1.              INTRODUCTION

1.1           Here in Tango.net.my and TANGO mobile app we respect your privacy as a visitor and/or user and we are committed to protect any information pertaining to any data and identity pursuant to the terms hereinafter appearing you may provide to us through these platforms. 

1.2           Please read this privacy policy (the “Policy”) carefully to understand how OVD Solutions Sdn Bhd, the owner and operator of Tango.net.my and the Tango mobile app (“TANGO”, “we”) uses personal information. By accessing or using www.tango.net.my, the Tango mobile app, or any other related sites, applications, services and goods that links to this policy (each, the “Site”), you acknowledge that you have read and understood this Policy. 

1.3           This Policy may change from time to time; any changes we make to this Policy will be posted on this Site, we will also take any other steps, to the extent required by applicable law, including notifying you about material changes. Changes to this Policy are effective as of the stated "Last Updated" date. 

1.4           We reserves the right to amend this Privacy Policy as and when it deems necessary. We recommend that you check the Policy periodically for any updates or changes.

1.5           You will be notified whenever there’s an update to the Privacy Policy. Your continuing use of our Website and/or mobile app following such amendments being placed on our Website represents an agreement by you to be bound by the Privacy Policy as amended. Such amendments may include replacing this Privacy Policy with an entirely new Privacy Policy.

1.6           Please discontinue using, surfing, browsing, relying, acting and/or in any manner utilising any of the services contained including but not limited to data, text, graphics, designs, logos, images, audio/visual materials, links and references in the Website if you disagree with any part of this Privacy Policy.

2.           INFORMATION(S)

2.1        Information We Collect: We collect information while you access, browse, view or otherwise use the Site. In other words, when you access the Site we collect personal information on your usage of the Site, including transactions and communications with other users through the Site, your searches, the pages you visited, as well as other actions on Site. We also, collect, use and process the information relating to such usage, including geo-location information, IP address, device and connection information, browser information and web-log information, and the URLs of the web pages you’ve viewed or engaged with before or after using the Site. We also collect and process information relating to the use of cookies and similar technologies, as detailed below. We use that information to provide you our services, enhance user experience, personalize your browsing experience as well as monitor the Site for preventing fraud and inappropriate content or behaviour. 

2.2        Information You Provide: When you register with us, use it, complete forms, participate in skills tests or surveys, or use the Site as collaborator, and/or register to our affiliate or partner or similar program, we ask you to provide certain personal information, including a valid email address, Facebook or Google account login details and username. We will also ask you to provide or otherwise collect additional information, such as, your name, profile details, physical address or billing information, telephone number or other contact details, transactional information, payment information (for example, in certain cases we process your payment method and credit card number), taxpayer information and forms, details about other social networks linked accounts, details about your listed gigs, purchases, education, profession and expertise, information and files uploaded by you to the Site, and additional authentication information (such as copies of your government issued ID, passport, or driving license, as permitted by applicable laws). We also collect information about or contained in your communications with Tango as well as any of your posts on our site and your communication with other users of Tango. Your privacy settings can be used to limit the publication of your information on our Website and mobile app and can be adjusted using privacy controls on the Website and mobile app. We will not, without your express consent, supply your personal information to party for the unintended purposes.

2.3        Information We Receive from Third Parties: We receive information from third party vendors and/or other commercially available sources, such as:

• Third party vendors who provide us data to supplement the information we collect about you, in accordance with applicable laws. 
• If you link, connect, or login to your account with a third-party service (e.g. Google, Facebook, etc.), we receive certain information, such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
• We also receive certain information about you, if you are invited to Tango by another user (for example, as part of our collaboration tools and partner program), in such case we will receive limited information, such as your email address or other contact information, and we will use it for the same purpose it was provided and in accordance with the terms of this Privacy Policy.

We combine your personal information with information we collect automatically or obtain from other companies and use it for the purposes detailed in this Policy. 

2.4           DISCLOSING PERSONAL INFORMATION

We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.

