2. Scope & Legal Basis
This Policy covers personal data processed by NielTan.com as the primary website and data controller. We also work with service providers and partners including ClickBinar Solutions and 101Next, who may process data on our behalf or jointly with us to provide membership and community services. We process personal data where we have one or more of the following legal bases: your consent; to perform a contract with you; to comply with a legal obligation; and for our legitimate interests where those interests do not override your rights. If you are an EU resident, the legal bases and your rights under the GDPR will apply in addition to the PDPA as relevant.
3. What personal data we collect
We collect the following categories of personal data as necessary for the stated purposes below:
4. How we collect personal data
We collect personal data:
5. How we use personal data (purposes)
We use personal data to:
6. Sharing personal data & third parties
We may share personal data with:
All third parties are bound by contractual safeguards requiring them to protect your data and only process it for specified purposes. If we ever sell or transfer all or part of the Site or business, personal information may be transferred to a buyer; we will notify you of any material changes.
7. International transfers
Your personal data may be stored or processed in Malaysia and in other jurisdictions where our service providers operate. Transfers outside Malaysia will be conducted in compliance with PDPA Section 129 and applicable guidance: we rely on appropriate safeguards (contracts, adequacy, or other lawful mechanisms) and will document these transfers. If you are an EU resident, cross-border transfers will likewise follow GDPR safeguards (adequacy, Standard Contractual Clauses, or approved mechanisms). (See our Data Transfers Register on request.)
8. Cookies, beacons, tags & pixels
We use cookies and similar technologies to provide core functionality (session, login), to analyze site usage, and to deliver optional marketing and social features. You can manage cookie preferences via the cookie banner on the Site; essential cookies are required for the Site to function.
9. Security
We implement reasonable technical and organizational measures to protect personal data (encryption at rest/in transit where feasible, access controls, secure backups, vulnerability management, and staff access audits). No system is perfect — if a personal data breach occurs we will act promptly to contain and remediate the incident.
10. Data breach notification
We maintain an incident response plan. Where a breach is “notifiable” under the PDPA and related guidance, we will notify the Personal Data Protection Commissioner (PDPC/JPDP) within the timescales required by law and notify affected individuals where the breach is likely to result in significant harm. We will also work with ClickBinar and relevant partners to investigate and remediate breaches.
11. Retention
We retain personal data only as long as necessary for the purpose collected or to meet legal or regulatory obligations. Typical retention examples (subject to change): account data — for the duration of active membership plus up to 7 years; transactional records — up to 7 years for tax/compliance; marketing lists — until consent withdrawn. We securely delete or anonymize personal data when it is no longer required.
12. Your rights
You have rights under applicable law, which may include: access, correction, erasure, restriction of processing, objection to processing (including direct marketing), portability, and withdrawal of consent. To exercise those rights, contact us at privacy@nieltan.com and include sufficient information to identify you and the request. We will acknowledge receipt and respond within a reasonable time (our target: acknowledgement within 7 business days; completion within 30 calendar days unless complexity justifies a reasonable extension).
13. Age restrictions
Our services are not intended for individuals under 18 years old. We do not knowingly collect personal data from children; if we learn that we have collected personal data from a child without verifiable parental consent, we will delete it.
14. WordPress, plugins & third-party platforms
The Site runs on WordPress and uses third-party plugins and services (analytics, email delivery, social logins). These parties may collect and process data independently according to their own policies. We recommend reviewing each provider’s privacy policy where you interact with their services.
15. User content & community (101Next)
Content you post to the community or membership areas may be visible to other members and processed by 101Next to provide community features. Do not post sensitive personal data to public community spaces. For membership data, 101Next may require certain fields to create your account — we will highlight required vs optional fields during signup.
16. Changes to this Privacy Policy
We may update this Policy from time to time. Material changes will be posted with a prominent notice on the Site and the updated effective date. Please check back regularly.
17. Contact & complaints
For any questions, requests, or complaints: privacy@nieltan.com or the registered address for ClickBinar Solutions above.
