- We’ve updated the Policy to reflect changes in data privacy laws.
- We’ve added details about your ability to manage the information you share with us, and the new tools we’ve created to help you do that.
This updated Policy gives you more control over your information and more clearly explains how we use it. Our core commitments regarding your privacy haven’t changed, including the commitment in our Charter to never sell your data.
Changes to This Policy
We may update this Policy from time to time. If we do, we’ll let you know about any material changes, either by notifying you on the Site or by sending you an email. New versions of this Policy will never apply retroactively — we’ll tell you the exact date they go into effect. If you keep using StartUp Borneo after a change, that means you accept this Policy.
Who We Are
StartUp Borneo (together with RESONICS Global Sdn Bhd, RESONICS Consultancy, and its and their parents, subsidiaries, affiliates, agents, representatives, consultants, employees, officers, and directors — collectively, “StartUp Borneo,” “we,” or “us”) provides services that help people bring innovative startups together and creative projects to life. Our main service is a community platform for startups and as a lunchpad offering funding opportunity for innovative and creative projects. We are a Community Driven Organization based in Kuching, Sarawak.
How This Policy Applies
What We Collect and Receive
In order for you to create an account on StartUp Borneo and use our Services, we need to collect and process certain information. Depending on your use of the Services, that may include:
- Information you provide by completing forms on StartUp Borneo — your name, email and postal addresses, telephone number, country of residence, login, and password details. We may ask for this information if you register as a user of the Services, subscribe to our newsletters, upload or submit content through StartUp Borneo, or if you contact us;
- Information you provide for identity verification purposes when launching a startup business/project, including your legal name, business name and Tax ID for business entities, and date of birth. In some cases, our payment processor will request that you provide a secure upload of an identity document (such as your passport, drivers license or other government-issued ID) to StartUp Borneo;
- Details of any requests or transactions you make through the Services. StartUp Borneo partners with other companies (such as PayPal) for payment processing, and the payment information you submit is collected and used by them in accordance with their privacy policies (for PayPal’s, click here). StartUp Borneo doesn’t store your payment information apart from the last four digits of your credit card or bank account (as applicable), expiration date, and country, which we require for tax, government regulatory, and security purposes;
- Information about your activity on and interaction with StartUp Borneo, including use of our mobile apps (such as your IP address, the type of device or browser you use, and your actions on the Site);
- Communications you send to us (for example, when you ask for support, send us questions or comments, or report a problem);
- Information that you submit on or to StartUp Borneo in the form of comments, contributions to discussions, or messages to other users; and
- The email address associated with your Facebook account, if you choose to sign up using your Facebook credentials. StartUp Borneo will also request permission to access your name, profile picture, and friend list (these permissions are governed by Facebook’s privacy policies and can be managed through your Facebook privacy settings). We never post anything to your Facebook, Twitter, or other third-party accounts without your permission.
You may decline to provide us with your information. However, this will limit your ability to register for an account or use our Services. You may pledge to a project as a guest by providing only an email address. However, to adjust your pledge, save payment details for future pledges, make project comments and take most other actions on our Site, you will need to finish creating an account. You may review, change or remove your information through your account settings.
How We Use This Information
We use the information we collect for the following purposes:
- To keep your account secure and protect our Services (including to verify the identities of creators and prevent fraud and abuse);
- To enable us to provide you with our Services, and to improve and promote our Services;
- To create and administer your account, contact you, and customize your experience on StartUp Borneo (for example, to show you projects that we think may interest you based on your previous use); and
- To track and analyze use of the Services so that we can improve how StartUp Borneo is performing and provide users with the best experience possible.
Users Personal Data
Data protection law requires a “lawful basis” for collecting and retaining personal information. Our lawful bases include:
- Performing the contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver the Services, enable creators to establish and display their projects, and enable backers to find and make pledges to them.
- Legal compliance: Sometimes the law says we need to collect and use your data. For example, tax laws require us to retain records of pledges and payments made through our Services.
- Legitimate interests: This is a technical term in data protection law which essentially means we have a good and fair reason to use your data and we do so in ways which do not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests.
For example, we use identity, device, and location information to prevent fraud and abuse and to keep the Services secure. We may also send you promotional communications about our Services, subject to your right to control whether we do so.
We analyze how users interact with our Site so we can understand better what elements of the design are working well and which are not working so well. This allows us to improve and develop the quality of the online experience we offer all our users.
Transfer of Your Personal Data
Personal data collected by us will be kept confidential but we may provide such information to third parties when required to do so by applicable law, including but not limited to, a court order or enforcement agency. We may also transfer your personal data to the following third parties where such transfer or disclosure is necessary to satisfy any of the purposes set out above or a directly related purpose:
- Our staff;
- Any person or company who is acting for us or on our behalf in respect of the purpose set out above or a directly related purpose;
- Our agents or professional advisers (whether ours or our agents’), including accountants, auditors and lawyers;
- Any financial institutions, credit card issuing companies, payment service providers necessary to support payments in relation to your project or backing;
- External service providers (including but not limited to telecommunication companies, information technology companies) that we engage for the purpose set out above or a directly related purpose; and
- Government and regulatory authorities and law enforcement agencies and other organizations as required or authorized by applicable law.