We share your personal information with third parties as detailed below: 

• With other users and Site visitors. Once you register, your username, country, and additional information regarding your activity is made public and is visible to all users of the Site. This information includes photos you upload, your published portfolio, Gig information, ratings, and additional information you may choose to add to your profile. We also offer you the opportunity to participate and post content publicly in forums, blogs and on other similar features. Please be aware that certain information, such as your user name and profile, together with the content uploaded by you, will be publicly displayed when you use such features. Your information will also be shared with other users when you message or otherwise communicate with such users. When you publish your information and/or share your data with other Tango users, you do so at your own risk. If you choose to share personal information with other users, including Sellers providing you a service via Tango, such personal information is shared with other users as separate controllers. While our Terms of Service require sellers, partners and affiliates of the Site to keep the information shared with them confidential, Tango cannot ensure that all users will do so and it is your responsibility to ensure that other users will comply with your standards. 
• With Service Providers. We share personal information for business purposes with service providers that provide us with services for the purpose of operating the Site, opening and operating your account as well as providing ancillary services and solutions. These include, among others, hosting services, billing and payment processors and vendors, CRM systems, forum hosting, community management services, data and cybersecurity services, web analytics and performance tools, translation tools, IT SaaS services, session recording, communication systems, mailing systems, data optimization and marketing services, data enrichment services, legal and financial advisors or technical consultants. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions; 
• For legal reasons. We share personal information with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of Tango, our customers, or the public; 
• For payments and fraud detection. We share personal information with payment processors, fraud detection agencies and similar third parties for the purpose of facilitating payments done via the Site and securing the Site and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; 
• With social media partners. Our Site includes certain social media features, including single sign on features. We also share limited personal information with such social media platforms and marketing partners, such as Facebook and Google, to promote our services or the Tango marketplace. Such features and third party services collect certain information about you and may set a cookie to enable their functionality. Such third parties’ features are governed by their policies. 
• With users with whom you interact. We share personal information to help facilitate interactions between users. For example, if you are a Buyer we may share certain limited information about you  with the Seller to ensure the services you receive from the Seller will fit your needs; such sharing of information is limited in scope, and is only intended to improve the services provided by the Seller and your user experience; 
• With our corporate affiliates. We share personal information with Tango’s corporate affiliates that are related by common control for the purpose of operating the Site, providing our services to you and for other purposes listed herein; and 

In the context of a corporate transaction. Personal information will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of Tango's assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets. 

External Links

Please note that the Site contains links to third party sites and if you navigate to a third party site from the Site, any data you provide to that site and any use of that data by the third party are not under the control of Tango and are not subject to this Policy. You should consult the privacy policies of each site you visit. This Policy applies solely to personal information collected by our Site. If you upload content, including personal information, to a social network and then tag the Site, your submission will be subject to that social network's terms of use and privacy policy, even where you post on an official Tango page on the social network. We do not have control over these terms of use and privacy policies and have not reviewed their adequacy. You should therefore review these before submitting any personal information.

3.           PURPOSE OF ACQUIRING AND PROCESSING YOUR PERSONAL DATA

3.1           We will use your personal information for the following purposes:

• to provide you with quality service and security, to operate the Site, to perform our obligations to you and to develop and improve our service. For example, we use personal information to verify your identity. We also use this information to establish and set up your account, verify or re-issue a password, log your activity, enable your communications with other members, provide customer support and contact you from time to time. The information helps us to develop and improve our services, to understand and analyse our performance as well as your preferences and performance and to customize and personalize our service and enhance your experience (including by making Gig suggestions, ranking search results, etc.). 
• to ensure marketplace integrity, prevent fraud and maintain a safe and secure marketplace and services. For example, we use personal information to monitor, track and prevent fraudulent activities and other inappropriate activities, monitor content integrity, verify or authenticate information provided by you, enforce our Terms of Service and comply with applicable laws. We conduct certain behavioural analytics to achieve the above objectives and in limited cases, if we detect activity that we think poses a risk to the Tango marketplace, other users, our community, or third parties, automated processes may restrict or limit your ability to use Tango. 
• to contact you, as requested by you or as otherwise approved by you or permitted according to this Policy. 
• to promote and advertise the Site, our services and the Tango marketplace. For example, we use the information collected from you for the purpose of sending direct marketing messages (as detailed below), to show you information that may be of interest to you, to organize and facilitate referral programs, contests or other promotional activities or events. 
• to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.

