ROSETECH PRIVACY STATEMENT

Protecting the individual’s privacy on the Internet is crucial to the future of Internet-based business and the move toward a true Internet economy. We have created this Privacy Statement to demonstrate our firm commitment to the individual’s right to data protection and privacy. This Privacy Statement outlines how we handle information that can be used to directly or indirectly identify an individual (“Personal Data”).

A. General Information

This Privacy Statement applies to Personal Data that you provide to Rosetech or which is derived from the Personal Data as outlined below. The use of and any information that is gathered by cookies or other web tracking technologies is subject to the disclosures.

The data controller of www.rosetech.com.my is Rosetech, ZP-01-21, Zest Point, Lebuhraya Bukit Jalil Bandar Kinrara 9, 47180 Puchong, Selangor, Malaysia (“Rosetech”). Where a client registration form is presented on this website or during a meeting with our representative, the data controller may vary depending on the actual offering or the purpose of the data collection but it is in any case displayed on the individual registration form privacy statement.

Rosetech will process the Personal Data provided hereunder only as set out in this Privacy Statement. Further information can be found in Sections B. and C. below. Where the processing of your Personal Data is based on a statutory permission, you can find information on which Personal Data Rosetech is processing or using for which purposes in Section B below. Where consent for the processing of your Personal Data is required you can find further information in Section C. below.

Where Rosetech is processing and using your Personal Data as permitted by law (see B. below) or under your consent (see C. below), Rosetech will store your Personal Data (i) only for as long as is required to fulfil the purposes set out below or (ii) until you object to Rosetech’s use of your Personal Data (where Rosetech has a legitimate interest in using your Personal Data), or (iii) until you refund your consent (where you consented to Rosetech using your Personal Data). However, where Rosetech is required by mandatory law to retain your Personal Data longer or where your Personal Data is required for Rosetech to assert or defend against legal claims, Rosetech will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.

As a general principle, your granting of any consent and your provision of any Personal Data hereunder is entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide Personal Data. However, there are circumstances in which Rosetech cannot take action without certain Personal Data, for example because this Personal Data is required to process your orders or provide you with access to a web offering or newsletter. In these cases, it will unfortunately not be possible for Rosetech to provide you with what you request without the relevant Personal Data.

Rosetech has affiliates and third-party service providers within as well as outside of the Malaysia. As a consequence, whenever Rosetech is using or otherwise processing your Personal Data for the purposes set out in this Privacy Statement, Rosetech may transfer your Personal Data to countries outside of the Malaysia including to such countries in which a statutory level of data protection applies that is not comparable to the level of data protection within the Malaysia.

You can request from Rosetech at any time information about which Personal Data Rosetech processes about you and the correction or deletion of such Personal Data. Please note, however, that Rosetech can delete your Personal Data only if there is no statutory obligation or prevailing right of Rosetech to retain it. Kindly note that if you request that Rosetech delete your Personal Data, you will not be able to continue to use any Rosetech service that requires Rosetech’s use of your Personal Data.

If Rosetech uses your Personal Data based on your consent or to perform a contract with you, you may further request from Rosetech a copy of the Personal Data that you have provided to Rosetech. Rosetech will carefully consider your request and discuss with you how it can best fulfil it.

Furthermore, you can request from Rosetech that Rosetech restricts your Personal Data from any further processing in any of the following events:

(i) you state that the Personal Data Rosetech has about you is incorrect, (but only for as long as Rosetech requires to check the accuracy of the relevant Personal Data),

(ii) there is no legal basis for Rosetech processing your Personal Data and you demand that Rosetech restricts your Personal Data from further processing,

(iii) Rosetech no longer requires your Personal Data but you claim that you require Rosetech to retain such data in order to claim or exercise legal rights or to defend against third party claims or

(iv) in case you object to the processing of your Personal Data by Rosetech (based on Rosetech’s legitimate interest as further set out in B. below) for as long as it is required to review as to whether Rosetech has a prevailing interest or legal obligation in processing your Personal Data.

If you believe that Rosetech is not processing your Personal Data in accordance with the requirements set out herein or applicable Malaysia data protection laws, you can at any time lodge a complaint with the data protection authority of Malaysia in which you live or with the data protection authority of the country or state in which Rosetech has its registered seat.

Use of this website by children. This website is not intended for anyone under the age of 18 years. If you are younger than 18, you may not register with or use this website.

Links to other websites.

