PRIVACY POLICY
Last updated April 4, 2024
TABLE OF CONTENTS
1. INTRODUCTION
1.1 This privacy policy (the “
Privacy Policy”) describes how Thanlyin Estate Development Limited (the “
Company”, “
we”, “
us” or “
our”) collects, stores, uses, shares and protects ("
process") the personal data of users of the Company’s website at
starcityyangon.com, and mobile application, StarCity Living App, and any products, websites or mobile applications that links to this Privacy Policy (collectively, the “
Platforms”). This Privacy Policy applies to the users of our services (“
you”, “
your” or “
yours”).
1.2 By interacting with us, accessing our services, submitting information to us (whether through our services or otherwise), or signing up for any products or other services offered by us through the Platforms, you agree and consent to us processing your
Personal Data (as defined below) and disclosing it to our subsidiaries and affiliates, our third party service providers in the manner set forth in this Privacy Policy.
1.3 Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Platforms.
2. DEFINITION
“Personal Data” means information about you, from which you are identifiable, including but not limited to your name, identification card number, FIN number, company registration number, passport number, telephone number, date of birth, gender, email address, payment data and transactions, profile photo, and any information about you which you have provided to us.
3. COLLECTION OF PERSONAL DATA
3.1 Personal Data You Disclose to Us
We collect Personal Data that you voluntarily provide to us when you express an interest in obtaining information about us or our services, when you participate in activities on the Platforms, or otherwise when you contact us.
Personal Data that we collect depends on the context of your interactions with us and the Platforms, the choices you make, and the products and features you use.
3.2 The Platforms’ Push Notifications
If you use our Platforms, we may request to send you push notifications regarding your account or certain features of the Platforms. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
4. USE OF PERSONAL DATA
4.1 We respect your data privacy rights and are committed to complying with all applicable data protection laws in Myanmar. We will use your Personal Data including but not limited to the following purposes:
(i) to provide you with the products or services that have been requested;
(ii) to facilitate bill payments;
(iii) to help us profile, review, develop, manage and enhance our products and services, including by analysing future customer needs;
(iv) to communicate with you and respond to your queries, requests and complaints;
(v) to provide ongoing information about our products and services which may be relevant to you or for which you have signed up or expressed an interest in;
(vi) to protect and enforce our contractual and legal rights and obligations;
(vii) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;
(viii) to facilitate any proposed or actual business transactions; and
(ix) to assist in law enforcement and investigations by relevant authorities.
4.2 Data Use, Consent, and User Control
User Consent and Control: We prioritize user consent and control over camera access. The app requests camera permission only when the user attempts to use a feature requiring it, and detailed information is provided regarding why the access is necessary. Users can enable or disable camera access anytime through their device settings, ensuring their autonomy and comfort.
Privacy Measures: Our app does not store or transmit any images or video content without explicit user consent. If any content is stored or transmitted, it is encrypted and handled according to our stringent data protection policies, as detailed in our Privacy Policy. We only use camera access for the stated purposes and ensure that all processing is done with the highest regard for user privacy and data security.
Compliance with App Store Review Guidelines: Our request for camera access and implementation fully complies with the App Store Review Guidelines. We are committed to upholding the principles of privacy, security, and transparency outlined in these guidelines, offering our users a safe and trustworthy experience.
5. DATA DISCLOSURE
We reserve the right to share your Personal Data with relevant authorities as may be required under applicable law.
6. RETENTION OF PERSONAL DATA
6.1 We will only keep your Personal Data for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by relevant law (such as tax, accounting, or other legal requirements).
6.2 When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise such information, or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
7. SECURITY OF PERSONAL DATA
7.1 Security Measures
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any Personal Data we process.
7.2 Limitations on Security
While we take commercially reasonable steps to help secure and safeguard Personal Data, no security system is impenetrable. Due to the inherent nature of the Internet or information storage technology as an open global communication vehicle, we cannot promise or guarantee that Personal Data, during transmission to and from our Platforms through any online means, will be absolutely safe from intrusion by others and remains at your own risk.
8. PRIVACY RIGHTS
8.1 We process Personal Data with your consent, and we respect your privacy rights in accordance with applicable laws. In the event that you choose to withdraw the Personal Data you shared with us, you can withdraw your consent at any time by giving Personal Data withdrawal notice to the contact details provided in
paragraph 11.
8.2 However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
10. AMENDMENTS AND UPDATES
We reserve the right to vary, modify, remove or update this Privacy Policy without prior notice to you. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you (but not obliged to do so) either by prominently posting a notice of such changes or by directly sending you a notification.
11. CONTACT US
11.1 If you have any queries or doubts about the policies set out in this Privacy Policy or about your Personal Data that we obtain, maintain, process, use and disclose, or if you would like to access or correct your Personal Data, please contact by email at
customercare@yomaland.com or by post to:
StarCity, Kyaik Khauk Pagoda Road,
Thanlyin Township, Yangon, Myanmar.
Yangon, Yangon 11141
Myanmar
11.2 Please note that if your Personal Data has been provided to us by a third party, you should request such third party to make such queries, complaints, and access and correction requests to us on your behalf.
12. GOVERNING LAW
This Privacy Policy shall be governed in all respects by the laws of Myanmar.