i-Neighbour's mission is to build smart communities with the use of recent technologies starting at the home ground and abroad. Central to this mission is the company's commitment to be transparent with you about the personal data that we collect and how it is used and shared.

This Privacy Policy describes how TimeTec Cloud Sdn. Bhd. ("TimeTec"), which operates i-Neighbour and related sites, collect, store and handle personal information of individuals in accordance with the Personal Data Protection Act 2010 (“PDPA”) and the laws of Malaysia. Our processing and use of personal data is also designed to comply with the EU General Data Protection Regulation (GDPR).

Please read this Privacy Policy to understand how we use the personal information we may collect from you.

By using our Services, you consent to our use of your data under this Privacy Policy, including our Cookies Policy.



Introduction
i-Neighbour is a cloud-based residential & visitor management system, catering to various users in a community, such as property developer, joint management body/committee, security personnel, residents and visitors.

Besides that, we have other i-Neighbour related sites and apps ("Other TimeTec applications"), involved in the provision of security, IoT, advert and related services for residential and commercial use: timetecsecurity.com, epicamera.com, i-environ.com, i-merchants.com and iadhub.com.

This Privacy Policy applies to i-neighbour.com, i-Neighbour-branded apps, and the abovementioned i-Neighbour-related sites, apps, communications and services (“Services”), including visitors to the websites.



Consent
If you use our Services, you consent to the collection, use and sharing of your personal data under this Privacy Policy (which includes our Cookies Policy and other documents referenced in this Privacy Policy) and agree to the Terms of Service. We provide you choices that allow you to opt-out or control how we use and share your data.

If you use our Services after an update to this Privacy Policy, you consent to the changed document.



Change
We may modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means (e.g. notice posted on our Facebook page along with the updated Privacy Policy), to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account. Your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that you are consenting to the updated Privacy Policy.

In this Privacy Policy you will understand:

•	About Personal Information
•	Who Collects and Processes Data Collected (EU GDPR Information)
•	Information We Collect
•	Ways We Collect Your Personal Information
•	How We Use Your Data
•	Data Disclosure
•	Data Security
•	Data Retention
•	International Transfer of Information Collected
•	Your Rights & Obligations
•	Links to Third Party Websites
•	Protection of Minors
•	How to Contact Us

About Personal Information
Personal information refers to any information which relates directly or indirectly to you. This includes any information that can be used to distinguish, identify or contact you. For the purposes of this Privacy Policy, personal information encompasses sensitive personal information which relates to information relating to your health, political opinions, religious beliefs, etc. For the avoidance of doubt, please note that this Privacy Policy is applicable only if you are a natural person / an individual.



Who Collects and Processes Data Collected (EU GDPR Information)
TimeTec processes Personal Data both as a Controller and as a Processor, as defined in the EU's GDPR.

TimeTec will be the Controller for "Subscriber" data, meaning Personal Data of the individual that registers for our services (i-Neighbour and Other TimeTec applications) and enters into the Service Agreement. For i-Neighbour, this covers both the registration for Community account and for Visitor membership account. In addition, TimeTec also controls Personal Data that we collect from our website and outside of our website through other channels. For instance, this includes when you contact us by telephone, email and chat services, respond to our marketing materials, submit physical forms and etc.

For "User" data that is stored or processed in each Subscriber's account (i-Neighbour and Other TimeTec applications), the respective Subscriber will be the Controller in accordance with GDPR, and TimeTec will be the Processor.

Through TimeTec’s services, each Subscriber have control over the Personal Data that is stored within their account. After Subscribers initiate the services, they may create additional Administrators and Users ("User" data). Take i-Neighbour as example, the users will comprise of Security personnel and Residents. In turn, those users will also add Visitor information (also "User" data) into the system. Ultimately, the account's Admins hold the rights to add to, modify or delete the User data. Because this data is user generated, it is the Subscriber’s responsibility to ensure that collection and processing of data is done in accordance with applicable law.