Transfer of Your Personal Data Outside Malaysia
By using our service, you agree that we may transfer certain personal data to places outside Malaysia in order to carry out the purposes set out above or a directly related purpose
How This Information Is Shared
Information that’s shared publicly
When you create an account, we create a basic profile page for you on StartUp Borneo, containing your username, the date the account was created, and a list of projects you have backed or launched. By default, your profile is private and you can choose to make it public in your account settings. Your username appears with the comments you post and messages you send on StartUp Borneo and, if your profile is set to public, people can click your username to view it. If you make your profile public, others will be able to see the following things:
- The account username you select, and the date the account was created;
- Any information you choose to add to your profile (like a picture, bio, or your location);
- Projects you’ve backed (but not pledge amounts or rewards chosen);
- Projects you’ve created;
- Comments you’ve posted on StartUp Borneo; and
- If you have “Liked” a project update.
If you would like to have a public profile, but don’t want others to see your name or profile image on a project’s Community tab, you may choose an account image or name that is not identifiable (e.g., CatLuvr88). You can modify or delete certain information associated with your account (such as your username, profile image, biography and location) from your account settings, and you can change your privacy settings if you want to make your profile private or adjust the default settings.
Creators are also asked to verify their identities before launching a project. Once this has been done, the creator’s Verified Name will be publicly displayed on their account profile and on any projects they launch.
Information that isn’t shared publicly
The following data will not be publicly displayed or revealed to other users:
- Any payment information you provide;
- Your password details;
- Your IP address;
- Your phone number;
- Your date of birth and other identity verification documentation (for creators);
- Private profile information, in accordance with your preferences; and
- Communications you send to us (for example, when you ask for support, send us questions or comments, or report a problem).
Information that’s shared with trusted third-party services
We may share your information with certain trusted third-party services to help us provide, improve, promote, or protect StartUp Borneo’s Services (like when we partner with payment processors, or use services that help us manage our ads on other sites). When we share data with third-party services that support our delivery of the StartUp Borneo Services, we require that they use your information only for the purposes we’ve authorized, and that they protect your personal information at least to the same standards we do. We may also share information that’s aggregated and anonymized in a way that it doesn’t directly identify you.
Information that’s shared with creators and collaborators
When you back a project, the project’s creator will know your username, the amount you have pledged, and the reward you have selected. Creators never receive backers’ credit card details or other payment information.
If a project you have backed is successfully funded, the creator will receive the email address associated with your StartUp Borneo account. They may also send you a survey requesting information needed to provide your reward. (For instance, they may need your mailing address, or T-shirt size.) Any information you provide in such surveys will be received by the creator.
Creators are required to keep backer information confidential, except as strictly necessary to communicate with backers directly and fulfill rewards. Creators should not ask for personal information that isn’t necessary to provide your reward, and should never request sensitive personal information such as your Social Security number or payment information. Contact us at email@example.com if you receive a request for information that seems inappropriate or excessive.
Collaborators are third parties that creators can appoint to help manage their project. These collaborators may be able to access the information available to creators (including backers’ names, email addresses, pledge amounts, reward selections, messages, and survey responses), and are required to treat backers’ personal information with the same care and respect as creators are.
Creators and their collaborators may also receive routine traffic analytics about their project pages.
Information that’s shared to protect StartUp Borneo and comply with the law
We do reserve the right to disclose personal information when we believe that doing so is reasonably necessary to comply with the law or law enforcement, to prevent fraud or abuse, or to protect StartUp Borneo’s legal rights, property, or the safety of StartUp Borneo, its employees, users, or others.
Links to other websites and services
We will retain your information as long as your account is active, as necessary to provide you with the Services or as otherwise set forth in this Policy. We will also retain and use this information as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect StartUp Borneo’s legal rights.
We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our Site, improve our Services or comply with legal obligations.
Users residing in certain countries are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of your personal information. While these rights are not applicable globally, all StartUp Borneo users can manage their personal information, as further described below, in their account settings.
You can request a downloadable copy of your personal data from StartUp Borneo from your account settings page. To modify or delete the personal information you’ve provided to us, please log in and update your profile. You may also delete your account from your account settings page. We may retain certain information as required by law or as necessary for our legitimate business purposes.
Email and Mobile Notifications
We want to communicate with you only if you want to hear from us. We try to keep emails to a minimum and give you the ability to opt in to any marketing communications we send.
We will send you email relating to your transactions on StartUp Borneo.
We’ll also send you service-related announcements when it’s necessary to do so.
We take security seriously, and the security of your personal data is important to us. We follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. No method of transmission over the internet or electronic storage is completely secure, so StartUp Borneo cannot guarantee its absolute security. Your account information is protected by a password, which you should choose carefully and keep secure.
We have a Security Incident Response Team (SIRT) and protocol in place in the event of a data breach. We encourage the responsible disclosure of vulnerabilities of our Services by emailing firstname.lastname@example.org, and we will invite valid disclosures to our bug bounty program.
Data Protection Officer
To contact our Data Protection Officer, please email email@example.com.
You can contact us in writing at:
1st Floor, Parcel 1.1E, Lot 3338,
Block A, The Laksamana Commercial Suites,
93350 Kuching, Sarawak, Malaysia.
Data Protection Authority
Subject to applicable law, StartUp Borneo is committed to protecting the privacy, confidentiality and security of the personal data which we hold by complying with the requirements of Act 709 Personal Data Protection Act 2010 (Laws of Malaysia) (the “Law”) with respect to the management of personal data.
People under 18 (or the legal age in your jurisdiction) are not permitted to use StartUp Borneo on their own. StartUp Borneo does not knowingly collect any personal information from children under the age of 13 and children under 13 are not permitted to register for an account or use our Services.
If you believe that a child has provided us with personal information, please contact us at firstname.lastname@example.org. If we become aware that a child under age 13 has provided us with personally identifiable information, we’ll delete it.