18. Legal disclaimer
This Privacy Policy is a statement of our current privacy practices and does not create contractual rights beyond applicable law. For legal advice tailored to your operations, consult a qualified privacy lawyer.
This Privacy Policy outlines how and why we collect, use, and process the personal data of our users and visitors. It also explains the options available to you regarding how we use your personal data, and how to contact us with questions or concerns.
If you have any questions, comments, or concerns regarding this Privacy Policy, please reach out to us via the contact information provided in the “Further Questions and Contacts” section below.
Below you will find information about the following:
1. Collection of Information.
2. How we utilize information.
3. Purpose of data processing
4. Cookies, beacons, tags, pixels.
5. How we share your personal information and who we share it with.
6. International Transfers.
7. Security measures.
8. Retention periods.
9. Age Restrictions
10.Changes to the Privacy Policy.
11. Consent
12. WordPress.Org
13. Personal Data Protect Act 2010.
> User Content
14. Collection of Information
> Personal Information That You Provide
> Personal Information From Other Sources
– E-Mail Address
– Information Collected Via Technology
15. Use and Disclosure of Information
> Information Collected Via Technology
> Security
> Third Party Websites
16. Further questions and contacts.
What do we do with your information?
When you access and browse the Site (including when you submit personal information to us through data entry fields on the website) we will collect the following from you:
Information you provide:
Contact information – we receive and store any information you enter on our Site. Our Site uses forms to collect your personal information including your name, address, telephone number, email address so you can place orders, request information, get support and use our services.
Payments and billing information – when signing up for any of our services, products, or programs, we request additional personal and payment information such as your name, credit card information, PayPal or relevant service, billing address, personal, government or TAX identification number or other information including but not limited to certificates, tax declarations, forms, payment documents and other relevant documents.
Surveys and contests – we may, from time to time, offer surveys and opinion polls and ask you to provide information about your experience and feedback for our services. Occasionally we may organize contests, sweepstakes, competitions, prize draws, or other promotions (collectively “Contests”) on our Site or through our Social Media channels and may offer a prize as a sign of appreciation to the people who have participated, qualified and/or completed our Contest. Information requested for entry may include personal contact information such as your name, email, address, phone number, etc. Participation is entirely voluntary and it’s up to you whether you choose to disclose any information or not.
Information we receive from your use of our services or third-parties
Automated information – when you visit our website we receive and collect information, which may in certain circumstances constitute personal information and which includes your IP address, referral URL, exit URL, browser software, operating system, date/time and/or clickstream data.
Website Analytics tools – We use analytics services by third parties to collect information about the use of this Site, such as number of visits, pages visited, popularity of certain content. Analytics tools use tracking technologies (like cookies) to recognize your device and compile information about you. They collect information such as what pages you visit and how much time you spend on these pages, the IP address assigned to you, what operating system and web browser you use, and what site you visited prior to visiting our website.
Information Logs – when you visit the Site, view content provided by us, use our services, use our Chat service, ask us a question, request technical assistance in regards to our services, send us an email or participate in a contest or survey on our website, we automatically collect and store certain information in log files. This includes your IP address, URL, referral URL, exit URL, browser software, operating system, date/time, requests type to our Site and error responses returned by our Site or Services.
Other information – we also receive and store any information that you provide on our Site, our Chat service, any forms on our site, email, telephone, or any other type of communication with our team or related to the provisioning of our services. Whenever you contact us, we will record the ticket, chat or call to ensure we have an accurate record of all communication, which is needed to provide our services and to support any action taken by our team as a result in the event of a dispute over our response.
When you access or use our Services, we need to collect, use, and otherwise process your information, as set out in this Policy. We are committed to your privacy and follow a few fundamental principles when we process personal data:
We strive to collect only the minimum personal data that we need to deliver any Services to you.
We aim for full transparency on how we use your information to comply with legal or other lawful purposes and respect your privacy.
We make sure we only use your information for the purposes you have given us permission for.
