About this Policy
This Policy sets out the essential details relating to your personal information relationship with Babel. This Policy applies to all Babel’s products and services, including all retail and food and beverages sold under the trade name Babel (collectively known as “Babel’s products and services”). The terms governing your use of the Babel’s products and services are defined in our Terms and Conditions.
From time to time, we may develop new or offer additional products and services. If the introduction of these new or additional products and services result in any change to the way we collect or process your personal information we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
The aim of this Policy is to:
- Ensure that you understand what personal information we collect about you, the reasons why we collect and use it, and who we share it with;
- Explain the way we use the personal information that you share with us in order to provide you the best wellness journey when you are using the Babel’s products and services; and
- Explain your rights and choices in relation to the personal information we collect and process about you and how we will protect your privacy.
For information on how to contact us if you ever have any questions or concerns, please see the “How to Contact Us” below.
Collection of Personal Information
We receive and store information about you, from which you are identifiable, including but not limited to your name, nationality, personal identity document number, address, telephone number, email address, credit card details, payment method and history, gender, date of birth, financial background, your occupation, your photo, data relating to your health and workout, and any information about you which you have provided to Babel in using our products and services, interact with our Customer Service or official social media platforms, registration forms, application forms or any other similar forms that has been or may be collected, stored, used and/or processed by Babel from time to time.
We also collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service. This information includes:
- Your activity on the Babel and the Babel App services, such as, but not limited to, application usage, club check-ins, hours of usage, payment record, training progress, personal training and class bookings and attendance, body composition, calories burned, distance traveled, search queries and retail and food and beverage purchases;
- Your interactions with our email, push and text messaging;
- Details of your interactions with Customer Service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;
- Device IDs or other unique identifiers;
- Advertising identifiers, such as those on mobile devices, tablets, and streaming media devices that include such identifiers;
- Device and software characteristics (such as type and configuration), connection information, statistics on page views, referring source (for example, referral URLs), IP address (which may tell us your general location), browser and standard web server log information; and
In addition to the personal information you provide to Babel directly, Babel may collect your personal information from publicly available sources or from third parties, for example, from:
- Filled up application or registration forms, surveys or training tools or other similar forms;
- Publicly available sources such as directories and online materials such as articles and social media (privacy setting set at public);
- Babel’s official social media pages or accounts, if you follow, like or are a fan of such pages or accounts;
- When you interact and communicate with Babel at any events or activities or contests;
- Other entities who provide you with services or with whom you have a contractual relationship and has the right to share the information with Babel; or
- Marketing service providers or partners.
All members are required to input their personal information into our database via the Babel App. However, if you do not provide Babel your personal information, Babel will not be able to process your personal information and may cause Babel to be unable to provide services or products to or accept payments from you.
Use of Information
We use information to provide, analyse, administer your account, enhance and personalise our products and services and marketing efforts, to process your registration, your purchases and your payments, and to communicate with you on these and other topics. For example, we use information to:
- Carry out research, analyse and understand our members’ demographics and behavior to develop, enhance and personalise products and services towards improving your experience with us;
- Assist us in responding to your queries and requests efficiently;
- Process payments and to prevent or detect fraud when you are purchasing from us. For example, payments that you make will be processed by our appointed service provider. Disclosure to these payment processing service provider is necessary for the purpose of conducting the sale transaction that you have opted for; and
- Process your personal information for more general use such as internal membership administrative purposes, maintain the safety and security of our products and services, and to comply with its obligations under the law.
In addition to the use of personal information outlined above, you may be subscribed to our newsletters, announcements, surveys, marketing and or promotional materials from time to time. These marketing and or promotional materials may come from Babel or through affiliation with third parties, you can choose to unsubscribe by selecting the unsubscribe function within the electronic marketing material or let us know at [email protected]. Please note that if you unsubscribe, we may still send you service-related messages, such as important announcements, account administration such as password resets, payment receipts and reminder for outstanding dues. You can always opt back in by contacting us at [email protected] at any point in time.
