Neuropower Malaysia Sdn Bhd (collectively, “Neuropower”), is committed to protecting the privacy of visitors to our websites (“Websites”) and users of our mobile applications (“Apps”). It is important that our users understand how we collect, use and disclose Personal Information (as defined below). This Privacy Notice (“Notice”) is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Websites and Apps.

References to “our”, “us”, “we” or “Neuropower” within this Notice are to Neuropower Malaysia Sdn Bhd. For the purpose of applicable data protection laws, Neuropower Malaysia Sdn Bhd is the data controller responsible for determining how and why your personal data is processed when you visit our Websites.

What Personal Information does Neuropower collect? How does Neuropower collect such Personal Information?

“Personal Information” is information through which a natural person is identifiable or may be identified, either directly or indirectly. This may include your name, physical address, the company for whom you work, phone number, email address, details of the preferences you express to us, your comments and questions, and technical information from the devices you use to access our website or product you are registering (e.g. a device identifier) or the person/company that installed or maintains it. Neuropower collects, uses and processes your Personal Information when you submit a form or request, or register a product with us in order to provide you with further information about Neuropower’s services or products.

The collection of Personal Information will be transparent to you, and you will have the opportunity to decide whether or not to provide it. However, please note that if you choose not to provide any of the Personal Information requested, Neuropower may be unable to provide you with the information and/or services or products that you have requested.

Neuropower may also collect certain Personal Information through your use of our Websites or Apps, such as device identifiers, IP address, and log files. For further information on “How does Neuropower use cookies or other tracking technologies?” please see below.

This Notice applies to all information we collect about you, information we collect directly from you, information we automatically collect, information we collect through our Websites, Apps and information we collect from third parties.

You have choices when it comes to the technology you use and the data you share. When we ask you to provide personal data, you can decline. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time.

Why does Neuropower collect your Personal Information?

Where we rely upon Legitimate Interest as a lawful basis, we have balanced your rights and freedoms against our interests or those of any third parties, and determined your rights are not infringed. Legitimate Interest is where your personal data is processed for either our own interests or the interests of third parties. This can include commercial interests, individual interests, or broader societal benefits.

Does Neuropower use your Personal Information to contact you?

Where you have provided your consent to receive marketing communications Neuropower may use the Personal Information you provide to contact you about products, services, promotions, special offers, surveys, and other information that may be of interest to you. If you would prefer not to receive such communications in the future, please let us know by sending an email to enquiry@neuropower.com.my. Please note that if you unsubscribe from marketing communications, you may continue to receive non-marketing communications about your account or transactions with us.

We will also use your Personal Information to contact you in response to a direct inquiry or if you register to receive communications on any of the Websites, such as the Investors section if available.

Does Neuropower share the information it collects with third parties?

Neuropower may share your Personal Information with its partners for the purposes set out in the table above.

In addition, Neuropower will provide access to or share Personal Information on an as-needed basis with third parties, including trusted service providers, consultants and contractors who are granted access to Neuropower facilities and systems or which provide services to Neuropower, and with government agencies and others as required by law.

Neuropower may share Personal Information with such third parties for the following purposes:

• to comply with Neuropower’s legal obligations, including complying with tax and regulatory obligations, sharing data with labour/trade unions and works councils, and responding to a court proceeding or a legitimate legal request from law enforcement authorities or other government regulators;
• to investigate suspected or actual illegal activity;
• to prevent physical harm or financial loss;
• to conduct web analytics on user interactions with our Website and Apps to improve our products and services; or
• to support the sale or transfer of all or a portion of our business or assets (including through bankruptcy).

We require any third party service providers that we use to respect the security of Personal Information that they process on our behalf, and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

Your Personal Information will also be maintained and processed by our service providers in Malauysia, within an appropriate legal and contractual framework, including (where applicable) the data transfer mechanisms required by applicable data protection laws, as detailed above.

How does Neuropower secure Personal Information?

Neuropower is committed to ensuring the security and integrity of Personal Information. Neuropower has adopted appropriate physical, technical and administrative procedures to safeguard your Personal Information when stored within Neuropower systems. However, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee or warrant that your transmission of Personal Information to us is completely secure.

How long do we keep your Personal Information?

We will only retain your Personal Information for as long as it is reasonably necessary for the purposes for which it was collected and to the extent permitted by applicable laws, including for the purposes of satisfying any relevant legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

When data is no longer necessary for the purpose of collection and/or processing, it will be removed, archived, or otherwise deleted as appropriate.

