Last Updated: May 2, 2020
This document establishes the privacy policies of Asia Monitor Group, its websites and mobile applications, as well as its compliance with specific national and international jurisdictions (including the privacy regulations and laws thereof). The publication of this document rescinds all previous privacy policies – implied, spoken or written –
2. Organization Information
Modern information and communication technologies play a fundamental role in the activities of Asia Monitor Group.
Asia Monitor Group is based in Malaysia and at the following postal address:
A-13 A-01, The Scott Garden
289, Jln Klang Lama, 58000 Kuala Lumpur,
WP Kuala Lumpur
Asia Monitor Group can be reached via e-mail at email@example.com
3. Anonymous Access
Visitors can access the website/application home pages and browse sites/applications without disclosing personal data or information about themselves.
4. Services and Links
Asia Monitor Group websites allows communication with other visitors and post information that can be accessed by other visitors. Communication via these posts is voluntary. All information communicated is the responsibility and discretion of the individual and may be collected by other visitors. Asia Monitor Group sites may include links to third-party web/mobile service providers. Asia Monitor Group is not responsible for the content, accuracy, or privacy policies of third-party web/mobile services.
5. Automatic Data Collection
Asia Monitor Group may collect information from your computer, mobile phone or other access device. The information sent to us includes, but is not limited to, data on the pages you access, your computer IP address, referral data, device identifiers, the type of operating system you’re using, your location (GPS), mobile network information, standard web log data and other information. Web log data includes the browser type you’re using and traffic to and from our site to determine trends, administer the site, track user movement in the aggregate, and gather broad demographic information for aggregate use. Automated decision-making is used to determine the likelihood of fraudulent activity to include duplication of respondent(s) and proxy usage. Automatically collected data may be sent to 3rd party data processors for the purpose of fraud prevention.
6. Data Collection and Purpose
Additionally, we may share personal data and social-demographic information we collect from you with Third Party Market Research Companies for the purpose of
We may also share personal data and social-demographic information with partners for several purposes, including, without limitation, fraud detection and prevention, copyright infringement, data validation, incentive or reward fulfilment (if applicable), identifying respondents for re-contact surveys, or communications, database matching, data append, coding, data segmentation, and/or developing data insights regarding survey participants, but not for marketing purposes.
We reserve the right to share your identity with others within the stipulations of data protection in an attempt to prevent further fraudulent activity. We may also obtain information about you from third parties such as identity verification services.
7. Sharing and Cookies
8. Children's Privacy
Asia Monitor Group does not knowingly collect personal data from individuals under the age of 16 in the EU and 13 outside of the EU. Minors 16 to 18 in the EU and 13 to 18 outside the EU are permitted to access the services of the site only with parental permission. It is the responsibility of the individual and the parent to ensure such permissions are obtained. It is possible that by fraud or deception we may receive information given to us or pertaining to children under 16 in the EU and 13 outside the EU. If we are notified of this and as soon as we verify the information, we will immediately delete the information from our servers.
Except as set forth herein, Asia Monitor Group does not disclose personal data to subsidiaries or other organizations without your permission or where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties. Asia Monitor Group tries to limit the information it provides to third parties to the information they need to help Asia Monitor Group provide goods and services to you.
10. Third Party Advertisements
Asia Monitor Group may share non-personally identifiable information collected via the service in aggregate, anonymous form with advertisers or other third parties so that they may better evaluate what products and services are most appealing to different segments of the user base. Asia Monitor Group does not disclose your first name/last name, address, email address or any other Personal Information to these third parties unless you give your express consent.
11. Confidentiality and Security
Asia Monitor Group does not employ the use of secure transmission methods to send personal data.
Asia Monitor Group has implemented security policies, rules and technical measures to protect the personal data from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.
Asia Monitor Group employees and data processors with access or association to the processing of personal data are obliged to respect the confidentiality of visitor personal data.
Asia Monitor Group does not disclose personal data to State institutions and authorities unless required by law.
12. Your Rights
12.1 We have summarized the rights that you have under GDPR for EU data subjects. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. Your data is not part of a statutory or contractual requirement, or a requirement necessary to enter into a contract.
12.2 Your principal rights under data protection law are:
(a) the right to access;
(c) the right to erasure;
(b) the right to rectification;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
12.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected. You can access your personal data by visiting https://globalmarketsurvey.com/login/
12.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
12.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; b) you withdraw consent to consent-based processing; c) you object to the processing under certain rules of applicable data protection law; d) the processing is for direct marketing purposes; e) and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: a) for the purpose of market research purposes you have participated in; b) for compliance with a legal obligation; c) for the purpose of fraud prevention; or d) for the establishment, exercise or defence of legal claims.