Information We Collect
With the purpose of providing you with i-Neighbour and other TimeTec App, Web & Services and to operate in an efficient and effective manner, we need to collect relevant personal information from you. The personal information collected by us may include (but is not limited to) the following:

•	Contact information such as your name, date of birth, identification supporting documents (including NRIC or passport number), gender, nationality and race, preferred language, current private and/or business address, installation address, telephone or mobile phone number, fax number, email address.
•	Your bank account information or credit card details (which we will not have access to as they will be managed by payment providers)
•	The status of i-Neighbour and other TimeTec App, Website & Services you have acquired from us or subscribed to
•	How you use i-Neighbour and other TimeTec App, Website & Services (for example traffic data such as date/time guard button is activated, trusted neighbours, visitors pass, announcement page, e-billing/-payment and other communications made and received by you and the date, duration, time and cost of such communications)
•	For i-Merchants user: Merchant and store information such as your name, business name, business logo and photos, identification supporting documents (including business registration license and number), business address, business telephone or mobile phone number, fax number, email address, website, and business hours.
•	The amount of data that has been received and/or sent by you
•	Information about your computer or device used to access our Services, and about your visits to and use of our websites (including your mobile device, IP address, geographical location, operating system, browser type, number of visits, average time spent on the site and pages viewed). The collected information is used to provide an overview of how people are accessing and using i-Neighbour and other TimeTec websites and not for any additional purpose, such as to profile users
•	We may do this using cookies, web Beacon or similar technologies. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes. To read more about how we use cookies, please read our Cookies Policy.
•	Details of the emails and other electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication. We use this to help ensure our communications are useful for you.

Ways We Collect Your Personal Information
We may collect personal information directly from you when you:

•	Communicate with us such as when you submit an application form to use our websites, applications or services (including free trials), downloading i-Neighbour or TimeTec App or when you contact us for any enquiries, including communication by telephone, email, chat services and social media
•	Purchase a subscription to our services
•	Register or subscribe for our publications such as newsletters, complete any online forms, take part in surveys, post on our blogs, download information such as white papers or other publications or interact with us through our websites
•	Respond to any marketing materials we send out
•	Commence a business relationship with us such as being our service provider/business partner
•	Visit or browse our websites
•	Lodge a complaint with us or provide feedback through websites or other channels
•	Other than personal information obtained from you directly , we may also obtain your personal information from third parties we deal with or are connected with you (credit reference agencies or financial institutions), and from such other sources where you have given your consent for the disclosure of information relating to you, and/or where otherwise lawfully permitted

How We Use Your Data
We may collect and use personal data from you or from the category of third parties identified in this Privacy Policy, for one or more of the following purposes:

•	To verify your identity
•	To assess and process your application(s) /request(s) for i-Neighbour and other TimeTec App, Website & Services
•	To administer and manage i-Neighbour and other TimeTec App, Website & Services we provide you including charging, billing, facilitating payments and collecting debts
•	To assess and/or verify credit worthiness
•	To detect and prevent fraudulent activity
•	To keep in contact with you and provide you with any information you have requested
•	To engage in business transactions in respect of i-Neighbour and other TimeTec App, Website & Services to be offered and provided to you
•	To establish and better manage any business relationship we may have with you
•	To process any communications you send us (for example, answering any queries and dealing with any complaints and feedbacks)
•	To notify you about benefits and changes to the features of i-Neighbour and other TimeTec App, Website & Services
•	To produce data, reports and statistics which shall be anonymised or aggregated in a manner that does not identify you as an individual
•	We may also use personal information for internal purposes such as auditing, data analysis, and research to improve i-Neighbour's products, services, and customer communications
•	To investigate, respond to, or defend claims made against, or involving TimeTec Cloud Sdn. Bhd.
•	To conduct our internal marketing and promotional activities. For example, we may use it to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. You can also unsubscribe from any email marketing using the links provided in the emails we send to you. Please refer to the section below on 'Your Rights' to object to processing for marketing purposes
•	To maintain records required for security, claims or other legal purposes
•	To comply with legal and regulatory requirement
•	For any other purposes that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities

Data Disclosure
As a part of providing you with i-Neighbour and other TimeTec App, Website & Services and the management and/or operation of the same, we may be required or need to disclose information about you to the following third parties:

•	Law enforcement agencies
•	Government agencies
•	Companies and/or organisations that act as our agents, contractors, service providers (including their subcontractors) and/or professional advisers
•	Companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions and providing you with i-Neighbour and other TimeTec App, Website & Services that you have requested or subscribed for
•	Our business associates and other parties for purposes that are related to the purpose of collecting and using your personal information
•	Other parties in respect of whom you have given your express or implied consent
•	Subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to i-Neighbour and other TimeTec App, Website & Services
•	Strategic partners that work with TimeTec to provide better products and services, or that help TimeTec market to customers. For example, when you inquire about i-Neighbour and other TimeTec solutions, TimeTec may send your email with your personal or non-personal information to Authorized Resellers for sales follow-ups. Personal information will only be shared by TimeTec to provide TimeTec solution and services to you; it will not be shared with third parties for their marketing purposes. Please note that TimeTec uses data processors that may collect, store and process your data on behalf of us. The selected processors offer sufficient guarantees with regard to technical and organizational security measures for the processing of your personal data. They are used for the following purposes: • Hosting of our applications or services • Customer relationship management system • Payment service platform • Provide user support tools, such as website live chat • Provide web visit and usage analytics

Data Security
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We use appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration/disclosure/access and any other misuse or unlawful processing. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, to be only accessed by those authorized with special access rights to our systems.

However, no method of transmission over the Internet, or method of electronic storage, is fully secure. We cannot guarantee the security of any information you send to us or store on the Service, and you do so at your own risk. Data could be accessed, disclosed, altered, or destroyed by a breach of any of our safeguards. If you believe your Personal Data has been compromised, please contact us with the details provided in “How to Contact Us” section below.

If we become aware of a personal data breach, we will inform you and/or the relevant authorities of the occurrence of the breach in accordance with applicable law.



Data Retention
We will retain your personal information for as long as is necessary and relevant for our business purposes, as described in this Privacy Policy. We will retain and use this personal information to comply with our legal obligations, maintain accurate financial and other records, resolve disputes, and enforce our agreements. Personal data we process on behalf of our client is retained for as long as needed to provide the Services.



International Transfer of Information Collected
Our company is based in Malaysia and we use IT and other service providers which are located in various countries. Our applications or services or parts of them may be hosted in facilities provided by Amazon Web Services in Singapore. Meanwhile, our websites may be hosted in Malaysia and when you send an email to us, this will also be stored on our email servers in Malaysia. Therefore, your information collected by TimeTec may be transferred to, processed and stored outside of your home country, in Singapore, Malaysia, the United States, Europe, or any other country in which TimeTec or its affiliates or service providers maintain facilities.

When submitting your personal data, you are agreeing to such processing, transfer or storage as outlined above. We will ensure at all times to take all reasonable steps necessary to maintain the security of your personal data in accordance with this Privacy Policy. We shall also take reasonable steps to ensure that any such third party entities are contractually bound not to use your personal information for any reason other than to provide i-Neighbour and other TimeTec App, Website & Services that are contracted by us to provide and to adequately safeguard your personal information.

EU Data Transfer
For personal data that is subject to European data protection laws, this means that any information which is submitted by you through the website or the application or service may be transferred to Singapore, Malaysia, the United States and/or to other territories outside of the EEA. We may also transfer your information to service providers outside the EEA for the purpose of providing our applications, advertising and services to you.

We take steps to ensure that where your information is transferred outside of the EEA to our service providers, appropriate measures and controls are in place to protect that information. Such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on certification of compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework or the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.

