WEALTHY PENTAGON SDN. BHD. (Company No.: 201501034104 (1159424-W)) (“Company” or “EASECOX”) is a private limited company incorporated under the laws of Malaysia and is authorised and licensed by the Easecox International Group to represent its business and brand presence in Malaysia, under the trade name of “EASECOX” or such other trade names as may be determined by the Company from time to time.
Any reference to “Company”, “EASECOX” “we”, “us” or “our” shall be a reference to the Company, our shareholders, directors, employees, managers, beauty designers, fitting designers, Distributors, representatives, agents, partners, Authorised Parties and/or our data processors and any of our group of companies including our respective subsidiaries, affiliates, associates and other related companies which EASECOX has direct or indirect interest in (as applicable). Any reference to “you” and “your” in this Privacy Policy refers to the Data Subject (as applicable). If you are an entity, references to “you” and “your” shall also include your shareholders, directors, employees, managers, officers, representatives, agents and partners, respectively.
We take seriously the importance of protecting your Personal Data and our team is at all times committed to ensure compliance with all relevant laws as well as this Privacy Policy.
This Privacy Policy serves as a notice pursuant to the Act (as defined below) in respect of and during the course of our Engagement and this Privacy Policy is applicable to the Data Subject. It explains the manner in which the Company records, stores, processes, discloses, transfers and otherwise uses Personal Data collected during the course of our Engagement as well as the rights available to you as a Data Subject, on the handling of Personal Data.
By entering into an Engagement with us and providing us with your Personal Data, it is deemed that you have read and understood this Privacy Policy and have agreed to our processing of your Personal Data in accordance with this Privacy Policy.
GLOSSARY
· Account(s) : means the Distributors' account or EA account registered with EASECOX via the Sites or any other applicable manner with regard to the purchase of and/or enquiry into our products and/or the Engagement.
· Act : means the Personal Data Protection Act, 2010, the applicable regulations, guidelines, orders and any statutory amendments/updates or re-enactments made pursuant thereto.
· Authorised Parties : means 3rd party data processors, retailers, authorised agents, entities, service providers, parties and/or online platforms which EASECOX formally and/or officially authorises to represent EASECOX, assist with processing of the Personal Data and/or make available and sell its products and/or execute any other forms of engagements related to EASECOX.
· Data Subject : refers to any party who is the subject of the Personal Data which shall include but is not limited to our Distributors, EAs, visitors to our Sites, any entities/individuals that get into
Engagements with us, business partners, service providers, agents, Authorised Parties and/or other stakeholders (as applicable).
· Distributors : refers to individuals and/or entities that subscribe to EASECOX's business plan in line with the business guidelines of EASECOX and/or any other official documents (as applicable).
· EA : refers to the individuals and/or entities who purchase our products without subscribing to our business plan.
· Engagement : means any type and/or category of engagement, dealings and/or transactions which the Company enters into and/or is involved in with the Data Subject, including but not limited to any commercial transactions in connection with the products, registrations of Accounts, the Company’s business, any correspondences and/or communication established with the Company (physically, via its Sites and/or any other mode of communication).
· Personal Data : means any information collected by EASECOX, which relates directly or indirectly to a Data Subject that is identified or identifiable from that information. The scope of Personal Data for purposes of this Privacy Policy is at all times in line with the definition of "Personal Data" in the Act.
· Privacy Policy : means this privacy policy including any revision(s) thereof subject to the terms hereunder.
· Sites : means the Website, the Account, mobile applications, official social media pages, authorised third party platforms (if any) and/or any such platform which EASECOX may include as its authorised Engagement mode with the Data Subjects.
·Website : refers to the official website of EASECOX at www.easecoxgroup.com.
COLLECTION OF YOUR PERSONAL DATA
Please note that we may collect yourPersonal Data from time to time in the course of our Engagement to accordinglycarry out and fulfil our Engagement.
