YOUR RIGHTS

You may withdraw your consent to the collection and processing of personal data concerning you at any time.

You are entitled to request access to and obtain copy of personal data concerning you, which is under our responsibility, or to request the disclosure of personal data concerning you without your consent.

You have the right to receive personal data concerning you which we possess.

You have the right to object the collection, use, or disclosure of personal data concerning you, at any time, in those circumstances specified in the Personal Data Protection Act.

You have the right to ask us to erase or destroy personal data concerning you, or to anonymize personal data concerning you, in circumstances specified in the Personal Data Protection Act.

You have the right to ask us to restrict the use of personal data concerning you, in circumstances specified in the Personal Data Protection Act.

You have the right to file a complaint in the event that we or a data processor, including our respective employees or service providers violates or does not comply with the Personal Data Protection Act, including notifications issued thereunder.

Last updated: 14 November 2022

United States

This applies solely to all visitors who reside in the State of California and is presented in compliance with the California Consumer Privacy Act of 2018 (“CCPA”).

INFORMATION WE COLLECT

We are required to disclose to you the categories and sources of personal data we collect within the last 12 months. Please refer to the sections What information do we Collect? and How do we use this information, and what is the legal basis for this use? for details on the personal data we collect.

SHARING PERSONAL DATA/DO NOT SELL MY PERSONAL DATA

We may disclose your personal data to third parties for a variety of business purposes. Please refer to the Who will we share this data with, where and when? section for details.

We do not sell your personal data to third parties for their own marketing and advertising or other business purposes.

YOUR OTHER CALIFORNIA PRIVACY RIGHTS

Right to Know

You have the right to request us to disclose to you certain information about our collection of your personal data over the past 12 months. Upon receipt and confirmation of your verifiable customer request, we will disclose to you:

• The categories of Personal Information we collected about you
• The categories of sources from which we collected Personal Information about you
• Our business or commercial purpose for collecting or selling such Personal Information
• The categories of third parties with whom we share such Personal Information
• The specific pieces of Personal Information we collected about you

Right to Request Deletion

You have the right to request us to delete Personal Information we collected from you. Upon receipt and confirmation of your verifiable customer request, we will delete such Personal Information from our records, unless it is necessary for us or our service providers to:

• Complete the transaction for which such Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with applicable law, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely render impossible or seriously impair the achievement of such research, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal obligation; or
• Use such Personal Data, internally, in a lawful manner that is compatible with the context in which you provided such Personal Information.

Right to access Personal Data

You may submit requests to exercise your rights in relation to your personal data to the email address set out in the How do I get in touch with you? section. We will seek to disclose and deliver to you the required information in accordance with the CCPA.

Right not to be discriminated against

We will not discriminate against you because you exercise your California privacy rights, and will not deny you goods or services, charge you a different price or rates for goods or services, or provide a lower quality of goods or services to you due to the exercise of such rights.

Vietnam

This applies solely to all visitors who reside in the Socialist Republic of Vietnam and is presented in compliance with the laws of Vietnam on protection of personal data.

DIRECT MARKETING

We will not use your personal data unless we have received your consent. If we use your personal data in any direct marketing communications, you have the right to request that we provide you with the source of that personal data. There is no fee for requesting this information. We will provide you with the source of personal data and notify you when it is impracticable to do so. Please refer to the section Direct Marketing in this Policy above for other details on direct marketing.

WHAT RIGHTS DO I HAVE?

In addition to the rights you have as listed in this Policy above, you have the following rights:

1. To require us to update any personal data which is out of date without undue delay; and

2. To require us to cease to provide any personal data to any third parties. 

HOW DO I GET IN TOUCH WITH YOU

If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch with our Legal Officer / Data Privacy Officer by post or email:

Address:

Office 25.01, 25th Floor, Deutsches Haus Ho Chi Minh City, No. 33 Le Duan, Ben Nghe Ward, District 1, Ho Chi Minh City, Vietnam

Attention: Legal Officer / Data Privacy Officer

Email: TTIVNLegal@ttigroup.com.vn with copy to privacy@tti.com.hk

Phone number: +84 283 866 8600

Last updated: 14 November 2022