We rely on a number of legal bases to use your information, as set out in this Policy:
Contract – the use of your information is necessary to perform any contractual obligations in order to provide any Services to you or to administer any Contests you enter into;
Legal obligations – our use of your personal information is necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims. For example, if we are requested to disclose your personal information to regulatory bodies or law enforcement authorities; or to use your personal information for tax calculations.
Our legitimate interests – necessary for the purposes of our legitimate interests, such as to:
Consent – we rely on your consent for us to use your personal information to send you marketing information (such as our newsletters and promotional offers) by email, SMS, or telephone. You may withdraw your consent at any time by updating your personal Info/Settings in your user profile in our User Area, using our Unsubscribe option in relation to email subscriptions, or contacting us using the details set out in the “Further questions and contacts” section of this Policy.
We use Cookies to collect some of the information set out in this Policy. A cookie is a small piece of data sent from a website and stored in your web browser on your computer, mobile or other handheld device, while you are browsing a website.
Our Site uses cookies to identify you. Cookies can store your account identifier, ordering status, personalisation or website tracking. They can also be used for technical purposes such as keeping track of your current shopping session and enabling you to proceed to checkout and pay for your according order or to save information which has already been entered (languages choices, and your region), so that we can offer improved and more personalised services, products and other relevant communication tailored to you. Cookies also allow us to fulfil our contractual obligations to third parties and partners if you have made a purchase on our website by following a link from theirs.
Our Site includes marketing cookies and remarketing pixel provided by third parties. That allows these parties to collect the information that you have visited our Site and were interested in certain offers. We also use beacons, tags, click tracking codes and scripts to analyze trends and movements of users around the Site, gather information about user base as a whole and how we can improve our service and Site, to provide advertising based upon activities and interests and to measure advertising effectiveness. As a result we may display targeted, or interest-based, offers to you based on the products you currently own or have recently viewed and deliver other communication more relevant to you and your interests outside of our Site, on other websites part of the third party’s network.
You can manage your preferences regarding Cookies either by modifying your browser settings or using the designated pop-up tool on our website. In the ‘Cookie Settings’ pop-up on our Site you will find a list of all cookies within each category (required, statistics, marketing), or a list of vendors serving cookies and similar technologies and will be able to choose which types of cookies you would like our Site to use, if any.
You can also modify your Cookie preferences straight from your browser. Please note that if you simply disable all of our cookies or cookies in general in your browser settings, you may find that certain sections or features of our Site will not work, because your browser may prevent us from setting Site functionally required cookies.
You can find more detailed information about our use of cookies in our Cookies Policy.
All personal information collected by NielTan.com under Click Binar Solutions is treated as confidential. We disclose entire or part of your data in the limited circumstances described below and with appropriate safeguards on your privacy:
If we are required by law – we will disclose information about you in response to a subpoena, court order, or other legitimate governmental request.
Our ClickBinar group companies, Subsidiaries, employees, and independent contractors – we will disclose information about you to our ClickBinar group companies, subsidiaries, business partners, external consultants, auditors, collaborators or other third parties, some of our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our services or to process the information on our behalf and also for administrative purposes, billing and tax and all other purposes related to the management of your account. We require all of them to comply strictly with this Privacy Policy.
Third Party Vendors – we will share information with third party vendors based within the European Union, United States and Malaysia, Data Center services providers based within the European Union, United States, Singapore and Malaysia, external advisors/consultants, business partners, tax, accounting and legal companies, collaborators based within the European Union, United States and Malaysia, who need to know information about you in order to provide various services on our behalf. This group includes vendors that help us provide our services such as payment providers that process your credit card information or information about alternative payment methods and invoicing, and accounting companies as well as vendors that help us prevent fraud. This group also includes trusted vendors we partner with that perform analysis of our products or customer demographics and do market research that help us understand and enhance our services and help us serve better advertisements. This group also includes third party providers that perform analytic services and analyse the data of our surveys and/or contests. We will only share information about you that is necessary for the third party vendor to provide the requested service. These companies will process the provided data under instructions of and in compliance with this Privacy Policy. We do not authorize vendors to retain, share, store or use your personally identifiable information for any secondary purposes. The third party vendors include companies that operate in different industries such as Fraud Detection, Technology Service, Internet Information Providers, Payments and Data Processors, Specialty Finance, Media, Internet Content & Information Industries, Advertising & Marketing and Technologies, that are located in the territory of the European Union, United States and Malaysia.
