UNIVERSAL X
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Universal X Sdn. Bhd. ("Universal X", "we", "us") is the data controller responsible for the personal data described in this notice. This notice is issued under the Personal Data Protection Act 2010, as amended by the Personal Data Protection (Amendment) Act 2024.
Our published company and contact details are being finalised and will appear on this page and on our Contact page before the E-Mall opens. In the meantime, all privacy enquiries should be sent to hello@universalx.shop.
This notice explains how we collect, use, disclose and protect your personal data when you visit the Universal X E-Mall, contact us through it, or redeem products through it.
The E-Mall is a members-only redemption store. It does not take payment. Products are redeemed using Product Points or Cash Points held in your Universal X member account, and collected in person from a stockist.
When you use the contact form: your name, your email address, and whatever you choose to write in your message.
When you subscribe through the footer form: your email address.
When you redeem products as a member: your member name and member identification, your Product Points and Cash Points balances, the products you redeem, the stockist you choose for collection, your collection reference, and the status of your order. This data reaches the E-Mall from the Universal X member system. You do not create a separate account here.
When you collect an order at a stockist: a record that the order was handed over to you, and the date of handover.
Automatically, when you browse: your IP address, browser type, device type, the pages you view, the time of your visit, and similar technical information generated by our hosting provider and our bot-protection service.
We do not ask you for sensitive personal data, including health information, and you should not send it to us through the contact form. If you tell us about a health condition unprompted, for example when asking whether a product is suitable for you, we will use it only to answer you and will not keep it longer than that purpose requires.
Directly from you, when you complete a form on the E-Mall or contact us. From the Universal X member system, when you are signed in as a member. Automatically from your device and browser when you visit. From a stockist, when you collect an order.
To answer your enquiries and provide customer support. To identify you as a member and show you your points balances and redemption history. To process, confirm and fulfil your redemptions, including preparing an order for collection. To confirm your identity at the point of collection. To keep records of redemptions and collections for accounting, audit and dispute resolution. To operate, secure and improve the E-Mall, and to prevent fraud and automated abuse. To send you updates you have asked for, where you have subscribed. To comply with our legal and regulatory obligations.
We do not sell your personal data. We do not use it for automated decision-making that produces legal effects for you.
Providing your personal data is voluntary. But if you do not provide it, we cannot answer an enquiry you send us, we cannot process a redemption or prepare an order for collection, and a stockist may not be able to release an order to you if you cannot be identified at handover.
We may disclose your personal data to the following classes of third party: our website host and forms provider, Webflow, Inc., for hosting the E-Mall and receiving form submissions; our bot-protection provider, Cloudflare, Inc., for preventing automated abuse of our forms; the operator of the Universal X member system, for verifying membership and points balances; stockists appointed by Universal X, for preparing and handing over orders for collection; our professional advisers in legal, accounting and audit roles, where reasonably required; and regulators, law enforcement and courts, where we are required or permitted by law.
Our web fonts are served by Google. Your IP address is visible to Google when a page loads its fonts.
We do not disclose your personal data to anyone else without your consent, unless the Act permits or requires it.
Our website host, our bot-protection provider and our font provider are based outside Malaysia and store data on servers outside Malaysia. Where we transfer your personal data outside Malaysia we do so in accordance with the Act's cross-border transfer requirements, and we take reasonable steps to satisfy ourselves that the recipient affords protections comparable to those under Malaysian law.
We take practical steps to protect personal data against loss, misuse, unauthorised access, alteration and disclosure, having regard to the nature of the data and the harm that would result. These include restricting access to those who need it, using reputable service providers, and serving the E-Mall over an encrypted connection.
No system is completely secure. If a personal data breach occurs, we will notify the Personal Data Protection Commissioner as soon as practicable, and we will notify you without unnecessary delay where the breach is likely to cause you significant harm.
We keep personal data only for as long as it is needed for the purpose it was collected for, and longer only where the law requires it, for example where accounting or tax rules set a minimum retention period for transaction records. Subscription email addresses are removed when you unsubscribe. Once personal data is no longer needed, we delete it or permanently anonymise it.
Under the Act you have the right to access the personal data we hold about you and be told how it is being processed. To correct personal data that is inaccurate, incomplete, misleading or out of date. To withdraw your consent to our processing of your personal data. To limit processing, including asking us to stop processing your data for direct marketing. To ask us to transmit your personal data directly to another data controller, where this is technically feasible and the formats are compatible. And to complain to us, and to the Personal Data Protection Commissioner.
Email hello@universalx.shop with your request. We may ask you to confirm your identity before we act, so that we do not disclose your data to someone else. We will respond within the period required by the Act. A fee may apply to an access request, as the Act permits. If we cannot comply with a request, we will tell you why.
If you are not satisfied with our response you may complain to the Department of Personal Data Protection (Jabatan Perlindungan Data Peribadi), Ministry of Digital, Malaysia, at www.pdp.gov.my.
The E-Mall uses only cookies that are necessary for it to function and to keep your session secure. At the date of this notice that is a single security token set by our hosting platform.
We do not use analytics cookies, advertising cookies, or tracking pixels on the E-Mall. If that changes, we will update this notice and ask for your consent where consent is required.
The E-Mall is intended for Universal X members, who are adults. It is not directed at children and we do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, contact us and we will delete it.
We may update this notice from time to time. The current version will always be published on this page with the date it was last updated. Where a change is significant we will take reasonable steps to bring it to your attention.
Universal X Sdn. Bhd. Email hello@universalx.shop