DXN PRIVACY NOTICE FOR DXN DISTRIBUTORS (EUROPE)

This Privacy Notice describes how DXN Marketing Sdn. Bhd. (“DXN” or “we” or “us”) use personal data collected or received from DXN Distributors (“Distributor” or “you”). 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 DXN Distributors in various ways, such as:

Registration: DXN collects your personal data through the registration form that you complete and send to us in paper form or electronically in order to become an DXN Distributors.

Logged in as DXN Distributors: If you are logged in on the DXN e-World as an DXN Distributors, we collect personal data that you provide to us while using the Website. For example, when you purchase products or services, we collect personal data.

Contacting Us:  When you contact us through the various communication channels provided on the “Contact Us” webpage of the Website, we collect personal data and other information that you provide. 

 

The Types of Personal Data We Process

We process the following types of personal data relating to you:

Data Type	Purpose
Contact information (e.g., name, postal or email address, social media handle, fax number and phone number);	Contractual necessity:  DXN Distributor contractual obligation
Distributors organisational information (e.g., the name of the company associated with your DXN distributorship, profession and ownership and management details);	Contractual necessity:  DXN Distributor contractual obligation
Demographics information such as gender, age, nationality, profession, date and place of birth. DXN distributorship is available only to individuals aged 18 and above	Legal obligation and Contractual necessity:  DXN Distributor contractual obligation
Marital status and beneficiary details (e.g., full name, address, and nature of relationship);	Legal obligation and Contractual necessity:  DXN Distributor contractual obligation
DXN Distributors details and login or access credentials (such as DXN e-World ID and password)	Contractual necessity and Legitimate interests:  DXN Distributors performance management
National identifiers, such as passport or ID card (including number, issue date, issue location, and expiration date), tax number or social security number to the extent permitted or required by applicable law or if necessary for the performance of a contractual obligation	Legal obligation:  Know Your Customer (KYC), Anti-Money Laundering (AML)
Payment information (e.g., bank account, debit or credit card numbers, payment service providers);	Contractual necessity and Legal obligation:  DXN Distributors performance management
DXN Distributors performance information (e.g., class, status, group and personal qualifications under the DXN Sales and Marketing Plan and DXN bonus history);	Contractual necessity and Legitimate interests:  DXN Distributors performance management
Product preferences, purchasing habits, purchasing history, and spending behaviour;	Contractual necessity and Legitimate interests: DXN Distributors performance management
Communication preferences	Consent:  DXN Distributors performance management

We may process other personal data under 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 only process your personal data to the extent it is necessary:

1. For the performance of your agreement with us or in order to take steps at your request prior to entering into an agreement with us, including to:

• Manage your relationship with us as a DXN Distributors from initial registration and throughout your time as a DXN Distributors;
• Create and manage your (online) account;
• Address your comments or enquiries;
• Process your orders of products or services;
• Fulfil our obligation to provide business and product support to you;
• Communicate with you about products or services that we offer, or intend to offer;
• Assess your performance under your DXN Distributorship;
• Provide business performance information to you;
• Provide your contact information, business identification information, and business performance information to related party/ies within the DXN Distributors in order to support your business with DXN;
• Perform accounting, auditing, billing, and collection activities; and
• Enforce contractual terms and conditions, including, without limitation, the applicable DXN Distributorship Rules and Regulations.

 

2. To comply with our legal obligations, including to:

• Comply with laws which require us to retain records; and
• Comply with any other laws which may be applicable to us.

 

3. For the purpose of our legitimate interests, including to:

• Operate, evaluate, and improve our products, business, and services, including by:
  • Tracking and analysing your use of products, materials, and/or services;
  • De-identifying your personal data in order to carry out analysis on information which does not identify you; and
  • Developing new products and services;
• Track, document, and evaluate participation in DXN trainings, meetings, and events;
• Prevent and protect you, us, and others against fraud, unauthorised transactions, claims, and other liabilities;
• Ensure compliance with company policies and industry standards; and
• Process personal data for internal administrative purposes.

When we process your personal data for these purposes, we have carefully balanced our organisation’s legitimate interests against your data protection rights. You can obtain further information by contacting us at pdpa@dxn2u.com

 

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:

• Other DXN Distributors in order to support your business with DXN;
• Providers of infrastructure- or platform- or software-as-a-service solutions, software development services, information system maintenance services, record management services or marketing services;
• Logistics providers;
• Financial transactions service providers; and
• 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

Your personal data may be transferred to and processed by other entities within the DXN organisation, as well as by trusted third-party service providers acting on our behalf. Some of these recipients are located outside the country where your personal data was originally collected, including in countries that may not provide the same level of data protection as your home country.

Where such transfers occur, we ensure that appropriate safeguards are in place to protect your personal data, in line with applicable data protection laws. These safeguards may include the use of standard contractual clauses (SCCs) approved by the European Commission, reliance on an adequacy decision by the European Commission (where applicable), or other legally recognized mechanisms.

Regardless of where your personal data is processed, we will handle it 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 our contact details provided below if you have any questions with respect to our data retention practices.

We retain your personal data for the duration of your distributorship with DXN. In the event of the termination of your distributorship due to your passing, DXN will retain your personal data for as long as necessary to administer the transfer of rights and benefits to your designated beneficiary(ies), in accordance with the applicable DXN Distributorship Rules and legal requirements.

Once the transfer process is completed, we will retain only those records required for legal, accounting, or contractual purposes (typically up to 7 years after closure of the distributorship account), while your beneficiary’s personal data will be processed as part of their continuing relationship with DXN.

 

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.

 

• Right to Contest

DXN uses an automated system to calculate bonuses. If you believe a decision regarding your bonus is incorrect, you may submit a request for review, share your views, or appeal the calculation within seven (7) days from the date of receipt of the monthly bonus statement.

 

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 the Data Protection Officer, Ms. Sayidatina via email to pdpa@dxn2u.com or by letter to:

 

Ms. Sayidatina 

Data Protection Officer

DXN Holdings Bhd.

DXN Cyberville
 Jalan Teknokrat 1, Cyber 3, 63000 Cyberjaya,

Selangor, Malaysia.

Attention: Legal & Compliance Department