To Protect Rights and Property – We will share account and personal information with companies, organizations or individuals when we believe in good-faith that access, use, preservation or disclosure of the information is necessary to meet any applicable law, comply with regulation, legal process or enforceable request; to enforce or apply our Terms of Service and other agreements; to investigate potential violations; to protect against harm to the rights, property or safety of ClickBinar, our users or the public as required or permitted by law. To the extent we are legally permitted to do so, we will take all reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.
Domain Registrars – the domain’s owner information (WHOIS Data) for any domain name is required and controlled by the ICANN-accredited registrar provider and the Registry for the top-level domain which you wish or have registered. We share your information to the extent necessary to comply with ICANN’s rules, regulations and policies, with rules and policies by the ICANN-accredited registrar providers we represent and the rules and policies of the top-level domain Registry. These registrar providers are located in Europe, USA, Canada and Malaysia. The information is also shared with the Registry for the top-level domain which may be located in another jurisdiction. The use and disclosure of the personal information as part of the domain registration process is governed by the Domain Name terms in our Terms of Service and the applicable agreements with the ICANN-accredited registrar.
Business Transfers – in connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that ClickBinar goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events happens, we will take any reasonable steps to notify you and this Privacy Policy would continue to apply to your information and the party receiving your information shall continue to use your information, but only consistent with this Privacy Policy.
With Your Consent – with your explicit consent or at your direction we may share and disclose information you have authorized us to with third parties. We will not, however, sell, rent, share or otherwise disclose personally identifiable information for commercial purposes in any way that is contrary to the commitments made in this Privacy Policy. We will take all reasonable steps to notify you when and what information might go to third parties and you will be able to choose whether to share it or not.
We host, store or otherwise handle your personal information within the borders of European Economic Area (EEA), the USA and Malaysia.
We will make sure that any transfers of your personal information from one country to another comply with thе data protection and privacy laws that apply.
European data protection laws, in particular, include specific rules on transferring personal information outside the EEA.
When transferring personal information outside the EEA, the USA and Malaysia, we will include the standard data protection clauses approved by the European Commission under Article 46.2 of the General Data Protection Regulation (GDPR) and Malaysia Personal Data Protection Act (PDPA) into our contract with Malaysia-based under ClickBinar group company or other Partners.
You can find out further information about the rules on data transfers outside the EEA or Malaysia, including the mechanisms that we rely upon, on the European Commission website here and Malaysia here.
In any event, your information will be processed in accordance with this Privacy Policy. If you would like further information about the global handling of your personal information, please contact us using the details set out in the “Further questions or making a complaint” section below.
We use Secure Sockets Layer (SSL) software to encrypt the information you enter on our Site in order to protect its security during transmission to and from our Site. When storing information, we protect its security by encryption and pseudonymization of critical data. When we process credit card information and payments, the credit card is subject to tokenization and strong security measures.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures require us in some cases to request proof of identity before disclosing personal information to you.
To protect against unauthorised access to your account and information, we implement session management, login expiration mechanisms and the option of using 2-factor authentication for User Area access. As an additional safety measure, be sure to sign off when you finish using your account and your computer.
Although we take all these measures to maintain the safety and security of your personal information, please note that no transmission over the Internet can ever be guaranteed to be secure. Consequently, please note that we cannot fully guarantee the security of any personal information that you transfer over the Internet to us.
