Privacy Policy

Controller and Processor

In Awarala Inc we control and process the information that you provide to us with the purposes of managing specific services requested by the data subject or complying with legal obligations. The personal data provided shall be stored for the period necessary for managing the requested service, and subsequently, they shall be stored, but locked, for as long as necessary to formulate, exercise and defend any claims arising from the data processing.

Data shall not be disclosed to third-party recipients.. Data subjects may exercise their rights of objection, access, portability, rectification, restriction of processing and erasure in respect of their data at any time contacting our registered office:

Awarala Inc (LL17750)
Suite 17, Unit 2-13, Level 2,
Labuan Times Square,
Jalan Merdeka,
87000 Federal Territory of Labuan, Malaysia

or sending an email to [email protected] along with your request and supplying in all cases their identity card or official document accrediting the identity of the data subject.

Notwithstanding any administrative appeal or legal action that may arise, data subjects may submit their claim to the Personal Data Protection Department (PDPD), especially where they have been unsuccessful in exercising their rights, via the website

Master Privacy Policy and Express Consent

1. Preamble

This Master Privacy Policy (“Privacy Policy”) explains the collection, use, processing, transferring and disclosure of “personal information” by Awarala Inc (“Awarala”), and also contains an Express Consent that applies to those who use our Websites and Services (as defined below). This Privacy Policy is incorporated into and made part of Awarala Master Terms of Use (“Master Terms”) located at

Unless otherwise noted on a particular website or service hosted by Awarala, this Privacy Policy applies to your use of all websites that Awarala operates. These include and, together with all other subdomains thereof (the “Awarala Website”), (collectively, the “Websites”), as well as the products, information, and services provided through the Websites.

This Privacy Policy also explains our commitment to you with respect to our use, processing, transfer and disclosure of non personal browsing and site usage data that Awarala collects as the provider of the Services. “Non personal browsing and site usage data” refers to information that Awarala collects indirectly and automatically about your activities while visiting the Websites and using the Services through tools such as Google Analytics. The type of information that we collect focuses on general information such as general location such as country or city where you are located (not intentionally fine-grained location information), pages visited, heat-map of visitors’ activity on the site, information about the browser you are using, etc. In addition, whenever you use an Awarala Login Service to log into a Website or use the Services, our servers (which, again, may be hosted by a third party service provider) keep a plain text log of the websites you visit and when you visit them. Awarala does not deliberately track people over the Internet. See section 11, below for more information about this.

As used in this policy, “personal information” means information that would allow a party to identify you such as, for example, your name, address or location, telephone number, or email address or information from which a person could deduce your identity.

By accessing or using any of the Services, you are accepting and agreeing to the practices described in this Privacy Policy.

2. Our Principles

Awarala is committed to handling responsibly the personal information and data we collect and process about you through our Services, whether personal information or non personal browsing and site usage data. We have designed our Privacy Policy consistent with the following principles (the “Principles”):

Privacy policies including provisions regarding data collection, processing and use, should be human readable, comprehensive, and easy to locate;
Only the minimum amount of personal information reasonably necessary to provide you with services should be processed, collected and maintained, and only for so long as reasonably needed or required, consistent with the principles of proportionality; and
Personal information you provide through our Services, or that we gather as a result of your use of our Services, should not be used for marketing or advertising purposes, nor should it be provided voluntarily (without your permission) to anyone else unless required.

3. Personal Information Awarala Collects

We may collect and process personal information through our Services, including without limitation:

  • when you provide us with your personal information such as by sending an email to us or signing up to receive updates from Awarala;
  • when you subscribe to one of our email discussion lists;
  • when you create an Awarala Login Service account;
  • when you provide personal information in connection with your participation in any of the forums we make available through our Services.

4. What Awarala Does with Personal Information

Emails and Newsletters . We use the personal information you provide to us when you send us emails or sign up to receive updates from Awarala in order to respond to your request – for example, to reply to your email or to send you communications about Awarala news and campaigns.

When you subscribe to updates from us, your email address is sent to and stored in a Customer Relationship Management (CRM) database (such as MailChimp, or Zoho) hosted on servers that can only be accessed by Awarala staff and contractors. Awarala may change CRM system(s) from time to time. When you subscribe to one of our email discussion lists, your name and email address is sent to and stored by (1) Awarala, and/or (2) another service with which  Awarala has engaged to provide email support (such as a CRM system as mentioned above). Personal information submitted as part of our email discussion lists is used for the purpose of managing the discussion lists. Your name and email address typically will be visible to other list participants when you correspond on the list and to the general public in the discussion archives. All emails sent to the discussions lists are publicly archived.

5. Disclosures of Personal Information

In general, it is not Awarala practice to disclose personal information to third parties other than as made available on the Services.

Awarala may share personal information with our contractors and service providers in order to maintain, enhance, or add to the functionality of the Services.

6. Security of Personal Information Collected via the Services

Awarala has implemented reasonable physical, technical, and organizational security measures for personal information that Awarala processes, transfers, stores and controls against accidental or unlawful destruction, or accidental loss, alteration, unauthorized disclosure or access, in compliance with applicable law. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. If any data breach occurs, we will post a reasonably prominent notice to the Websites and comply with all other applicable data privacy requirements including, when required, personal notice to you if you have provided and we have maintained an email address for you.

