Last Updated in December 2021

This Privacy Policy describes how Will Academy Sdn.Bhd. (Company Registration number: 1464625-P) (Company Address: No. 114, 2nd Floor, Parkcity Commerce Square, Jalan Tun Ahmad Zaidi, Bintulu, 97000 Sarawak, Malaysia) (hereafter collectively known as “us” or “we”) collects, uses, and shares information about you when you visit and interact on our website (mobile and desktop) and mobile app (collectively, “Site”) or other means connected to the Sites (such as contacting our customer service team via chat or email). Below is a detailed points of our privacy practices.

1. Information We Collect

We collect information about you that you provide to us when using the Site, such as your name, address, phone number, credit card details, e-mail address, and account password.

By visiting our Site, we may also automatically collect certain usage information, such as your IP address, geographic data, country, search preferences related to specific searches, browser, and information about your device’s operating system, application version, language settings, and pages that have been shown to you. If you are using a mobile device to access our mobile app or mobile optimized Site, we might also collect information that identifies your mobile device, such as the device ID, location of the device (with your consent), and device-specific settings and characteristics.

If you need to get in touch with our telemarketing team, or reach out to us through other means (such as through social media), we will collect information from you there too.

You can decide to participate in our programs or other promotions, and doing this will also mean providing us with personal data. In addition to that, you can provide us with feedback or ask for help with using the Sites or our various communications platforms.

Where required by law, we rely on the following legal bases to process personal information:

• Necessity to Perform Contract with You – we need to process your information in order to communicate with you – for example if there are changes to our seminars / courses that you have registered for and we need to inform you of the same;

• Our Legitimate Interests – we process your information for security and safety; to detect and prevent fraud; to protect and defend the rights or property of others, or our own rights and interests; and to respond to lawful requests, court orders, and legal process;

• Compliance with Legal Obligations – we need to process your information to comply with relevant laws and regulatory requirements;

• Consent for Direct Marketing Communications and Non-Essential Cookies – we rely on your consent to send direct marketing and to use/allow non-essential cookies. You can unsubscribe from direct marketing at any time by following the instructions set out in this Privacy Policy; and

• Protect Vital Interest – we may need to process your information in case of emergency involving an individual’s life or health.

2. How We Use the Information We Collect

We may use information collected through the Site to:

• Provide you with the requested services, such as creating a user account, processing and confirming your registrations with our courses, and communicating with you about services requested (excluding credit card number), special requests;

• Send you email marketing communications about products and services that may be relevant to you

• Conduct surveys or provide you with information about our services on our Site or on other websites you may visit

• Maintain and improve the Site, tailor the user experience, and for internal training

• Protect the security of you and the Site

• Exercising a right or obligation conferred or imposed by law, including responding to request and legal demands

When you make a registration on one of our business partners’ websites or apps, we may also receive certain information such as your name and reservation information in order to process your reservation and identify which channel your reservation has originated from.

Communications on the Site

We may access communications and may use automated systems to review, scan, and analyze communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research; customer engagement, including to provide you with information and offers that we believe may be of interest to you; and customer or technical support. We reserve the right to block the delivery of or review communications that we, in our sole discretion, believe may contain malicious content, spam, or may pose a risk to you, us or others. Note, all communications sent or received using the Site’s communication tools will be received and stored by us.

3. Mobile Devices

With your consent, we may send you push notifications with information about your participations, potential future participations, or as part of any of our programs that you participate in. You may grant us access to your location information or contact details in order to provide services requested by you. When you upload a picture from your mobile device, your picture may also be tagged with your location information.

4. Sharing Your Information

In connection with your visit to our Site and use of our services, we may share your information as follows:

• Third Party Service Providers who provide data processing services to us (for example web hosting), or who otherwise process personal information for purposes such as credit card and payment processing, business analytics, customer service, marketing, or distribution of surveys, to facilitate the delivery of online services and advertising tailored to your interests, and/or fraud prevention. Our third party service providers will only process information as needed to perform their functions. They are not permitted to share or use the information for any other purpose.

• Business Partners with whom we may jointly offer products or services, or whose products or services may be offered on our Sites. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasion share your personal information with those partners.

• Our Affiliated Group Companies – our affiliated (group) companies’ employees who have access to this information with our permission and who need to know or have access to this information to perform the service requested by you (including telemarketing) and internal (audit/compliance) investigations.

