Introduction.

XQST LUXURY SDN. BHD. (previously known as Phoenix Placement Agency Sdn Bhd) is primarily in the business of trading and rental of luxury fashion goods on the Platforms. Given the nature of our business, we appreciate the importance of data protection and our team is at all times committed to ensure compliance with all relevant laws as well as this privacy policy ("Privacy Policy").

This Privacy Policy serves as a notice pursuant to the Personal Data Protection Act, 2010 ("PDPA") in respect of and during your use of any of the services on the platforms made available by the Company. It explains the manner in which Company records, stores, processes, discloses, transfers and otherwise uses Data collected during the course of us serving you as well as the rights available to you as a data subject, on the handling of Data.

Interpretation.

Any reference to "XQST", "we", "us" or "our" shall be a reference to the XQST Luxury Sdn Bhd (“Company”). If you are a corporate entity/partnership/organisation, references to "you" and "your" shall also include your shareholders, directors, employees, managers, officers, representatives, agents and partners, respectively.

By reference to "Services", it means the leasing service rendered by XQST to you for the renting of luxury fashion goods and all ancillary services related to such leasing / renting.

"Data" for purposes of this Privacy Policy means any information collected by XQST and it relates directly or indirectly to a data subject that is identified or identifiable from that information. By using the Services and providing us your Data, it is deemed that you have read and understood this Privacy Policy and have agreed to our processing of your Data in accordance with this Privacy Policy.

Data XQST collects.

Personal data that XQST may collect from you at any time throughout your use of our Services includes:

  1. full name (as per NRIC / Passport);
  2. NRIC number or passport number;
  3. date of birth;
  4. gender;
  5. correspondence address;
  6. occupation;
  7. contact number and email address;
  8. debit card details or credit card details or details of other payment method(s);
  9. bank account details (including name of bank and bank account number);
  10. password and user name created for your account in respect of the use of the Services; and
  11. any such information as our team may require to serve you better.

You are responsible for the accuracy and completeness of all Data provided by you to us (for which we have assumed), and that none of such Data is misleading or out of date. Should there be any changes/updates to your Data, you will promptly update us in writing to our customer support team at [email protected]

In the case where Data of another data subject is provided by you (e.g. Data related to your family members, child, spouse or other dependent for emergency contact purposes), you confirm that you have explained or will explain to them the processing of their Data in accordance with this Privacy Policy and you represent and warrant the accuracy, truthfulness and completeness of their Data.

XQST collects data from our Platforms.

Your Data will be collected vide our "Platforms", which refers to (i) our website, www.xqst.co and such mobile version of the same operated and maintained by the Company (if any); and (ii) any social media messaging platform(s) where you interact with member(s) of our team. By collecting, recording, storing, disclosing, transferring, transmitting or otherwise using the Data constitute an act of us "processing" your Data.

Please take note that if you visit our Platforms as a guest without subscribing to the use of the Services, we may obtain and retain your Data in a limited manner for promotional and marketing purposes.

If you do not want to provide us your Data.

During the course of us servicing you, it may be obligatory or voluntary for you to provide and for us to collect and process your Data. If mandatory and if you fail or refuse to provide and/or do not provide on the basis of not willing to consent to this Privacy Policy, we may not or will not (as the case may be) be able to serve you.

Purpose and method XQST process your Data.

The purpose for which XQST may use your Data include amongst others the following and such purposes may be carried out by any means or methods as XQST deems fit, subject to the laws of the relevant jurisdictions:

  1. for the registration and opening of a customer account with XQST for purpose of the Services;
  2. for the use and access to XQST’s Platforms and internal operation and administration including data analysis, market research and consumer analysis and assessment;
  3. facilitating, dealing with, arranging, administering, managing our Services to you;
  4. processing your payment or where appropriate at the discretion of our management, any refund process;
  5. responding, addressing or attending to your queries and/or requests and to take actions related to such queries and/or requests;
  6. verifying the authenticity of your identity with a third party data holder or authorised verification body;
  7. as applicable, meeting any service charges requirements;
  8. as applicable, for marketing and advertising purposes and to send to you all the marketing and promotional materials in relation to the Services (subject to your consent);
  9. complying to any requirements or obligations of the laws of the relevant jurisdictions;
  10. adhering to any rulings, guidelines and orders imposed by any regulatory body;
  11. subject to your consent given at the time of registration or at any time thereafter, provide any updates, promotions, or any activities or information in relation to the Services and/or XQST, or through any of our appointed third party agencies, by way of electronic mails, social media announcement and/or any other appropriate channels of communication;
  12. carrying out any due diligence, background checks, or any other monitoring or scrutinising activities in accordance with relevant legal requirements or for purposes of risk management as may be required by the relevant laws;
  13. analysing customers’ profiling to improve and enhance our level and standard of services to you;
  14. sharing of your Data for purposes of seeking legal and/or financial advice (including for purposes of preparing such legal documentation);
  15. sharing of any of your Data with a third party business partner or service provider for purposes of a potential joint collaboration of services;
  16. sharing of any of your Data with third party such as event company or outsourcing company for administration, marketing or promotional purposes;
  17. sharing of any of your Data to third party for the delivery of such products;
  18. to share any of your Data with the auditor for our internal audit and reporting purposes;
  19. to detect, investigate and prevent any fraudulent or illegal activity, omission or conduct;
  20. to upgrade, improve or revamp our Platforms;
  21. for our storage, hosting back-up (whether for disaster recovery or otherwise) of your Data, whether within or outside of Malaysia; and/or
  22. any other purposes as we may deem fit for purposes of enhancing your experience with XQST.

