DXN WEBSITE VISITOR PRIVACY/COOKIES NOTICE

This Privacy Notice describes how DXN Group of Companies (“DXN” or “we” or “us”) use personal data collected or received from visitors (“Visitors” or “you”) of this website (“Website”). It describes how we collect or receive your personal data, the types of personal data we process, how we use, share and protect these data, how long we retain these data, your rights with respect to the processing of your personal data, and how you can contact us about our privacy practices.

How We Collect and Receive Personal Data from You

Where we ask you to provide us with your personal data, we will indicate whether providing the personal data is a statutory or contractual requirement, or a requirement necessary to enter into and/or facilitating a contract, as well as whether you are obliged to provide the personal data and of the possible consequences of a failure to provide the personal data.

DXN collects and receives personal data from Visitors in various ways, such as:

• Contacting Us: When you contact us through the various communication channels on our website’s “Contact Us” page, we collect personal data and other information that you provide, such as email addresses, telephone numbers or online forms.
• Cookies: We use cookies (small data file placed on a computer or mobile device) or similar technologies that collect certain Website usage information when you access, view, and use the Website. We do not enable third parties to place cookies on your device. Data collected via cookies is anonymous unless you log in to our services.

You may disable cookies via your browser’s settings (e.g., under the “Preferences” or “Internet Options” features of your browser). However, disabling cookies may impair Website functionality.

The Types of Personal Data We Process

Through the cookies listed above under the section “How We Collect or Receive Personal Data from You” we collect information regarding your Website usage, IP-address, browser type and operating system.

In addition, when you communicate with us through various communications channels, we collect your contact details, such as your name, email address, address, telephone number, and/or fax number. You may also voluntarily provide other personal data in connection with your inquiries or comments. We encourage you, however, to provide no more personal data relating to you than is necessary in order for us to provide an appropriate response to your inquiries or comments.

We may process other personal data in exceptional circumstances only. If we need to process other types of personal data about you, we will make sure that you are informed about the processing of such personal data and that there is a valid legal basis for doing so (e.g., your consent).

How We Use the Personal Data We Collect

We process your personal data only where necessary, including but not limited to the following purposes:

1. To comply with our legal obligations, such as:
   • Retaining records as required under applicable laws and regulations; and
   • Responding to lawful requests from regulatory or enforcement authorities.
2. For our legitimate business interests, including to:
   • Respond to your comments, enquiries, or requests;
   • Communicate with you about our website, products, or services;
   • Operate, maintain, administer, monitor, and improve our website and online services, including by:
     • Tracking and analysing usage patterns and website performance;
     • De-identifying personal data for aggregated analysis;
   • Prevent and protect against fraud, misuse, unauthorised access, and other harmful activity; and
   • Conduct internal administrative and business operations.

How We Share Personal Data

DXN does not sell, rent, or trade your personal data. We do share your personal data among us as joint controllers and with:

• Related entities operating direct selling businesses around the world under the company name DXN, to whom it is reasonably necessary or desirable for DXN to disclose personal data;
• Providers of infrastructure- or platform- or software-as-a-service solutions, software development services, information system maintenance services, record management services or marketing services;
• Government authorities or other third parties, if required or allowed otherwise by law or reasonably necessary to protect the rights, legal interests, property, or safety of you, others, or ourselves.

International Data Transfers

We transfer the personal data we collect about you to entities within the DXN organisation, as well as to third-party service providers that process personal data on our behalf. Some of these companies and service providers are located in countries other than the country in which the personal data was originally collected. The laws of those countries may not have the same level of data protection as the country in which you initially provided the personal data. When we transfer your personal data to other countries, we will protect that personal data as described in this Privacy Notice and in accordance with applicable law.

How We Protect Personal Data

We maintain appropriate technical and organisational security safeguards designed to protect the personal data we process against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure, or use.

How Long We Retain Personal Data

We store personal data as long as necessary to fulfil the purposes for which we collect the data (see above under "How We Use the Personal Data We Collect"), except if required or allowed otherwise by law. Please contact us using the contact details provided in this Privacy Notice if you have any questions regarding our data retention practices.

Updates to this Privacy Notice

DXN may update this Privacy Notice from time to time. We will notify you of any significant changes to this Privacy Notice on the relevant DXN websites, in official DXN publications, or through other appropriate communication channels. All changes shall be effective from the date of publication, unless otherwise provided in the notification.

Your Rights

Subject to the relevant legislative provisions, you have the following data protection rights:

• The right to access
  You have the right to obtain confirmation as to whether or not your personal data are being processed and, where this is the case, access to the personal data. You also have the right to ask us for a copy of your personal data.
• The right to rectification
  You have the right to ask us to rectify personal data about you that you think are inaccurate. You also have the right to ask us to complete data you think are incomplete. This right always applies.
• The right to erasure
  This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your data where there’s no compelling reason for us to keep using the data. This is not a general right to erasure; there are exceptions, e. g. if we have a legal obligation to keep your data.
• The right to restriction of processing
  You have the right to ask us to restrict the processing of your personal data under certain circumstances.
• The right to data portability
  This right only applies to personal data you have given us. You have the right to ask that we transfer the data you gave us to another organisation or give the data to you.
• The right to withdraw consent
  Where you have provided us with consent to process your personal data, you have the right to withdraw your consent at any time. This will not affect the lawfulness of the processing that has been carried out based on your consent prior to the withdrawal.
• The right to object
  When we process your personal data for purposes of pursuing our legitimate interests, you have the right to object to such processing at any time. If you object, we will stop the processing unless we have strong and legitimate reasons to continue using your data.
• The right to lodge a complaint
  If you have concerns about the way we handle or process your personal data, please contact our Data Protection Officer (contact details below) who will investigate the matter and report back to you. If you are still not satisfied after our response, depending on the law of the country where you live or work, you may have the right to complain to a data-protection regulator.

How to Contact Us

If you have any enquiries about this Privacy Notice, if you would like to update information we have about you, or if you wish to exercise your data protection rights, you may contact your local affiliate via email to pdpa@dxn2u.com or by letter to:

Data Protection Officer
DXN Holdings Bhd.
DXN Cyberville
Jalan Teknokrat 1, Cyber 3, 63000 Cyberjaya,
Selangor, Malaysia.
Attn: Legal & Compliance Department