By using our website, products or services or by interacting with us in the ways described in this Privacy Policy, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Policy. If you do not want your information to be transferred outside the EEA you should not use our website, applications or services.

Transfer Outside Malaysia
It may be necessary for us to transfer your personal information outside Malaysia if any of our service providers or strategic partners who are involved in providing part of a i-Neighbour and other TimeTec App, Website & Services are located in countries outside Malaysia. You consent to us transferring your personal information outside Malaysia in these instances. We shall take reasonable steps to ensure that any such overseas entities are contractually bound not to use your personal information for any reason other than to provide i-Neighbour App, Website & Services that are contracted by us to provide and to adequately safeguard your personal information.



Your Rights & Obligations
Right to Access, Correction, Deletion, Data Portability
We can assist you to access, correct or delete your personal information held by us. Where you wish to have access to your personal information in our possession, wish to amend or to delete your information, you may make a request to us by contacting TimeTec Team with the contact details provided below. You should quote your name, address and phone/account number and provide brief details of the information you want a copy of in any such request. We will use reasonable efforts to comply with your request to access, correct or delete your personal information within 30 days of receiving your request. If you request for a copy of your data, we will provide it in electronic format. Please note that we may have to withhold access to your personal information in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.

Restriction of Processing, Object to Processing & Withdraw Consent
At any time, you may request to place restrictions on processing or object to the processing of your Personal Data, on legitimate grounds, except if it's otherwise permitted by applicable law. You may at the time of collection and at any later time, oppose the processing of your personal data for the purposes of marketing. Where the processing of your information is based on your consent, you have a right to withdraw that consent subject to legal or contractual restrictions.

If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us with the contact details provided below. You also have a right to lodge a complaint with data protection authorities.

This provision does not apply to Personal Data categorised as "User" Data, which is controlled by the Subscriber. In this case, the management of the "User" Data is subject to the Subscriber’s own Privacy Policy, and any request for access, correction or deletion should be made directly to the Subscriber responsible for the uploading and storage of such data into the Service.

Incomplete Personal Information
Where indicated (for example in registration/application forms), it is obligatory to provide your personal information to us to enable us to process your application for i-Neighbour and other TimeTec App, Website & Services . Should you decline to provide such obligatory personal information, we may not be able to process your application or provide you with i-Neighbour and other TimeTec App, Website & Services .
Your Obligations
You are responsible for providing accurate and complete information to us about yourself and any other person whose personal information you provide us and for updating this personal information as and when it becomes incorrect or out of date by contacting the TimeTec Team via the contact details provided below. This obligation is a condition to the provision of i-Neighbour and other TimeTec App, Website & Services to you and/or any other person authorised or permitted by you or your organisation/company to use the Products and/or Services. In the event you may need to provide us with personal information relating to third parties (for example about your spouse or children or where you are the designated person in charge (from an organisation or company) for dealing with us, if you are acquiring and are responsible for a service and/or product that they will use), you confirm that you have (i) obtained their consent or otherwise entitled to provide their personal information to us and for us to use accordingly, and (ii) informed them to read this Privacy Policy at our website.



Links to Third Party Websites
Please be informed that this Privacy Policy applies solely to i-Neighbour and other TimeTec Websites and does not apply to any third party websites you may access from our websites. To determine how they deal with your Personal Information, you should ensure that you read their respective privacy policies.



Protection of Minors
As a general rule, children and persons under the age of 18 years should not disclose personal data to us without the consent of their parents or guardians. We do not solicit personal data from children and we do not knowingly collect personal data from children, use said data in any way or disclose said data to third parties without authorization.



How to Contact Us
If you have requests and questions or concerns about i-Neighbour Privacy Policy, please contact us at:

TimeTec Cloud Sdn. Bhd.
No. 6, 8 & 10, Jalan BK 3/2
Bandar Kinrara
47180 Puchong
Selangor, Malaysia
Tel: +603 - 8070 9933
Email: info@i-neighbour.com