This website may contain links to foreign (meaning non-Rosetech Group companies) websites. Rosetech is not responsible for the privacy practices or the content of websites outside Rosetech. Therefore, we recommend that you carefully read the privacy statements of such foreign sites.

B. Where Rosetech uses Personal Data based on the Law

In the following cases, Rosetech is permitted to process your Personal Data under the applicable data protection law.

Providing the requested goods or services.

If you order goods or services from Rosetech, Rosetech will use the Personal Data that you enter into the order or registration form (usually (a subset of) your name, (email) address, telephone number, company name and address, your job title and role and, if payment is to be made to Rosetech, credit card number or bank details) only to process your order or to provide the requested goods or service. This may include taking the necessary steps prior to entering into the contract, responding to your related inquiries, and providing you with shipping and billing information and to process or provide customer feedback and support. This may also include conversation data that you may trigger via the chat functionalities on www.rosetech.com.my or other local Rosetech web presences, contact forms, emails, or telephone. In this Privacy Statement, “goods and services” includes (access to) Rosetech’s web services, offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, tutorials, trainings and events.

If you participate in tutorials or trainings provided by Rosetech, Rosetech may also track your learning progress in order to make this information available to you. Furthermore, we communicate on a regular basis by email with users who subscribe to our services, and we may also communicate by phone to resolve customer complaints or investigate suspicious transactions. We may use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications, which are not marketing-related but merely required for the relevant business relationship. With regard to marketing-related types of communication (i.e. emails and phone calls), Rosetech will

(i) where legally required only provide you with such information after you have opted in and

(ii) provide you the opportunity to opt out if you do not want to receive further marketing-related types of communication from us. You can opt out of these at any time.

Rosetech and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, Rosetech is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through Rosetech’s websites or other delivery channels controlled by Rosetech. This may include :

(i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists;

(ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information;

(iii) blocking of access to Rosetech’s services and systems in case of a potential match; and

(iv) contacting a user to confirm his or her identity in case of a potential match.

Furthermore, you acknowledge that any information required to track your choices regarding the processing or use of your Personal Data or receipt of marketing materials may be stored and exchanged between members of the Rosetech as required to ensure compliance.

Each of the use cases below constitutes a legitimate interest of Rosetech to process or use your Personal Data. If you do not agree with this approach, you may object against Rosetech’s processing or use of your Personal Data as set out below.

Rosetech may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any Personal Data. If you nonetheless enter Personal Data in a questionnaire or survey, Rosetech may use such Personal Data to improve its products and services.

Rosetech may anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its products and services.

In case of telephone calls or chat sessions, Rosetech may record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions in order to improve the quality of Rosetech services.

In order to keep you up-to-date/request feedback. Within an existing business relationship between you and Rosetech, Rosetech may inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars or events) which are similar or relate to such products and services you have already purchased or used from Rosetech. Furthermore, where you have attended a webinar, seminar or event of Rosetech or purchased products or services from Rosetech, Rosetech may contact you for feedback regarding the improvement of the relevant webinar, seminar, event, product or service.

You may object to Rosetech using Personal Data for the above purposes at any time. If you do so, Rosetech will cease using your Personal Data for the above purposes (that is to say, under a legitimate interest set out above) and remove it from its systems unless Rosetech is permitted to use such Personal Data for another purpose set out in this Privacy Statement or Rosetech demonstrates a compelling legitimate interest to continue processing your Personal Data.

C. Where Rosetech uses My Personal Data based on Client’s Consent

In the following cases Rosetech will only use your Personal Data as further detailed below after you have granted your prior consent into the relevant processing operations. Therefore, each information about a processing operation with regard to Personal Data is linked to one consent statement in the Consent Resource Center. If you re-open this Privacy Policy after you have initially one or more consents granted you will not only see the information related to the consents you have granted but the full privacy statement.

Subject to a respective provision and your consent, Rosetech may use your name, email and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with Rosetech in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about Rosetech’s software and services (including marketing-related newsletters) as well as events of Rosetech and in order to display relevant content on Rosetech websites. In connection with these marketing-related activities, Rosetech may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks’ data or the web offerings’ own databases in order to display to you more relevant information.

Rosetech offers you the option to use its web offerings including forums, blogs, and networks linked to this website that require you to register and create a user profile. User profiles provide the option to display personal information about you to other users, including but not limited to your name, photo, social media accounts, postal or email address, or both, telephone number, personal interests, skills, and basic information about your company.