3.2           We will ask for your consent before using information for a purpose other than those set out in this Policy.

3.3            Direct marketing:

• We shall use your personal information to send you direct marketing communications about our products, services or promotions from Tango marketplace that may be of interest to you or our related services. This may be via email, post, SMS, telephone or targeted online advertisements. Our processing of your personal information for marketing purposes is based on our legitimate interest, or on your consent, or as otherwise permitted according to applicable laws. You have a right to prevent direct marketing of any form at any time by following the opt-out link attached to each communication. We take steps to limit direct marketing to a reasonable and proportionate level, and we shall send you any information and/or communications which we believe may be of interest or relevance to you, based on the information we have about you.

4.           CONSEQUENCES OF NOT CONSENTING TO THIS PRIVACY POLICY/NOT PROVIDING YOUR PERSONAL DATA 

The collection of your personal data by us may be mandatory or voluntary in nature depending on the Purposes for which your personal data is collected. Where it is mandatory for you to provide us with your personal data, and you fail or choose not to provide us with such data, or do not consent to the above or this Privacy Policy, we will not be able to provide our Platform and/or Service to you.

5.           HOW LONG DO WE KEEP PERSONAL INFORMATION?

We apply a general rule of keeping personal information only for as long as is required to fulfil the purpose for which it was collected. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes:

• as long as it is necessary and relevant for our operations, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and 
• in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Site terms and take other actions as permitted by law.

6.           SECURITY

We implement technical and organizational measures to maintain the security of the Site, our services and personal information and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. In addition, we contractually ensure that any third party processing your personal information equally provides for confidentiality and integrity of your data in a secure way. However, the transmission of data via the internet is not completely secure, and although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Site. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access. Users who have registered to the Site agree to keep their password in strict confidence and not disclose such password to any third party. Further information about our data security practices can be provided on request.

7.           UPDATING PERSONAL INFORMATION

We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately. We will make sure we investigate the matter and we shall rectify and correct any inaccuracies as quickly as possible where necessary or give you ways to update it quickly or to delete it - unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we will ask you to verify your identity before we can act on your request. If for any reason you have a problem with deleting your personal information, please contact Tango's Customer Support and we will make reasonable efforts to delete any such information pursuant to any applicable privacy laws. 

You can review and change your personal information by logging into the Site and visiting your account profile page. You may correct, update or delete your personal data at any time by editing your profile on the “Account Settings” page on the Platform. However, please note that your personal data may be retained on our back-up systems for some time. In addition, you cannot delete information associated with past transactions as we keep track of these records.

8.           CHILDREN AND OTHER INDIVIDUALS 

To the extent that you have provided (or will provide) personal data about your family members, spouse, other dependents (if you are an individual), directors, shareholders, employees, representatives, agents (if you are a corporate, an entity or an organisation) and/or other individuals, you confirm that you have explained to them that their personal data will be provided to, and processed by, us and you represent and warrant that you have obtained their consent to the processing (including disclosure and transfer) of their personal data in accordance with this Privacy Policy.

In respect of children (i.e. individuals under the age of 18 or the legal age for giving consent pursuant to the applicable laws in your country) or individuals not legally competent to give consent, you confirm that you are the parent or legal guardian or person who has parental responsibility over them or the person appointed by court to manage their affairs or that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their personal data in accordance with this Privacy Policy.

9.           INTERNET AND MOBILE APPLICATION USE

You acknowledge that the provision of your personal data to us over the Internet is entirely at your own risk.