Where appropriate, the type of PersonalData which we may collect during our Engagement includes (but is not limitedto) your:
(a) full name (legal or otherwise);
(b) national registration identity card(NRIC) number or passport number;
(c) contact number, email address, gender,age, occupation, date of birth;
(d) address (including correspondenceaddress, billing address and delivery address);
(e) credit card details or details of otherpayment method(s);
(f) bank account details (including name ofbank and bank account number);
(g) password and username created for yourAccount;
(h) health or skin condition, religiousbeliefs, other biometric data; and/or
(i) any such information as our team mayrequire from you and/or you may provide to us from time to time pursuant to andin the course of our Engagement.
You are responsible for the accuracy andcompleteness of all Personal Data provided to us (which accuracy we haveassumed), and none of such Personal Data shall be misleading, inaccurateor outdated. Should there be any changes/updates to your Personal Data,you shall promptly update us in writing in the manner indicated in this PrivacyPolicy.
In the casewhere Personal Data of another data subject is provided by you (e.g. PersonalData related to your family members, child, spouse or other dependent foremergency contact or other required purposes), you confirm that you haveexplained to them the processing of their Personal Data in accordance with thisPrivacy Policy and you warrant the accuracy and completeness of theirPersonal Data.
MANNER OF COLLECTION OF YOUR PERSONAL DATA
Your Personal Data may be collected by us at any point in the course of Engagement which include the following events:
(a) as a Distributor and/or EA, when you enter into an Engagement via our Sites (including but not limited to the act of creating an Account, placing an order for the products, signing up for the business plan (for Distributors), enquiring about the products and/or interacting with our team);
(b) as a Distributor and/or EA, when you enter into an Engagement in person, whether at physical stores or outlets connected to us and/or our Authorised Parties, any of our participating or organised events and/or activities (including but not limited to trade fairs, exhibitions, conferences, pop-up stores, workshops and/or talks);
(c) as an Authorised Party, when you enter into an Engagement physically or virtually, in the course of carrying out and completing a commercial arrangement and/or contractual obligation between the Authorised Parties and the Company;
(d) as a Data Subject, during any other forms of Engagement with the Company in connection with our business (including but not limited to establishment of contractual relationships, establishment of partnerships, engagement of services and/or the overall operation of our business);
(e) as a Data Subject, when you visit any of our Sites, via cookies, web beacons and/or other similar technologies which we utilise to provide you with a better service, assist with our analytics for our business/Sites and/or to increase the general efficacy of our operations. Upon your visit to our Sites, our servers and/or equivalent technological equipment may record your Personal Data (which includes browser type, other visited webpages and/or any other related information); and
(f) upon our access to your Personal Data via any publicly available resources or through third parties like your referrers/sponsors.
The collection, recording, storage, disclosure, transfer, transmission or utilisation of the Personal Data shall constitute an act of us “processing” your Personal Data.
Please take note that if you visit our Sites as a guest without signing up for an Account and/or entering into an Engagement, we may obtain and retain your Personal Data in a limited manner for promotional and marketing purposes.