• Where Required or Permitted by Law – such as to protect ourselves against liability, to respond to subpoenas, judicial processes, legitimate requests, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, protect our legitimate interests or to the purchasers in connection with any sale, assignment, or other transfer of all or a part of our business or company. We may also, in compliance with applicable law, disclose your information to enforce or apply the terms and conditions applicable to our services or to protect the rights, property, or safety of willbusinessacademy.com, our users, or others.

• Business Reorganization – such as part of any sale, assignment or other transfer of our business, or transition of service to another provider. We will ask for your consent if required by applicable law.

We provide appropriate protections for such sharing as required by applicable law to prohibit third parties from using your information for their own purposes, and to address the security and confidentiality of your information. Except as disclosed in this Privacy Policy or as required or permitted by applicable law, we will not disclose your information to third parties without your consent.

5. Cookies

Our Site uses and allows third parties to place cookies (session and persistent), pixels/tags, SDKs, application program interfaces (“APIs”), and other technologies (collectively, “Cookies”) on our Site that collect and store certain information about you. Some of these Cookies are necessary to provide, secure, and maintain the Site to you, such as to keep you logged in while your visit our Site, while other Cookies are used to provide you with a better user experience, such as:

• To personalize the Site by remembering information about your activities on the Site (e.g., the language you selected or your log-in details);

• Perform website analytics, such as impression reporting, demographic reporting and interest reporting to improve our Site and services; and

• To provided you advertising tailored to your interest (see below for details)

Interest Based Advertising

We may also allow certain third parties to place Cookies on our Site in order to collect information about your online activities on our Site (e.g., pages visited on the Site and searches you performed) and over time and across different websites you may visit. This information is used to provide advertising tailored to your interests from us (via email, on our Site, and on other websites) and by third parties on other websites you may visit, also known as interest based advertising, and to analyze the effectiveness of such interest based advertising. We may also share one-way hashed information with third party partners (e.g., Facebook) who may combine hashed information with other identifiers in order to serve custom advertisements on other websites or mobile apps based on your prior visits to the Site. willbusinessacademy.com neither supports nor endorses the goals, causes, or statements of any websites or mobile apps that display our advertisements.

Cross-Device Tracking

We may also combine information collected through Cookies and certain usage information from a particular browser or mobile device with another computer or device that may be linked to you (cross-device tracking) in order to optimize our services and provide tailored communications and advertisements to you. If you do not want to combine such information for its optimization of communications to you can opt to unsubscribe yourself from you website.

Your Choices

Please review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details.

Please also visit the following third parties’ websites to exercise certain opt-out choices over Cookies:

• Google Analytics – https://tools.google.com/dlpage/gaoptout?hl=en

• Baidu – http://www.baidu.com/duty/safe_control.html

• Apple – https://support.apple.com/en-us/HT202074

• Facebook – https://www.facebook.com/ads/settings

• Google Ads – https://adssettings.google.com/

By exercising such choice regarding interest based advertising, you may still receive advertisements, but the network from which you opted out will no longer deliver ads tailored to your interests. You should also know that logging out of your user account will not actually mean that you opt out of personalized advertisements. You may need to make such choices on each browser and device you may use to exercise choice regarding certain Cookies. Lastly, at this time the Site is not configured to honor browsers’ “Do Not Track” signals.

6. Opting Out of Marketing Communications from Us

You can opt out of receiving marketing communications from us at any time by using the “Unsubscribe” link in each newsletter or communication, or through your account (if you’ve created one) – the email subscriptions settings is under “Profile”.

7. International Transfers

In connection with the purposes described above, your information may be stored in locations outside of your home country, which may have different standards of data protection than your home country. As permitted by applicable law, you may request details about the suitable safeguards we have in place by contacting us as detailed below.

8. Information from Other Partners

On occasion, affiliated entities, business partners, or other third party providers may share information with us. One example is if you access or sign in to our Site through social media, such as Facebook, we may collect information from you such as your username, and other information made available to us via such services. In general, your ability to provide such information is through the service provider themselves and you can change those settings in your account settings of the relevant service provider. In general, we may work with our partners to improve and personalize your use of our website in accordance with this policy.

9. Protecting Your Information

We maintain reasonable physical, electronic, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access. Please be advised that we do not keep your credit card information, thou occasionally you might be required to provide your bank account name and bank account number, but solely for the purpose of refund and reimbursement. Once the refund or reimbursement has been initiated, we will proceed to delete the information from your system.