We will only process your Data in accordance with the PDPA and the applicable regulations, guidelines, orders and any statutory amendments or re-enactments made pursuant thereto as well as this Privacy Policy.

When does XQST disclose and transfer your Data.

Data. Subject to the laws of the relevant jurisdictions, the Company may disclose your Data to the following persons under any of the circumstances set out below:

  1. our shareholders, directors, employees, staff, subsidiary companies (local or foreign), related entities (local or foreign), independent contractors, service providers, business associates, agents and any other agent who assists the Company in processing the Data and manages the operation and maintenance and in support of the Services;
  2. if required to do by operation of law or by regulatory or compliance bodies in order to identify risks or threats relating to fraud, money laundering, terrorism financing and/or any other illegal or criminal activities;
  3. auditors, accountants and/or solicitors in the preparation of documents of the Company for statutory filing purposes or any other document required to be submitted to adhere to the statutory or regulatory compliance owed by the Company to governmental authorities or compliance bodies;
  4. to the extent permitted by any relevant laws, any third parties (including financial advisers / legal advisers / professional advisers) carrying out due diligence review in connection with any proposed merger, acquisition, sale, reorganisation, joint venture or any other corporate activity related to the Company or any of its subsidiaries, related or associated companies;
  5. any third party data processor or authorised verification body;
  6. data centres and/or servers, storage facilities and/or records managements companies located within or outside of Malaysia for purpose of storing your Data;
  7. government agencies, law enforcement agents, courts, tribunals, regulatory / professional bodies, if required to do so in satisfaction of any applicable law, regulation, order or judgement; and/or
  8. any other person which requires your Data in order to operate and maintain the Services.

We will take reasonable measures to procure compliance to this Privacy Policy by any foreign entities handling your Data to adequately protect the confidentiality and privacy of your Data. Except as indicated in this Privacy Policy, it is our strict policy that we must not sell, rent, transfer or disclose any of your Data to any third party without your consent.

XQST retains and destruct your Data.

We will retain your Data for as long as any of the purpose indicated in this Privacy Policy subsists notwithstanding the cessation of your use of our Services or the termination of your account with us. Thereafter, we will delete from or keep anonymous your Data in our records and system unless otherwise required to be retained for legal, regulatory, tax or accounting requirements.

Notwithstanding the representations made in this Privacy Policy, you acknowledge that transmissions over the internet (e.g. emails/webmails/data transmission) are not secured unless they have been encrypted. As internet communications may be routed through different countries before being delivered, we cannot guarantee a risk-free transmission and do not accept responsibility for any unauthorised access or interception or loss of Data that is beyond our reasonable control.

How we secure your Data.

In order to ensure adequate protection and measures are in place to protect your Data, we will use our reasonable endeavour to utilise appropriate software, hardware, programming systems and/or servers and other information technology equipment which we deem suitable and fit for the purpose of storing and securing your Data.

Against compliance with the PDPA, we endeavour to take reasonable and practical measures to mitigate and reduce the risks of unauthorised exposure, destruction, accidental loss, damage and alteration, to your Data by restricting the access of any unidentified or unauthorised third parties to your Data. We may from time to time implement and improve our technical, electronic and procedural security measures to safeguard your Data.

Our Platforms may contain links to external websites. The Company is not responsible for the veracity of such websites and does not substantiate or endorse the content, information, services or any other details contained or featured on such external websites. You are advised to read the terms of use and/or privacy policy of such third party website(s) before accessing or using these websites.

When you want to access to your Data kept with us.

To the extent permitted under the PDPA and applicable laws, you have the right to request for access to or request for a copy of, your Data for purposes of checking, correcting or updating such Data.

Access to your data or correction of such data can be effected and processed (i) vide interactive communication channel available on our Platforms; (ii) electronic mail to [email protected]; (iii) by contacting our customer support team at +6012 968 9728.

Upon receipt of a request for correction of Data from you, we reserve the right to reject and demand that you resubmit your request if such correction cannot be effected due to insufficient information or such correction cannot be verified against the documents requested (as the case may be).

Please be informed that, subject to any legal restrictions and/or contractual conditions, you have the right to withdraw your consent to our processing of your Data with reasonable notice by sending an email to us at our contact details below, indicating your intention to withdraw your consent. Please however note that, upon such withdrawal of your consent, we might not be able to continue to serve you and we will construe the withdrawal of consent as your intention to discontinue our Services. We will thereafter close your account with XQST accordingly.

We keep our Privacy Policy up-to-date.

We have the absolute right to modify, vary, update and/or amend all or any part of this Privacy Policy at any time from time to time with reasonable notice to you by publishing an updated version of this Privacy Policy on our website. Without prejudice to the law, by continuing use of the Services and/or communication with us, you shall be deemed to have agreed and accepted our modified, varied, updated and/or amended Privacy Policy.

This Privacy Policy is prepared and issued in both the English and Malay language. In the event of any inconsistency or discrepancy between the versions, the English version shall prevail.

Feel free to talk to us.

If you have any queries or concerns relating to this Privacy Policy or if you wish to have access to or correct your Data or make a complain, you may contact us at:

Address : A1-3A-9, Arcoris Business Suite, Jalan Kiara Mont Kiara, 50480 Kuala Lumpur 
Attention : Personal Data Officer
Contact No : +6012 968 9728
Email Address : [email protected]

Please click here for Malay version