We are part of Toga Limited Group of Companies. In order to provide you with the best experience when using our system, we may collect, use, disclose, process and protect your personal identifiable information or personal data.Our system, www.togago.com is owned and operated by WGS Discovery Tours and Travel (M) Sdn. Bhd.("TogaGo", "Us", "We", or "Our")

The Personal Data Protection Act 2010 (hereinafter referred to as the "PDPA"), which regulates the processing of personal data in commercial transactions, applies to WGS Discovery Tours and Travel (M) Sdn. Bhd.

We believe you should be informed about what kind of personal data we collect and how we use it in our system, both through our website and/or app (the "Site"). By reading this Privacy Policy, you can always make the best decision about the personal data that you share with us. Personal data here refers to any information which are related to an identified or identifiable natural person ("Personal Data"). By clicking "agree", you acknowledge that you have read this Privacy Policy and the TogaGo Terms of Use (https://www.togago.com/about/Terms) and understand their content and consequences, and you agree and give consent to Us for the collection, use, disclosure and processing of your Personal Data in accordance with this Privacy Policy and/or the Terms of Use. Further, you acknowledge that every Personal Data that you have provided or will provide is yours to share and is true and accurate.

From time to time, TogaGo may revise this Privacy Policy to reflect changes in the laws and regulations, our use practices, the features of our Site and/or advances in technology. If we make revisions that change the way we collector use your Personal Data, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy.

This Privacy Policy explains about:

• Information We Collect
• How We Use Your Information
• Sharing of Your Personal Data
• Access to or Correction of Your Personal Data
• Withdrawing Consent
• Removal of Your Personal Data
• Retention of Your Personal Data
• Protection of Your Personal Data
• Links to Other Websites
• Registration and Memberships
• Miscellaneous
• Our Contact

Information We may Collect from You

Following your consent, we may collect your Personal Data to provide our services to you when using the Site.

Personal Data We May Collect from You

We may collect the following personal data from you:

• Personal information to establish your identity and background such as your full name, passport or identity card number, photo and nationality
• Payment information such as your bank account number, bank account holder full name and details, bank swift code, billing address and other bank account details
• Booking information (such as, for each traveller, the traveller’s name, frequent flyer details, redress control number, country of citizenship, booking reference number, and itinerary, which may include name of airline or carrier, hotel accommodation and/or vessel, port of destination, port of arrival, date and time of departure and/or check-in, date and time of arrival and/or check-out, meal preferences, luggage information, and layover information)
• Account information (such as login credentials, including email address and password, and account settings)
• Your contacts (such as contact information of people you add to, or notify of, your reservations or itineraries through our Services)
• Your preferences (such as your home airport, seating preferences, meal preferences, communication preferences, and other preference information you provide us)
• Reviews you submit (including any screenname you publish under or any personal information you include about yourself or others in such review)
• Content you publish (including your travel recommendations and any personal information you include about yourself or others, or in content you publish in your Guide or other mediums provided by us)
• Photos of you (such as when you add a photo of yourself to your profile, upload photos to a review, or link your social media account to your TogaGo account)
• Communications you send us (such as questions, conversations, complaints, or other information that you may submit to our support team)
• Promotion information (if you choose to participate in a contest, sweepstakes, or similar campaign, we will collect any information you provide in relation to such activity, such as photos, images, captions, or other content, in accordance with the terms provided at that time)
• Other information you may provide (including other information you provide about yourself or others through our Services or to which you provide us with access via third-party platforms)

For general browsing although no personal data is revealed to us, certain technical and statistical information is available to us via our internet service provider such as cookies, your IP address, the time, date and duration of your visit.

If you provide us with any personal data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such personal data to us, you represent to us that you have obtained the consent of the third party to provide us with their personal data for the purposes as listed below.

How We Collect Your Personal Data

We may collect personal data either from you, from your authorized representatives, from third parties, or from publicly available sources which may include (but is not limited to):

• when you register for our services (for example register to be user of our product)
• when you contact us in person, by a phone call or over the counter (for example when you contact us for any enquiries, complaints, comments or feedbacks, we may keep record of that correspondences)
• when you participate in any surveys, questionnaires, competitions, contests, offers, or promotions done internally or via an appointed third party
• when you commence a business relationship with us (for example, as a service provider, or business partner)
• when you visit any of our subsidiaries, branches or premises
• when you attend any of our corporate events or third-party open day
• when you visit or browse our websites
• when you apply job with us
• when you interact with us via social media or interactive applications including but not limited to Yippi, Facebook, Twitter, and Instagram
• when we collect information about you from third parties we dealt with or are connected with you (payment collector, credit reporting agencies or financial institutions)
• from such other sources where you have given your consent for the disclosure of personal data relating to you, and/or where otherwise lawfully permitted.

Use of Personal Data Collected

We may also collect, maintain and store your information to offer you the best packages that will be suitable with your preferences. In addition, we may also use your information as collected through the Site for the following purposes:

• registering your use and/or access of the Site;
• managing, operating, administering and/or access of the Site;
• contacting you on the matters relating to your use and/or access to the Site and managing the queries and/or requests submitted by you through the Site;
• customizing your experience when using the Site, and improving your customer experience and satisfaction;
• publishing your reviews about our services as well as the listed products on our Site;
• enforcing the provisions in our Terms and Conditions;
• resolving disputes, collecting outstanding payment and troubleshooting and/or;
• for the purposes otherwise that will be made available to you at the point of collection.

