PRIVACY POLICY
Thank you for visiting our website (“Site”). Axcelearn Sdn. Bhd. (“Axcelearn” or the “Company”) is committed to treating the personal and corporate information of our Site users, customers, and vendors with respect and sensitivity.
We’ve updated our Privacy Policy and improved our privacy practices so we can better safeguard your data. This Site also uses cookies to personalize your experience and target advertising. By continuing to use our Site, you accept the terms of this Privacy Policy, our Terms of Use, and our Cookies Policy. To learn how to opt out of our use of Cookies on this Site, click here, but please note that if you disable cookies, you may not be able to use all the features of our site.
This Privacy Policy (together with our Terms of Use and any other policies referenced) identifies how we will collect and process any personally identifiable information, such as your name, email, address, financial account information, etc., that we collect from you, or that you provide to us.
If you are a Malaysia resident, our privacy practices comply with the Personal Data Protection Act 2010 (“PDPA”), and any PDPA-specific information is identified in this Policy. Explanation of your rights under the PDPA can be found here.
As our services evolve and we perceive the need or desirability of using your personal data collected in other ways, we may from time to time amend this Privacy Policy. The effective date appears at the end of this Privacy Policy. We encourage you to check our Site frequently to review the current Privacy Policy in effect and any changes that may have been made to it.
By providing your Personal Data to us in any format (e.g., via email, telephone, fax, or in person) and/or continuing to use any of our services or visiting our Site you accept and consent to the practices described in this Privacy Policy Notice.
- Introduction
- What Personal Information does the Company collect?
- How does the Company use Personal Information?
- Do we share your Personal Information with any third parties?
- Our storage of your Personal Data
- Access to other websites
- Protecting children’s privacy
- PDPA Privacy Laws
- Conditions of use and changes to our Privacy Policy
- Contacting us
1. INTRODUCTION
This Privacy Policy describes how the Company collects, uses, and shares information about visitors to our website at www.tonyrobbins.com, attendees of our programs, individuals who contact us to purchase materials or request information, and other users of our services. The Website and our other programs and services are the “Services.” This Policy describes how we obtain and use personal data (which can be used to identify a specific individual) and anonymous data (which cannot).
Children. The Services of Axcelearn Sdn. Bhd. are not directed to children. If you become aware that a child (based on the jurisdiction where the child lives, which in Malaysia means someone under the age of 18) has provided us with Personal data without parental consent, contact us at the location identified below in the Contact Us section.
2.WHAT PERSONAL DATA DOES THE COMPANY COLLECT?
We collect personal information that you enter on our Site or otherwise volunteer to us when you contact us to, among other things, make purchases, request information, or register for or attend our programs. You can choose not to provide certain information, but then you might not be able to take advantage of many of our features.
For purposes of this Policy, “Personal Data” means information (whether stored electronically or in paper based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession).
Personal Data which includes:
- Identifiers: Name, address, email, phone, driver’s license
- Other Data: Financial information, medical information, health insurance information
- Protected Classes: Race, gender, sexual orientation, religion
- Commercial Information: Records of personal property, purchasing or consuming histories or tendencies
- Biometric Information: Fingerprints, retina scans, face prints
- Internet Activity: Browsing history, search history, IP address, website interactions
- Geolocation Data: GPS coordinates, location history
- Sensory Data: Audio, electronic, visual, thermal, olfactory
- Professional Data: CV, resume, employment history
- Education Data: Educational background, grades, scores
- Inferences: Drawn the above categories, such as preferences, characteristics, attitudes, predispositions, abilities, aptitudes, intelligence, psychological traits
The examples given in this table are not meant to provide an exhaustive list, but are examples of the kinds of data included in each category. Axcelearn does not collect Personal Information in every one of these categories, and we identify below which categories we collect.
Axcelearn collects only that Personal Data that is relevant for the purposes for which the data is requested. Axcelearn does not use your Personal Data in any way that is incompatible with the purposes for which it was collected or for which you have consented.
INFORMATION YOU GIVE US
When you contact us through our Site, or by corresponding with us by phone, e-mail, or otherwise, or attend an Axcelearn event, we may collect Personal Data including:
- Identifiers: Name, address, email, and phone; for current or prospective affiliates, suppliers, and subcontractors, personal information such as Malaysian identity card number (MyID), or other relevant information, as applicable
- Other Data: Credit card and account information collected when you purchase products or services; medical and health data (e.g., as necessary when participating in some of our live events); self-assessment data and results, such as information you input when taking self-assessment quizzes, DISC assessment tests, and the like;
- Protected Classes: Gender, sexual orientation, race, and date of birth;
- Professional Data: For those considering careers with Axcelearn, professional data and education information such as resumé or C.V., salary history, education history, citizenship information, and position sought, as applicable; [When considering an individual for employment, additional Personal Data may be collected, as set forth in our Employee Privacy Policy];
- Education Information: As needed for participation in programs and live events;
- Inferences: Personal information about your goals and aspirations for our products, services, and live events, or inferences derived from that information.