PROCESSING YOUR PERSONAL DATA
EASECOX may process and/or use your Personal Data for the following acts, subject to the laws of the relevant jurisdictions:
(a) registration, opening, maintenance and administration of an Account and/or signing you up for the business plan (for Distributors) as well as to calculate your rewards, incentives and/or other membership benefits (as applicable);
(b) internal operation and administration, including data analysis, market research, consumer analysis, products demand analysis and other related commercial assessment (including sharing of your Personal Data to profiling companies, marketing agents and/or other related third parties for such purpose);
(c) in any way, processing, facilitating, dealing with, arranging, administering and/or managing our Engagement with you;
(d) processing orders of any products and/or sharing any of your Personal Data to a third party for the delivery of such products (including but not limited to our payment service providers and/or logistics service providers);
(e) processing your payment and/or any refund (only to the extent permissible by our management) as well as meeting billing requirements and/or sale and service charges;
(f) responding, addressing or attending to your queries and/or requests and to take actions in relation thereto;
(g) verifying the authenticity of your identity with a third party data holder or authorised verification body;
(h) for marketing, advertising purposes, providing any updates, promotions, activities or information related to EASECOX either by itself or through any of our appointed third party agencies, by way of text messages, phone calls, electronic mails, social media announcement and/or any other appropriate channels of communication (subject to your consent);
(i) complying with any requirements or obligations of the laws of the relevant jurisdictions;
(j) adhering to any rulings, guidelines and orders imposed by any regulatory body of the relevant jurisdictions;
(k) to seek legal and/or financial advice (including for purposes of preparing related documentation);
(l) sharing any of your Personal Data with a third party business partner or service provider (such as the Authorised Parties) for purposes of a potential joint collaboration of services and/or any other commercial transactions;
(m) sharing any of your Personal Data with a third party such as an event company or outsourcing company for administration, marketing or promotional purposes;
(n) sharing any of your Personal Data with our accountants or auditors for our internal audit and reporting purposes;
(o) detect, investigate and/or prevent any fraudulent or illegal activity, omission or conduct;
(p) to upgrade, improve or revamp our Sites;
(q) for our storage, hosting back-up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside of Malaysia; and/or
(r) any other purposes as we may deem fit for purposes of your Engagement with EASECOX.
DISCLOSURE AND TRANSFER OF PERSONAL DATA
Subject to the laws of the relevant jurisdictions, the Company may disclose your Personal Data to the following persons under any of the circumstances set out below:
(a) our shareholders, directors, employees, consultants, staff, subsidiary companies (local or foreign), related entities (local or foreign), independent contractors, service providers, Authorised Parties, business associates, agents and any other party who assists the Company in the processing of the Personal Data and the management of the operation and maintenance, in support of our business;
(b) our subsidiaries, affiliates, associates and other related companies which EASECOX has direct or indirect interest in as deemed necessary by EASECOX for the purposes of our business;
(c) 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;
(d) 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;
(e) 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;
(f) any third party data processor or authorised verification body;
(g) data centres and/or servers, storage facilities and/or records managements companies located within or outside of Malaysia for purpose of storing your Personal Data;
(h) government agencies, law enforcement agents, courts, tribunals, regulatory / professional bodies, if required to do so in satisfaction of any applicable law, regulation, order or judgment; and/or
(i) any other person which requires your Personal Data in order to operate and maintain our business and to carry out and complete the Engagement.
Given the cross-border nature of EASECOX’s business, please take note that we may disclose your Personal Data (locally and internationally), during the ordinary course of our business and/or for purposes of the Engagement, to the entities within the Easecox International Group including its parent company, subsidiaries, affiliates, associates and/or related companies (including the Distributors thereunder). By acceptance of this Privacy Policy, you are deemed to consent to such cross-border transfer of your Personal Data and EASECOX will take all reasonable steps to ensure that the foreign recipients of your Personal Data provide a level of personal data protection in line with the standards under the Act.
We will take reasonable measures and exercise due diligence to procure compliance with this Privacy Policy by any foreign entities handling your Personal Data to adequately protect the confidentiality and privacy of your Personal 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 Personal Data to any third party without your consent.
RETENTION AND DESTRUCTION OF YOUR PERSONAL DATA
We will retain your Personal Data for as long as any of the purpose indicated in this Privacy Policy subsists notwithstanding the cessation of your Engagement with us or the termination of your Account with us. Thereafter, we will delete from or keep anonymous your Personal 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 Personal Data that is beyond our reasonable control.
SECURITY OF PERSONAL DATA
In order to ensure that adequate protection and measures are in place to protect your Personal Data, we will use our reasonable endeavours 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 Personal Data.
Against compliance with the Act, 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 Personal Data by restricting the access of any unidentified or unauthorised third parties to your Personal Data. We may from time to time implement and improve our technical, electronic and procedural security measures to safeguard your Personal Data.
Our Sites 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.
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Last Updated: 20 July 2025