Data Retention

We will retain your information for the period necessary to fulfil the purposes outlined in this Privacy Policy and internal company policies. When we no longer needs to use your information, we will – unless we need to keep your information to comply with applicable legal or regulatory obligations or the information is required to carry out corporate tasks and achieve our business objectives – remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.

10. How You Can Access or Change Your Information

You can easily correct your account name, your personal details and contact number at any time on our mobile application. Alternatively, please contact us at the contact details listed below (at section number 15) to exercise any of the following rights:

• Access: You are entitled at any time to obtain information about your personal information that we store, in accordance with applicable law and without any fee. However, in exceptional cases we ask you to pay reasonable fees before we provide the information if permitted by applicable law.

• Rectification: You may request that we rectify any of your personal information that is incomplete or incorrect.

• Deletion: You may request that we delete your account.

• Restrictions of Processing: i> You may ask us to cease processing of your personal information for example if you have objected to the processing and the existence of legitimate grounds is still under consideration.

• Objection: You may object, at any time, to your personal information being processed for direct marketing purposes.

• Right to Revoke Consent: You have the right to withdraw your consent at any time, without affecting the lawfulness of our processing based on such consent before it was withdrawn.

Data Portability : If applicable, you may request us to send you your personal information which we store, in a commonly used and machine readable format which shall be decided at our sole discretion.

To protect your privacy and security, we will verify your identity before responding to such request, and your request will be answered within a reasonable timeframe.We may not be able to allow you to access certain personal information in some cases e.g. if your personal information is connected with personal information of other persons, or for legal reasons. In such cases, we will provide you with an explanation why you cannot obtain this information. We may also deny your request for deletion or rectification of your personal information due to statutory provisions, especially those affecting our accounting processes, processing of claims, for fraud detection or prevention purposes, and mandatory data retention, which may prohibit deletion or anonymization.

11. Non Disclosure Clause

11.1. You shall (i) use reasonable efforts to maintain the confidentiality of the information and materials, whether oral, written or in any form whatsoever, of the other that may be reasonably understood, from legends, the nature of such information itself and/or the circumstances of such information’s disclosure, to be confidential and/or proprietary thereto or to third parties to which either of them owes a duty of nondisclosure (collectively, “Confidential Information”); (ii) take reasonable action in connection therewith, including without limitation at least the action that each takes to protect the confidentiality of its comparable proprietary assets; (iii) to the extent within their respective possession and/or control, upon termination of this Agreement for any reason, immediately return to the provider thereof all Confidential Information not licensed or authorized to be used or enjoyed after termination or expiration hereof, and (iv) with respect to any person to which disclosure is contemplated, require such person to execute an agreement providing for the treatment of Confidential Information set forth in clauses (i) through (iii).

11.2. As a violation by either Party of this Agreement could cause irreparable injury to the other Party and as there is no adequate remedy at law for such violation, the non-breaching Party may, in addition to any other remedies available to it at law or in equity, enjoin the breaching Party in a court of equity for violating or threatening to violate this Agreement. In the event either Party is required to enforce this Agreement through legal action, then it will be entitled to recover from the other Party all costs incurred thereby, including without limitation, reasonable attorney’s fees.

12. Updates to Privacy Policy

On occasion, we may revise this Privacy Policy to reflect changes in the law, our information collection and use practices, the features of our Site, or advances in technology. If we make revisions that change the way we collect or use your information, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy. Therefore, you should review this Privacy Policy periodically so that you are up to date on our most current policies and practices. We will also prominently post such material changes prior to implementing the change, and ask for your consent if required by law.

13. Links to Third Party Websites

We may provide links to other websites that are not owned or operated by us (“Third Party Websites”). When you use a link online to visit a Third Party Website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the linked Third Party Website before providing any information on that website.

14. Additional Considerations

Language

This Privacy Policy has originally been drawn up in the English language. Translations in other languages are available for your convenience. In case of conflict between the English language version and a translated version, the English language version shall prevail.

Terms of Use

Please review the our “Terms and Conditions” page for more details on using our Site. This Privacy Policy forms an integral part of our Terms and Conditions.

15. Contacting Us

If you have any questions about this Privacy Policy or our privacy practices, please contact our office addressed at No. 114, 2nd Floor, Parkcity Commerce Square, Jalan Tun Ahmad Zaidi, Bintulu, 97000 Sarawak, Malaysia or at the number 6010-5888 3464.