- We do not collect or receive Biometric Information or Sensory Data.
INFORMATION WE COLLECT AUTOMATICALLY
Internet Activity: When you visit our Site, our web server automatically collects and stores the following information:
- The Internet protocol (IP) address used to connect your computer to the Internet, referring website address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages on our Site you viewed; page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number;
- Our Site uses cookies and pixel tags to collect this information.
These information helps us improve our Site and facilitates your online experience when accessing our Site.
INFORMATION WE RECEIVE FROM OTHER SOURCES
This is information we receive about you from third parties who operate other Sites or services we use in order to provide our products and services to you. We work closely with third parties, including, for example, business partners, promoters, affiliates, and sub-contractors in technical, payment and delivery services, advertising networks, marketing analytics providers, promotions, and search information providers. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
COOKIES
Our Site uses cookies to personalize your experience and target advertising, and we recommend you review our Cookies Policy.
3. HOW DOES THE COMPANY USE PERSONAL INFORMATION?
INFORMATION YOU GIVE US
We will use this information:
- to provide you with the Services that you request from us;
- to carry out our obligations arising from any contracts entered into between you and us, or between you and our promoters, affiliates, or distributors;
- to contact you in the future to provide you with information about other products and services we offer, or that are offered by our affiliates or third party vendors;
- to notify you about changes to our Services;
- to comply with applicable laws and regulations;
- to assess your suitability for participation in our live events, and to determine additional Axcelearn materials, services, or events to recommend and market to you;
- for training purposes, quality assurance, and to record details about the products and services you order from us;
- to make inquiries about you for credit reference purposes;
- to perform data analyses (including anonymization and aggregation of Personal Information);
- for prospective employees, to respond to and process your job application and CV.
INFORMATION WE COLLECT ABOUT YOU
We will use this information:
- to provide targeted advertising and marketing services;
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep our site safe and secure.
INFORMATION WE RECEIVE FROM OTHER SOURCES
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
4. DO WE SHARE YOUR PERSONAL INFORMATION WITH ANY THIRD PARTIES?
Axcelearn does not sell your Personal Data to any third parties. To provide the Services, we sometimes disclose Personal Data to service providers for business purposes. Sometimes we disclose your Personal Data to those third parties, and they sometimes collect your Personal Data in the first instance and provide it to us.
Our service providers are contractually obligated to comply with all applicable laws (e.g., the PDPA), and all such third parties use your Personal Data only on behalf of Axcelearn and under the instructions of Axcelearn on how your information may be used and processed. Axcelearn and our partners will use your Personal Data for limited purposes as specified in this Policy. Axcelearn takes reasonable steps to ensure these third parties use your Personal Data only for the purposes for which they have been engaged by Axcelearn, that they do not share or sell your Personal Data to anyone else.
By enjoying our Services and sharing your Personal Data, you agree that we have the right to share the categories of Personal Information we collect for the following business purposes:
- Sales – for the purpose of fulfilling requests from you to purchase goods and services from our Site or at our events;
- Targeted advertising – to provide advertising of Axcelearn’s programs and services on other Sites and platforms;
- Marketing – for the purpose of direct marketing of goods and services offered by Axcelearn and our affiliates that you may be interested in;
- Self-Assessment testing – for administering and providing self-assessment testing services, including the DISC assessment test;
- Cloud services – for provision of cloud storage services;
- Contractual performance – for the performance of any contract we enter into with you, or they enter with you on behalf of Axcelearn;
- Web analytics — analytics and search engine service providers that assist us in the improvement and optimization of our site;
- Medical assessment – for the analysis of medical and health information you submit to determine if you are an appropriate participant in our live events.
We may also disclose your personal information to third parties in the following circumstances:
- In the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets as part of the purchase, transfer, or sale of services or assets;
- If we sell all or substantially all of our assets to a third party, in which case personal information about our customers will be one of the transferred assets;
- If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or any lawful request by public authorities (including to meet national security or law enforcement requirements), or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us, our customers, or others.
Whenever we share information with third parties, we will take steps to ensure that the third parties put in place adequate measures to safeguard your Personal Information, and they will be required to use any Personal Information for only the intended purpose for which it was shared.
5. OUR STORAGE OF YOUR PERSONAL INFORMATION
Axcelearn uses reasonable and appropriate measures to protect your Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Data we collect.
We will keep your personal data for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example if you have made a complaint about a product) for as long as is necessary to protect us from a legal claim.
You may unsubscribe from any of our online e-mail updates and marketing by following the unsubscribe instructions in the body of any e-mail message we have sent to you. We will take commercially reasonable steps to implement your unsubscribe requests promptly, but you may still receive promotional information form us by mail for up to 60 days, and up to 10 days for e-mail. You may also continue to receive information from those third parties to whom we have previously disclosed your Personal Data.