You further acknowledge that if you post your rating and/or review on the Platform, your rating and/or review will become a public information and will be retained by us even after your account has been terminated. Your email address and phone number will not be visible to others through any rating and/or review that you post.

If any part of the Platform links you to other websites, those websites do not operate under this Privacy Policy and we do not accept any responsibility or liability arising from those websites. We suggest you to read and understand those websites’ privacy policy before you provide your personal data to those websites.

We use cookies (an alphanumeric identifier that we transfer to your computer’s or mobile device’s hard drive so that we can recognise your web browser or mobile device, track your visits to the Platform or remember your username and/or password each time log-in) to monitor your use of the Platform. All such demographic data collected through cookies are not personal data and we may use this data in aggregated, statistical and/or anonymised form. You may disable cookies by changing the settings on your web browser or mobile device, although this may mean that certain features on the Platform will not function properly if you set your web browser or mobile device to not accept cookies.

In addition to using cookies and related technologies as described above, we may also permit certain third party companies to help us tailor advertising that we think may be of interest to users and use other data about user activities on our Platform and/or Service (e.g., to allow them to tailor ads on third party services). These companies may deliver ads that might also place cookies and otherwise track user behaviour.

Please note that when you first install our mobile application on your mobile device, we will set up an account associated with that mobile device (“Account”). We will collect and use your personal data, in accordance with this Privacy Policy, whenever you activate our mobile application on that mobile device. This use includes linking your personal data with your Account. Most mobile platforms (iOS, Android, etc) have different permission systems for obtaining your consent. The iOS platform will alert you the first time our mobile application wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that our mobile application seeks before you first use the mobile application, and your use constitutes your consent.

The Platform may integrate with social sharing features and other related tools which allow you to share information with your friends or the public, depending on the settings you establish with the social sharing network. The social sharing network’s use of your personal data made available by Tango is governed by that social sharing network’s privacy policy, not by this Privacy Policy. By connecting your social sharing network account through the Platform, you agree that we may collect your personal data from your social sharing network account only in accordance with your privacy settings you have set up under your social sharing network account and for the Purposes provided under this Privacy Policy.

We may automatically receive, record and store location services information from your computer or mobile device when you interact with us. You hereby consent to our use of anonymised location services information collected from you. Where the location services information is personally identifiable, we will give you the options to manage your disclosure of this information. Depending on the functionalities available on your computer or mobile device, you may benefit from advanced options to manage the location services information. A computer or mobile device may report its GPS location at the time you interact with us if the location services settings are enabled. Such information is not identified as personal data, except where we are required to do otherwise under applicable law.

Our collection of your computer or mobile device location information is solely at your discretion. You can enable or disable location services when you use the Platform at any time, through your computer or mobile device settings. Should you use the Platform with location services enabled, you consent to our collection and dissemination of your computer or mobile device location information through the Platform, as specified in this Privacy Policy. Under no circumstances shall we be liable for claims or for any damages therefrom, arising out of your informed decision to allow other users to see your computer or mobile device location information, as specified in this Privacy Policy.

10.        TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF YOUR COUNTRY 

Our information technology storage facilities and servers may be located in other countries outside of your country. This may include, but not limited to, instances where your personal data may be stored on servers located outside of your country. In addition, your personal data may be disclosed or transferred to entities located outside your country. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in your country under the applicable laws in your country. You hereby expressly consent to us transferring your personal data outside of your country for such purpose.

Contact Us

If you have any questions about this Privacy Policy, or have any further queries, or would like to make a complaint or data access, correction or limitation request in respect of your personal data, you may do so by:

1. adjusting the settings in your account maintained with us; or
2. contacting us via the communication channel on the Platform; or
3. contacting us at privacy@tango.net.my

English Version to Prevail 

In the event of any inconsistencies or discrepancies between the English version and other translated versions of this Privacy Policy, the English version shall prevail.

Last updated on        10 April 2022.