The Awarala Login Services account systems have security risks in addition to those described above. Among other things, they are vulnerable to DNS attacks, and using any Awarala Login Service may increase the risk of phishing. See “More about Awarala Login Services” below and other information about those services throughout this Privacy Policy.

7. Information from Cookies and Similar Technologies

We and our service providers (for example, Google Analytics as described in section 1 above) may collect information using cookies or similar technologies for the purposes described above and below. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device. Cookies may enable us to personalize your experience on the Services, maintain a persistent session, passively collect demographic information about your computer, and monitor advertisements and other activities. The Websites may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).

8. Non Personal Browsing and Site Usage Information We Process and Collect

When you use the Services, our servers (which may be hosted by a third party service provider) may process and collect information indirectly and automatically (through, for example, the use of your “IP address”) about your activities while visiting the Websites and using our Services, and information about the country you are located in and the browser you are using. In addition, we use website and application analytics services provided by third parties that use cookies and other similar technologies to collect information about the use of the Websites and Services, and to report trends, without identifying individual visitors (this is all “non personal browsing and site usage information” for purposes of this Privacy Policy and as described in section 1, above). The third parties that provide us with these services may also collect information about your use of third-party websites. You can learn about Google’s practices in connection with this information collection and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at Whenever you use an Awarala Login Service, our servers (which, again, may be hosted by a third party service provider) keep a log of the websites you visit and when you visit them. We may share the non personal browsing information we collect with our third party service providers in connection with the services they provide.

9. No Linking

We do not intentionally link browsing information or information from our Awarala Login Services server logs to the personal information you submit to us. We use this information for internal purposes only, such as to help understand how the Services are being used, to improve our Services, and for systems administration purposes. Awarala may use a third party analytics provider (for example, Google Analytics as discussed in section 1 above) to help us collect and analyze non personal browsing and site usage information through operation of our Services for those same purposes.

In connection with your use of the Services, you may tag content, create lists of favorite content, and do other things to personalize your experience. You should not, however, tag other persons or post photographs or other images or likenesses without that other person’s express consent. This information will be retained by Awarala in connection with the relevant Awarala Login Service.

10. No Selling or Sharing

Except in the unique situations identified in this Privacy Policy,  Awarala does not sell or otherwise voluntarily provide the non personal browsing information we collect and process about you or your website usage to third parties.

11. Data Retention

Awarala generally discards non personal browsing information from our Awarala Login Services and website once we have used the information for the limited purposes noted above under “No Linking” and described elsewhere in this Privacy Policy. Nevertheless, we may, but are not obligated to, retain certain data in connection with routine information technology backups and for archival purposes.

12. Notice

Any other non-personal information that we collect which is not described specifically in this Privacy Policy will only be collected, processed, transferred and used in accordance with the Principles.

13. Reorganization or Spin-Offs

Awarala may transfer some or all of your personal and/or non personal browsing information to a third party as a result of a reorganization, spin-off, or similar transaction. Upon such transfer, the acquirer’s privacy policy will apply. In such event, Awarala will use reasonable efforts to notify you and to ensure that at the time of the transaction the acquirer’s privacy policy complies with the Principles and with all applicable laws.

14. Children

Awarala services are not targeted to children.

15. Third-Party Sites

The Services may include links to other websites. You should consult the respective privacy policies of these third-party sites. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.

16. Special Note to International Users

If you are accessing or using the Services in regions with laws governing data collection, processing, transfer and use, please note that we may transfer your information to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. The Services are hosted in America, Europe and Asia. Please note that your personal information may be located on servers in the America, Europe and Asia. By providing your personal information or otherwise access and use our Services or Websites, you expressly consent to the use of your personal information for the uses identified above in accordance with the Privacy Policy.

Data transferred from the European Union to the United States or outside the European Union will be made on the grounds of a certification to the E.U./U.S. Privacy Shield regime and/or a data transfer agreement based on the Standard Contractual Clauses approved of by the European Commission respectively, consistent with applicable data privacy requirements.

17. Accuracy of Personal Information Collected

Awarala intends to keep personal information accurate and up-to-date. We also retain personal information no longer than is necessary to carry out the purposes described in section 3 above, or as required by law. If changes need to be made to your personal information, please notify us (as identified below, see the “Questions” section) right away. If you inform us of changes or we otherwise become aware of any factual inaccuracies in personal information, we will promptly make changes as appropriate. You also have the option to update some of your personal information yourself via your Awarala account or profile if you have one.

18. Access to Personal Information

Along with all other rights granted to you under applicable laws, you may at any time request to be informed of personal information that Awarala holds. If you wish to access such personal information, you should apply in writing to Awrala (as identified below, see the “Questions” section). You are generally entitled to access personal information that Awarala holds and to have inaccurate data corrected or removed to the extent Awarala still maintains it. In certain circumstances, you also may have the right to object for legitimate reasons to the processing or transfer of personal information.

19. Changes and Updates to this Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will provide you with notice of such update through (at a minimum) a reasonably prominent notice on the Websites and Services, and will revise the Effective Date below. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting, using, processing and transferring the personal information we collect.

20. About this Privacy Policy

This private policy has been adapted from Creative Commons Privacy Policy and the recommendations from European Data Protection Agencies.

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