Disclosure of Information
We are committed to remain your information confidential and not share it with any other parties other than the parties you have authorised as described below:
The Babel Family
We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information. For example, we may engage Service Providers to provide marketing, advertising, communications, infrastructure and IT services, to personalise and optimise our service, to process credit card transactions or other payment methods, to provide customer service, to collect debts, to analyse and enhance data (including data about users' interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorise them to use or disclose your personal information except in connection with providing their services and will require them to delete or destroy the information.
We may offer joint promotions or programmes that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.
Notwithstanding, personal information may be disclosed for any purpose other than the above if:
- The disclosure is necessary for the purpose of preventing or detecting a crime, or for the purpose of investigations or was required or authorised by or under any law or by the order of a court;
- Babel acted in the reasonable belief that we had in law the right to disclose the personal information to the other person;
- Babel acted in the reasonable belief that we would have had your consent if you had known of the disclosing of the personal information and the circumstances of such disclosure; or
- The disclosure was justified as being in the public interest in circumstances as determined by the minister charged with the responsibility for the protection of personal information.
You may also choose to disclose your information in the following ways, but not limited to:
- While using the Babel App, you may have opportunities to post reviews, feedback or other information publicly, and third parties could use the information you disclose;
- Certain portions of our service may contain a tool which gives you the option to share information by email, text message and social, within the Babel App, or other sharing applications, using the clients and applications on your smart device; and
Accuracy of Your Information and Your Rights to Access Your Information
All members are required to input their personal information into our database via the Babel App. To ensure that the personal information collected is accurate, complete, not misleading and kept up-to-date, we have designed specific fields with rules, if applicable, to reduce errors, wrong information and incomplete forms. We will also be sending push notifications on a periodic basis to remind you to review the validity of your information. In situations where we deem information that was inputted is insufficient or inaccurate, we will reach out to you in writing to provide further information or revise the current one if necessary.
On the other hand, you have your rights over your information. You can request access to your personal information and to correct or update out-of-date or inaccurate personal information we hold about you, except where compliance with a request to such access or correction is refused under the Act. You can most easily do this by visiting the "Account" portion of the Babel App, where you have the ability to access and update information about your account.
We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as free trial fraud.
Security of Your Personal Information
Babel ensures that all information collected will be safely and securely stored. We protect your personal information by implementing technical and organisational measures that are designed to provide a level of security appropriate to the risks of processing your personal information. Those measures are, but not limited to, the following :
- Allowing access to personal information only via passwords;
- Maintaining technology products to prevent unauthorised computer access;
- Securely destroying your personal information when it is no longer needed for our record retention purposes;
- All data is transported securely with end-to-end SSL encryption and stored using 256 bit Advanced Encryption Standard. For hard copy formats, these documents will be filed and locked in dedicated cabinets; and
- From a user’s perspective, your password protects your user account, so we encourage you to use a unique and strong password and limit access to your mobile device or computer.
These measures are designed to provide a level of security appropriate to the risks of processing your personal information, however, please note that no system is ever completely secure.
Retention of Personal Information
We keep your personal information only as long as necessary to provide you our products and services and for legitimate and essential business purposes, such as maintaining the quality and performance of our products and services, making data-driven business decisions, complying with our legal obligations, and resolving disputes.
Upon your request, we will delete or anonymise your personal information so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal information, including situations such as the following:
- If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal information until the issue is resolved;
- Where we are required to retain the personal information for our legal, tax, audit, and accounting obligations, we will retain the necessary personal information for the period required by applicable law; and/or
- Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
Such request can be made by emailing us at [email protected].
Updates To This Policy
We may occasionally make changes to this Policy to changing legal, regulatory and operational requirements. When we make material changes to this Policy, we will notify our members appropriate under the circumstances, e.g., by displaying a prominent notice either digital or physical or by sending you an email.
Your continued use of Babel’s products and services after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. Therefore, we encourage you to read any such notice carefully.
How To Contact Us
B Fitness Asia Sdn. Bhd.
Lot 03-06, Level 3, Menara KEN,
Jalan Burhanuddin Helmi, Taman Tun Dr. Ismail,
60000 Kuala Lumpur, Malaysia.
Thank you for being part of the Babel family!
13 September 2018
(In the event of any conflict between the English and other language versions, the English version shall prevail)