We may also use your Personal Data and other information collected for:

• digital marketing which includes, however is not limited to social media, display advertisement, Search Engine Optimization ("SEO"), Search Engine Marketing ("SEM"), push notification using open graph techniques and
• conventional marketing purposes which includes however is not limited to sending you email(s) about new products, special offers, and surveys or other information which we think you may find interesting.
• Please note that you may opt out of any marketing materials we may send to you by following the unsubscribe instructions set out in our marketing materials if you choose to opt out of any marketing materials and we will respect your wishes. However, please note that we may target and personalise our marketing communications, purchase recommendations and other contacts that we display on our website and application based on the combined data we have collected about you.

With Whom We Share Your Personal Data

Your Personal Data may be shared to other companies, organizations and/or individuals (the "Third Party") for completing the service we provide to you. We may engage the Third Parties for obtaining their services which include, however are not limited to website hosting, data analysis, marketing, promotions, processing credit card transactions and other relevant services.

Depending on your location, TogaGo and the Third Party may also be transferring your Personal Data overseas.

Please note that TogaGo may disclose your Personal Data pursuant to the following conditions:

• Consent: We will only share your Personal Data with the Third Parties when we have your consent to do so. We will need your opt-in consent for sharing any sensitive Personal Data, as required by the applicable laws and regulations. By clicking the "Agree" button, you have established a clear affirmative act and a freely given, specific, informed and unambiguous agreement to the processing of the personal data. This may include the sharing of the collected personal data to the Third Party.
• To Purchasers: This is in connection with any sale, assignment, or other transfer of all or part of our business or company.
• For Legal Reasons: Based on our discretion, we may share your Personal Data with the Third Parties if we deem the share of data is necessary to: i) comply with the applicable laws and regulations; ii) enforce our Terms and Conditions; iii) investigate any potential fraud or illegal acts; and/ or iv) protect our brand, our reputation as well as our property.

If Personal Data Provided by You Is Incomplete

Where indicated in our login or registration, it is obligatory to provide your personal data to us to enable us to process your application for our services. Should you fail to provide a complete and obligatory personal data, we may not be able to process your application or provide you with our services and payments.

Your Rights to Access and Correct Your Personal Data

We can assist you to access and correct your personal data held by us. Where you wish to have access to your personal data in our possession, or where you are of the opinion that such personal data held by us is inaccurate, incomplete, misleading or not up-to-date, you may make a request to us via Customer Support at our TogaGo site.

How Long We Will Keep Your Personal Data

We will retain your personal data in compliance with this Policy and/or the terms and conditions of your subscriptions of our product for the duration of your relationship with us, for such period as may be necessary to protect the interests of the company or its subsidiaries and/or its customers as may be deemed necessary, where otherwise required by the law and/or where required by Toga Limited Group of Companies or its subsidiaries’ s relevant policies.

Retention of Your Personal Data

Your Personal Data will be retained for as long as your account is still in existence and as needed to provide you without services. We shall cease to retain Personal Data, or with reasonable effort to remove the means by which the Personal Data can be associated with You as an individual, as soon as, (a) the purpose for which Personal Data was collected is no longer being served by the retention of data; and (b) it is not required by the applicable laws and/ or not necessary for business purposes.

Protection of Your Personal Data

We will protect your Personal Data by maintaining reasonable security arrangements, including physical, technical and organizational procedures, to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. If there is any breach of Personal Data, we will notify you through our channels, whether directly or indirectly, to give you sufficient information regarding such breach of Personal Data. Following the notification, we will strive with our utmost best effort to recover the security of your Personal Data in our Site.

Links to Other Websites

Our Site may contain links to other websites of interest. However, once you have used these links to leave our Site, you should note that we do not have any control over that other website. Please note that we are not responsible for the privacy policy or practices of such other websites and advise you to read the privacy policy of each website you visit which collects your Personal Data.

Registration and Memberships

This Site allows you to create a user account based on the data you provide. By providing the data, registering, and creating your account, you warrant that: You are at least 18 years of age;

Information about you is true and accurate, current and complete as required in the registration form on the Site (the "Registration Data"); and

You will update this Registration Data to keep it true, accurate and complete.

Assignment, Change of Control, and Transfer

All of our rights and obligations under our Privacy Policy are freely assignable by us to any of our affiliates, in connection with a merger, acquisition, restructuring, or sale of assets, or by operation of law or otherwise, and we may transfer your information to any of our affiliates, successor entities, or new owner.

Our Global Operations

You agree to our information practices, including the collection, use, processing, and sharing of your information as described in this Privacy Policy, as well as the transfer and processing of your information to Malaysia and other countries globally where we have or use facilities, service providers, or partners, regardless of where you use our Services. You acknowledge that the laws, regulations and standard of the country in which your information is stored or processed may be different from those of your own country.

Cookies

TogaGo uses cookies and/or similar technologies (scripts, tags, web beacons) to store information about visitor's preferences, and/or to record user-specific information on which pages the site visitor accesses or visits, and/or to personalize our web page content based upon visitor's browser type and/or other information that the visitor sends via their browser.

In accordance with the PDPA:

For any request access and/or corrections on your personal data, we may refuse to comply with your request. We will inform you of our refusal and the reason(s) for our refusal if such request made refused.

Miscellaneous

Applicability: in the event of inconsistency between the Terms and Conditions and this Privacy Policy, then the provisions in this Privacy Policy will apply.

Transfer of Business: in the event of change of control or ownership of TogaGo's business or group of companies, then the Personal Data collected in the Site may be part of transfer of the assets.

Language

The Privacy Policy shall be prepared and executed in English and if translated into a language other than English for any purpose, the English version shall in all events prevail and be paramount in the event of any differences, questions or disputes concerning the meaning, form, validity, or interpretation of this

Our Contact Details

Toga Limited Group of Companies or its subsidiaries is committed to protecting your personal data. If you have questions or comments about TOGA’s administration of personal data relating to TogaGo, please contact us.

If you have any questions, comments or suggestions regarding this Policy, we would be glad to hear from you. Please contact us via Customer Support at TogaGo.