Information collected on our website will only be retained for as long as necessary to fulfill the purpose for which it was collected. In general, we will automatically delete your information 2 years after you no longer have any active services with us. Since we offer a service for customers worldwide and we need to comply with regulations across the globe in regard to retention of personal information related to contractual agreements, provision of services, financial, billing, invoicing operations and tax calculations, a versioned copy of your contact, payment and billing personal data associated with your past invoices is stored for a period of 10 years after deactivating an account. Your personal data is deleted automatically by our systems in accordance with these retention periods .
In accordance with ClickBinar Terms of Service, we do not sell products, provide services or collect information from any individual under the age of 13. If you are under the age of 13, you are not allowed to use the Site and you must request your parent or guardian to use the Site instead. Should you have an evidence that someone under the age of 13 has bought services and provided their personal information to us, please contact us using the details set out in the “Further questions and contacts” section below.
We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post the updates to this Privacy Policy here and on any other place we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
If we make material changes to this Policy, we will notify you here, by email, or by means of a notice via our Site, at least ten (10) calendar days before the changes take effect.
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only. If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no. How do I withdraw my consent? If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at legal@ClickBinar.com or WhatsApp us at: +6 016 454 4536.
Our store is hosted on WordPress.org. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through WordPress’s data storage, databases and the general WordPress application. They store your data on a secure server behind a firewall. We have Secure Sockets Layer (SSL) to increase the security of the website. This SSL certificate is also compulsory for all major search engines such as Google, Bing, Yahoo, YouTube, Facebook and other online platforms that comes with search engine feature(s).
By accessing or otherwise providing your personal information to us, you agree to the terms and conditions of ClickBinar’s Privacy Policy, which is incorporated into and forms a part of our terms of service You expressly consent to the processing of your Personal Information according to this Privacy Policy.
Your Personal Information will be processed and stored in Malaysia governed by the Personal Data Protection Act 2010 or PDPA. Your Personal Information will not be used or disclosed for purposes for which you have not given consent or which are not permitted under applicable law.
In general, we are collecting Personal Information that you submit to us voluntarily. We also are collecting information that you submit in the process of communicating, creating or editing your account and user profile in relation with our nature of business on website, mobile application, software, eCommerce and all other digital technology related.
We may receive Personal Information about you from other sources to which you have expressly consented to.
E-Mail Address
If you send an e-mail to us, or fill in either form via feedback, landing page opt-in, payment gateway or other forms, we will collect your name, e-mail address, mobile number or other information deemed necessary and other information you provide.
Information Collected Via technology
As you use our services, certain information may also be passively collected and stored on our or our service providers’ server logs, including your Internet protocol address, browser type, and operating system.
Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent, or otherwise share for marketing purposes the Personal Information that we collect from third parties, unless you or authorize us to do so.
Personal Information collected is to provide you access, to process engagement services, to improve, better tailor the features, performance, and support of our business dealing in website, mobile application, software, eCommerce and all other digital technology related and to offer you additional information, opportunities, promotions and functionality from us.
We may share some or all of your Personal Information with our affiliated and group companies that are under a common control, so that they may send daily deal e-mails to you as consented newsletters, in which case we will require them to honour this Privacy Policy.
We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to:
a) comply with relevant laws or to respond to subpoenas or warrants served on us; or
b) to protect and defend our rights or property, you, or third parties.
Please note that your personal information may be transferred, stored and processed outside Malaysia in secured cloud servers.
We will do our best to protect your personal data, we cannot however guarantee the security of your data transmitted to our site; any transmission is at your own risk and you agree not to hold us responsible for any breach of security while accessing the internet that is out of our control. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our website may contain links to other sites (the “Linked Sites”). We are not responsible for the privacy policies or practices of such other Linked Sites. You agree to waive any claim against us with respect to the Linked Sites.
If you have any questions regarding this Privacy Policy, if you wish to exercise any of your rights in relation to your personal information, or if you want to object to the collection or processing of your data by ClickBinar, whether entirely or partially, please contact us at legal@ClickBinar.com or our Data Protection Officer who can be reached at privacy@ClickBinar.com.
Additionally, this Privacy Policy is subject to occasional revision at our discretion. If you object to any such changes, you must cease using our platform and any further use shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.