12.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
12.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
12.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
12.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
12.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
12.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
12.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
12.13 You may exercise any of your rights in relation to your personal data by sending in a support ticket after being logged in.
Visitors from areas other than the EU may request access to their own specific personal information collected by Asia Monitor Group by visiting the member account information section of the Asia Monitor Group website: https://globalmarketsurvey.com/profile/
Access to personal information may require proof of identity. Access to personal data is provided without charge. Personal data may be challenged or updated and, where appropriate, data will be completed, erased, rectified or amended. Asia Monitor Group reserves the right to refuse access to personal data. In such a case, reasons will be given for refusal.
You can close your account through our website. If you close your account, we will mark your account in our database as "Closed," but will keep your account information in our database. This is necessary to deter fraud or abuse of the site, by ensuring that persons who try to commit fraud or abuse of the site will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally-identifiable information will not be used by us for any further purposes, nor sold to or shared with third parties, except as necessary to prevent fraud and assist law enforcement or as required by law.
13. International Data Transfers
We operate internationally and may transfer information about you to any jurisdiction where we do business, including Malaysia. When you use our websites, you acknowledge that we may transfer information about you as described in this policy.
We will transfer your personal information for any of the purposes identified in this policy to any of our subsidiaries, affiliates, service providers, and business partners that may be located outside of the jurisdiction where you are located. The laws in those jurisdictions may not provide the same level of data protection compared to the laws in your country. However, we will treat your personal information as subject to the protections described in this policy.
When we transfer personal information subject to the General Data Protection Regulation to entities located outside of the European Economic Area ("EEA"), we will rely on an appropriate legal basis, such as appropriate safeguards, which could include the standard contractual clauses, binding corporate rules, the EU-US Privacy Shield program, or another framework deemed adequate by the European Commission, or as otherwise permitted by applicable law, such as pursuant to your consent or in order to perform our contractual agreements with you.
14. Privacy Compliance
Global: OECD Privacy Guidelines on the Protection of Privacy and Transborder Flows of Personal Data Guidelines
Global: Malaysian Guidelines for the Regulation of Personal Data Files Adopted by General Assembly Resolution 45/95 of 14 December 1990
Malaysia: Privacy Act of 1994
European Union: European Convention on Human Rights and General Data Protection Regulation (GDPR)
Canada: Personal Information Protection and Electronic Documents Act
Privacy compliance is ensured by periodic self-assessment.
15. Notice to California Residents (CCPA)
CCPA defines the term “sell” broadly. Its meaning includes “renting, releasing, disclosing, disseminating, making available, [and] transferring…for monetary or other valuable consideration.”
Under this definition, and the CCPA’s broad definition of “personal information,” we may “sell personal information” about you to our vendors or other partners, such as your contact information or certain combinations of anonymized or pseudonymized demographic and other information.
Categories of information we’ve “sold” in the previous 12 months include:
Categories of information we’ve otherwise disclosed for a business or commercial purpose (for example, for confidential use by our service providers) in the previous 12 months include:
If you are a California resident, you also have the following special rights:
Your Right to “Know” and to Request Deletion
You have the right to know the categories and specific pieces of personal information we have collected about you. You have the right to know the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information, and the categories of third parties with whom we share personal information.
You have the right to request deletion of personal information we’ve collected or maintain.
To exercise these rights contact us at firstname.lastname@example.org. We may ask you to provide additional information, such as first and last name and email in order to verify who is making the request.
Please note that any requested disclosures will only apply to the 12-month period preceding the request, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.
Your Right to Opt Out of the “Sale” of Your Information
You have the right to opt out of the sale of your personal information.
Your Right to Non-Discrimination
You have the right not to receive discriminatory treatment by Asia Monitor Group for the exercise of the privacy rights conferred by the CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please understand, however, that certain exercises of your rights may render it impossible for us to render services to you.
Your Right to Use an Authorized Agent
You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided below. In order to verify you have authorized an agent we will require a signed, written authorization from you.
If you make a request to access or delete your information, or to opt out of the sale of your personal information, we may ask you for additional information to verify your identity. This information may include: your full name, birth date, phone number, email address, or other basic personal information about you that we already have on file.
16. Privacy Support
Asia Monitor Group
A-13 A-01, The Scott Garden
289, Jln Klang Lama, 58000 Kuala Lumpur,
WP Kuala Lumpur
Phone – +60 322422346