Privacy Policy

Who we are

This Privacy Policy is issued by Autonomous Logistic Solutions Sdn Bhd ("ALS", "we", "us", "our"), a company incorporated in Malaysia. ALS provides Level-4 autonomous electric logistics vehicles, deployment services, fleet operations and remote operations centre ("ROC") support to enterprise customers in Malaysia.

This Policy applies to personal data we collect through:

•    our corporate website at als-mobility.com

•    our deployment and demo-request microsite at [app.als-mobility.com / final URL]; and

•    any enquiry, demo request or other communication you send us through those sites or in connection with them

(together, the "Sites").

This Policy is our written notice under section 7 of the Personal Data Protection Act 2010 ("PDPA"). It does not govern personal data processed in the course of a commercial engagement with an ALS customer (for example, data captured by vehicle sensors or telemetry during a deployment). That processing is governed by the relevant services agreement and any data processing terms attached to it.

Personal data we collect

We collect only what is needed to respond to you and operate the Sites.

a)    Data you give us directly

When you submit a "Request A Demo" or contact form, email us, or otherwise correspond with us:

•    name and job title;

•    company or organisation name;

•    business email address and telephone number;

•    the nature of your enquiry, your operational requirements, and any other information you choose to include.

b)    Data collected automatically

When you visit the Sites:

•    IP address, browser type and version, device type and operating system;

•    pages visited, time and date of visit, referring website, and general interaction data;

•    cookie identifiers (see Section 8).

c)    Data from other sources

We may receive your business contact details from a colleague who refers you to us, from a business partner, or from publicly available professional sources, where relevant to a potential engagement.

We do not intentionally collect sensitive personal data (as defined in the PDPA) through the Sites. Please do not submit such data through any form.

Purposes of processing

We process your personal data for the following purposes:

We will not use your personal data for any purpose that is not directly related to the purposes above without first notifying you and, where required, obtaining your consent.

Disclosure of personal data

We may disclose your personal data to:

•    our employees and authorised personnel who need it to respond to you or perform the purposes above;

•    service providers who act on our behalf, such as website hosting, email and cloud infrastructure, analytics, and customer relationship management providers, in each case under obligations of confidentiality and only for the purposes above;

•    our technology and business partners where necessary to arrange a demonstration or assess a deployment, and only with your prior knowledge;

•    professional advisers, including legal, accounting and insurance advisers;

•    regulators, law enforcement and courts, where required by law or to protect our rights; and

•    a successor entity, in the event of a merger, acquisition, restructuring or sale of assets, subject to the same confidentiality obligations.

We do not sell personal data.

Transfers outside Malaysia

Some of our service providers (for example, cloud hosting and analytics providers) may store or process data on servers located outside Malaysia. Where personal data is transferred outside Malaysia, we will do so only in accordance with section 129 of the PDPA — including where the destination has comparable data protection law in force, where you have consented, or where the transfer is necessary for the performance of a contract with you or for steps taken at your request prior to a contract — and we will take reasonable steps to ensure the data is protected to a standard comparable to that required under Malaysian law.

Retention

We retain personal data only for as long as necessary for the purposes for which it was collected:

•    Demo requests and enquiries: for the duration of our discussions with you and up to [24] months after our last contact, unless a commercial relationship follows, in which case retention is governed by the relevant agreement.

•    Website analytics data: up to [26] months, after which it is deleted or aggregated so that it no longer identifies you.

•    Records required by law (for example, records relevant to a legal claim or regulatory obligation): for the period required by the applicable law.

When personal data is no longer required, we will delete or permanently anonymise it.

Your rights

Under the PDPA you have the right to:

•    access the personal data we hold about you;

•    correct personal data that is inaccurate, incomplete, misleading or out of date;

•    withdraw consent to processing at any time (this will not affect processing that took place before withdrawal, and may mean we are unable to continue responding to your enquiry);

•    object to processing that is likely to cause damage or distress, or that is for direct marketing purposes;

•    request data portability, where technically feasible, of personal data you have provided to us.

To exercise any of these rights, contact us using the details in Section 11. We may need to verify your identity before acting on a request. We may charge a prescribed fee for access requests as permitted under the PDPA.

We will respond to a valid request within 21 days, or notify you of any extension permitted under the PDPA.

Cookies and similar technologies

The Sites use cookies and similar technologies for:

•    Strictly necessary functions (security, load balancing, form submission);

•    Analytics, to understand how visitors use the Sites and improve them [e.g. Google Analytics — specify]; and

•    Preferences, to remember settings you have chosen.

You can control cookies through your browser settings. Disabling cookies may affect the functionality of parts of the Sites. [If any advertising, remarketing or social-media pixels are deployed, they must be listed here and a consent banner implemented.]

Security

We implement reasonable technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure, alteration or destruction, including access controls, encryption in transit, and staff confidentiality obligations. No method of transmission over the internet is completely secure and we cannot guarantee absolute security.

In the event of a personal data breach that is likely to cause significant harm, we will notify the Personal Data Protection Commissioner and affected individuals in accordance with the PDPA.

Third-party links

The Sites may contain links to third-party websites, including those of our technology partners. We are not responsible for the privacy practices or content of those sites. This Policy applies only to the Sites.

Changes to this Policy

We may update this Policy from time to time. The updated version will be posted on the Sites with a revised "Last updated" date. Where a change materially affects how we use your personal data, we will take reasonable steps to bring it to your attention.

Language

This Policy is issued in English and Bahasa Malaysia in accordance with section 7(3) of the PDPA. In the event of any inconsistency between the two versions, the [English] version shall prevail.