Please note that when you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
6. ACCESS TO OTHER WEBSITES
Our Site may include links to and from other websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites are not covered by this Privacy Policy. We are not responsible for the privacy practices of any third parties or the content of linked sites although we do encourage you to read the applicable privacy policies and terms and conditions of such parties or websites. This Privacy Policy only applies to how Axcelearn deals with your Personal Data, and it does not apply to any other company or any other company’s websites even if you access them via our Site. Please check those websites’ policies before you submit any Personal Data to them.
7. PROTECTING CHILDREN’S PRIVACY
We are strongly committed to protecting the safety and privacy of children who visit our Site. Our Site is not designed nor is it intended to be used by children under 18, and we do not knowingly collect personal information online from children under 18 and have adopted techniques to ensure compliance with this Privacy Policy. Our Site includes content that we believe to be unsuitable for children under 18, and we encourage all parents to talk to their children about online safety and to monitor their children’s use of the Internet.
8. PDPA PRIVACY LAWS
The Personal Data Protection Act 2010 (“PDPA”) is an Act that regulates the processing of personal data in regards to commercial transactions in Malaysia.
8.1 DEFINITIONS
The following additional definitions apply to this section of the Privacy Policy:
“Controller” means the Company which is the organization that determines the purposes for which, and the manner in which, any Personal Data is Processed and used in its business.
“Processor” means any Person Processing Personal Data.
“Person” means a natural person, corporation, association, organization, partnership, or other legal entity.
“Processing” is any activity that involves use of the Personal Data. It includes, without limitation, obtaining, recording or holding the Personal Data, or carrying out any operation or set of operations on the Personal Data including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Data to third parties.
8.2 THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
In order to comply with the PDPA, we are required to set out the legal basis for the processing of your Personal Data. In accordance with the purposes for which we collect and use your Personal Data, as set out above, the legal basis for processing your Personal Data will typically be one of the following:
- our own legitimate business interests, or the legitimate business interests of our third party partners, promoters, affiliates, distributors, suppliers, vendors, and subcontractors, such as, for example, providing direct marketing to our customers of our products and services that we think would be of interest, permitting prospective employees to search and apply for job opportunities, handling inquiries from our promoters, affiliates, distributors, vendors, and customers, or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest;
- the performance of a contract that we have in place with you;
- your consent where appropriate; or
- compliance with our legal obligations, including to meet national security or law enforcement requirements.
8.3 WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you is stored on our servers or on servers provided by cloud service providers. By submitting your Personal Data, you agree to this transfer, storing, and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
8.4 ADDENDUM TO HOW LONG WE STORE YOUR PERSONAL DATA
In some cases, there is a legal requirement to keep Personal Data for a minimum period of time. Except in those circumstances, we do not keep your Personal Data for any longer than is necessary for the purposes for which the Personal Data was collected or for which it is to be further processed.
8.5 YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA
Subject to certain exceptions, you have the following rights with respect to your Personal Data:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
All of these rights are subject to certain conditions and exemptions. For example, Axcelearn will not be obligated to erase your Personal Data if we need to retain it to protect ourselves in the event of a legal claim.
To exercise any of these rights, please submit a written request to us using the contact information set forth below. The Company reserves the right to charge a fee in dealing with such a request as permitted by applicable law and regulations. You may also opt out of receiving additional marketing information by using the unsubscribe feature in any marketing email we send you.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. CONDITIONS OF USE AND CHANGES TO OUR PRIVACY POLICY
If you choose to visit our Site and attend our events, your visit and any dispute over privacy is subject to this Notice and our Terms of Use, including limitations on damages, resolution of disputes, and application of the law of Malaysia.
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices or relevant laws. We will indicate at the end of this Privacy Policy when it was last updated.
If you have any concern about our privacy practices, please contact us with a thorough description, and we will try to resolve it. As our business changes, our Privacy Policy and Terms of Use may change also. We may e-mail periodic reminders of our notices and conditions, but you should check our Site frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.
10. CONTACTING US
This Site is owned and operated by Axcelearn. If you have any questions or suggestions with respect to this Privacy Policy or our privacy practices, please e-mail us at [email protected], or you can contact us by mail at:
Axcelearn Sdn. Bhd.
D-15-01, Menara Suezcap 1, KL Gateway,
No. 2, Jalan Kerinchi Lestari,
Bangsar South,
59200 KL.
ADDITIONAL INFORMATION
PHOTOS AND FILMING AT AXCELEARN
If you attend an Axcelearn event or visit Axcelearn premises on a photo or video shooting day, you may be captured in photos and/or videos (“footage”). As the context requires, Axcelearn is the data controller of the footage. We may use the footage to produce informational and marketing materials for internal and external publication and display, including in promotional brochures and social media. If you don’t want to be included in footage, please refrain from entering the designated shoot area and from being in range of the camera and sound equipment or let us know by contacting the event organiser.
We may share the footage with third party service providers we use for the event and/or the shooting. We will ensure that appropriate safeguards are in place to protect your personal data and that international transfers of your personal data are compliant with applicable data protection laws. If you have questions about this initiative, please contact the event organiser.
[Updated March 15, 2024]