Your Rights – How can you correct, change or delete your information held by Neuropower?

You may request to access, update, correct, change, or delete your Personal Information at any time. Neuropower will use reasonable efforts to timely update and/or remove your Personal Information. To protect the user’s privacy and security, Neuropower will take steps to verify the user’s identity before making any requested access or change.

Failure to Provide Personal Information:

Where we are required by law to collect your Personal Information, or we need to collect your Personal Information under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the Personal Information we need in order to provide the services you have requested from us. In this case, we may have to cancel the provision of the relevant services to you, in which case we will notify you.

For all Website and App users:

To request access to, or for updates, corrections, changes, or to delete your Personal Information, you can contact us by email at enquiry@neuropower.com.my..

Please note that while we will assist you in protecting your Personal Information, it is your responsibility to protect your passwords and other access credentials from others.

What should you understand about the third party links that may appear on this Website?

In some instances, Neuropower may provide links to non-Neuropower controlled websites, which Neuropower will make reasonable efforts to identify as such. Neuropower does not control such third party websites, however, and cannot be responsible for the content or the privacy practices employed by other websites if you click through and leave a Neuropower controlled site. Furthermore, Neuropower is not responsible for the governing of information collected about you by third party websites or platforms and cannot guarantee the security of the personal data that you provide, or that is collected by such websites. When you leave our websites, we encourage you to read the privacy notice of every website you visit.

PowerMaster Account Deletion

After you delete your PowerMaster Account, you will not be able to reactivate your account. You will no longer be able to log in to the PowerMaster APP and web portal. The purchased plan associated with the account will be deleted immediately regardless of remaining purchased plan. The products registered in the said account will also be permanently deleted.

When you delete your account, any and all data or information associated with that account may be deleted at the same time. However; we may reserve the associated data or information of your account for a longer time under some reasons. Please see our Privacy Policy to know when we will reserve your data.

How to delete your PowerMaster Account

We are sorry to see you go but you may follow the steps below to delete your PowerMaster account:

1. Ensure that there are no more devices linked to your account. To do so:
   • Log in to your PowerMaster account.
   • Click on Devices Setting.
   • If you have registered devices, click on the trash can icon to delete the devices.
2. Please send an email to enquiry@neuropower.com.my for your account deletion request.
3. Our team will reach out to you and assist your further with the account deletion process.

Cookies and similar technologies

When you visit our Website, one or more “cookies” or similar technologies are generated and deployed with your consent, if required.

Cookies are small files of letters and numbers that are stored on your browser and/or the hard dive of your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit the Site. A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e. how long it will remain on your device) and a value, which is usually a randomly generated unique number.

We use cookies to make the Site easier to use and to better tailor our web presence and products to your interests and needs. Cookies are also used to help speed up your future activities and deliver a more personalised experience on the Site.

Some cookies may process your personal data (e.g. IP addresses and other online identifiers). Please see Neuropower’s Privacy Notice for further details about how your personal data is processed and your rights in relation to this.

Other cookies are used to compile anonymous, aggregated statistics that allow us to understand how people use our web properties and to help us improve web structure and content. We cannot identify you personally from this information although the same principles apply regarding these cookies.

Whilst necessary cookies will always be enabled, you can make your own choices regarding other types of cookies by managing which optional cookies are deployed on your device at any time. To do this you can set browser settings accordingly. Guidance on how to control cookies for common browsers can be found online

Please be aware that if you disable cookies that we use, this may impact your user experience while using the Site and could also mean that you may not be able to access all or parts of our website.

What additional information should specific users know?

Parents, Guardians, and Children: Our Apps and Websites are intended for visitors who are at least 18 years of age, or the age of majority in their jurisdiction of residence. Neuropower does not knowingly solicit information from, or market products or services to, children. If you do not meet the age requirements set out above, please do not enter your Personal Information on this or any other Neuropower Websites or Apps.

How might Neuropower change this Privacy Notice?

As Neuropower expands and improves its Websites and its Apps, or as legal requirements change, we may need to update this Privacy Notice. If we decide we need to update this Notice, we will notify you of any changes to the data processing activities described via an alert on the home page of our Website or App before these changes are implemented. The date of the latest version will be identified at the bottom of the Notice.

How can you contact Neuropower?

If you have any comments or questions about this Notice or our privacy practices, please contact us at enquiry@neuropower.com.my. or at No.23, Jalan Serendah 26/41, Hicom Industrial Estate, 40400 Shah Alam, Selangor, Malaysia.

Last Updated: October 2023