These profiles may relate to a single web offering of Rosetech may also allow you to access other web offerings of Rosetech or of other entities of the Rosetech Group, or both (irrespective of any consent granted under the section “Forwarding your Personal Data to other Rosetech companies.” below). It is, however, always your choice which of these additional web offerings you use and your Personal Data is only forwarded to them once you initially access them. Kindly note that without your consent for Rosetech to create such user profiles Rosetech will not be in a position to offer such services to you where your consent is a statutory requirement that Rosetech can provide these services to you.

Within any web offering, beyond the mere provision of access your profile is used to personalize interaction with other users (for example, by way of messaging or follow functionality) and by Rosetech to foster the quality of communication and collaboration through such offerings and for Rosetech to provide gamification elements (gamification is the process of taking something that already exists, such as a website, an enterprise application, or an online community, and integrating game mechanics into it to motivate participation, engagement, and loyalty). To the greatest extent supported by the relevant web offering, you can use the functionality of the relevant web offering to determine which information you want to share.

In connection with the registration for and provision of access to an event or seminar, Rosetech may ask for information about your health for the purpose of identifying and being considerate of individuals who have disabilities or special dietary requirements throughout the event. Any such use of information is based on the consent you grant hereunder.

Kindly note that if you do not provide any such information about disabilities or special dietary requirements, Rosetech will not be able to take any respective precautions.

If you register for an event, seminar, or webinar of Rosetech, Rosetech may share basic participant information (your name, company, and email address) with other participants of the same event, seminar, or webinar for the purpose of communication and the exchange of ideas.

Rosetech may transfer your Personal Data to other entities in the Rosetech Group. The current list of Rosetech Group entities can be found here. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Section C. above.

You may at any time refund consent granted hereunder by unsubscribing. In case of refund, Rosetech will not process Personal Data subject to this consent any longer unless legally required to do so. In case Rosetech is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any refund has no effect on past processing of personal data by Rosetech up to the point in time of your refund. Furthermore, if your use of a Rosetech offering requires your prior consent, Rosetech will not be (any longer) able to provide the relevant service, offer or event to you after your revocation.

D. Biometric (Face) Data for Attendance

Where your employer has turned on face recognition for attendance in RosieHR, a photo of your face is taken when you enrol and each time you clock in or out. Depending on your employer's settings, RosieHR stores either a numeric template of your face or reference photos of your face, together with the result of each check (verified, mismatch or no face).

This data is used solely to verify that the person clocking in or out is you. It is not used for any other purpose, and it is not sold or shared with third parties. Face matching is done in your browser or by a face verification service hosted on your employer's own server.

Face data is only collected after you give your explicit consent during enrolment, in line with the Personal Data Protection Act 2010 (Malaysia). It is kept for as long as you remain employed or until you withdraw your consent. You may withdraw your consent at any time by contacting your HR department, who will delete your enrolled face data. After that, your attendance can no longer be verified by face.

E. AI Chat (Rosie)

When you chat with the RosieHR assistant (on the web or on Telegram), the text of your messages and the answers is stored for 30 days so the assistant can follow the conversation, and is then deleted automatically. If you ask the assistant to remember something (for example a language preference), that note is kept for up to 12 months or until you ask it to forget. The assistant may also learn a simple style preference from your recent messages (language, tone, emoji and length of answers only). Sensitive details such as identity numbers, account numbers, passwords and health information are not saved as notes. Only you can see this information. You can view, delete or switch it off at any time under Profile > Memori AI, or by asking the assistant to forget it.

Refund Policy

At Rosetech Sdn. Bhd., customer satisfaction is our top priority. If you are not completely satisfied with your purchase, we offer a refund within 7 working days of the purchase date, subject to the terms below:

Eligibility for Refund

- The request for a refund must be made within 7 working days from the date of purchase.
- Items or services must be unused, in their original condition, and where applicable, returned in the original packaging.
- Proof of purchase (e.g., receipt or order confirmation) is required.

Non-Refundable Items/Services

- Customized products, digital access, or services already rendered.

How to Request a Refund

To request a refund, please contact us at admin@rosetech.com.my with:
- Your order number
- Reason for the refund
- Any supporting documents (if required)

Once we receive your request, we will review it and notify you of the approval or rejection of your refund. Approved refunds will be processed within 3–5 working days and returned to your original method of payment.

Late or Missing Refunds

If you haven’t received a refund yet:
1. First check your bank account again.
2. Then contact your credit card company (it may take some time before your refund is officially posted).
3. Next, contact your bank.

If you’ve done all of this and you still have not received your refund, please contact us at admin@rosetech.com.my.