PRIVACY POLICY

PRELIMINARIES

The Roulette Code is located at http://www.TheRouletteCode.com and its directly associated domains or sub-domains (collectively, “TRC”,  “Website” or “website”). At TRC, we understand that your privacy is important to you and that you care about how your information is used and shared online. TRC’s Privacy Policy is designed to help you understand how we collect and use the personal information you decide to share, and help you make informed decisions when using TRC. We respect and value the privacy of everyone who visits TRC and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and TRC’s obligations under the law.

This Policy applies to TRC’s use of any and all data collected by TRC in relation to your use of our Website. Please read this Privacy Policy carefully and ensure that you understand it completely. Your acceptance of TRC’s Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

Definitions and Interpretations

In this Privacy Policy the following terms shall have the following meanings:

“Account”means a registered member account (with email validation) required to access and/or use the members functionalities;
“Cookie”means a small text file placed on your computer or device by our Website when you visit certain parts of our Website and/or when you use certain features of our Website;
“Website”means this website, http://www.TheRouletteCode.com and any of its directly associated domains or sub-domains;
“We/Us/Our”means TRC, a Website owned and operated by Dr. Bill Lim (also the Data Protection Officer) @ Jalan PJU 7/12B, Mutiara Damansara, Petaling Jaya 47810, Selangor, Malaysia. Contact:  admin@TheRouletteCode.com

By using or accessing TRC, you are accepting the practices described in this Privacy Policy.

If you have any queries in relation to this Privacy Policy, you can email us at: admin AT TheRouletteCode DOT COM This is a legal document which sets out how TRC handles data which identifies you. This Privacy Policy forms part of our Terms of Website. At TRC we believe strongly in protecting the privacy of our Members’ personal information. This statement describes the privacy practices we apply for the TRC Website. As part of that, it also expresses our approach to complying with the data protection laws which apply in Malaysia. If you have questions or concerns regarding this statement, you should contact the TRC customer services at admin AT TheRouletteCode DOT COM

1. THE INFORMATION WE COLLECT AND WHY WE COLLECT IT

Information collected during registration. When you register on the TRC Website, you provide your name, your email address, your photo, your location details and some optional details about yourself. They are available to you, and capable of being corrected or updated, through your ‘MEMBER LOGIN > Edit Profile & Password’ page, when you are logged-in. We also store all purchase transactions you make on our Website for accounting and affiliate bonus calculations and payments. We DO NOT store your credit card details on our Website.

Cookies

We use small files known as “cookies” to enhance users’ experience of the TRC Website as follows:

  • To facilitate optimal use of the TRC Website by Members, by means of a “session” cookie.
  • The cookies on the TRC Website do not access or use information by which people can be personally identified. If you wish, you can prevent these files from using non-personal information about you by either deleting the cookie folder in your browser or by putting your browser’s Privacy setting higher, but doing so will mean that you will not be able to use the TRC Website in the way that we intend it to be used, and may well adversely affect your experience of websites that use cookies to enhance or personalize that experience.
  • If you leave a comment on our website you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
  • If you have an account and you log in to our website, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
  • When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you log out of your account, the login cookies will be removed.
  • If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Comments

  • When visitors leave comments on our website we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
  • An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to our website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact Us Form

We provide a Contact Us Form for users to send us a message. You are required to enter your Name and Email address when using the form. Any personal data captured is solely used for the purpose of responding to your message and the information is kept up to 12 months after addressing any issues raised and the case closed. The information is kept for customer service purposes, but will not be used for marketing purposes.

Embedded Content From Other Websites

  • Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
  • These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

Our Website uses plugins that provides analytics services and social sharing and each of these plugin have their own Privacy Policies and you can view them via the links below:

Social Media Follow Buttons

Google Analytics

2. ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION

The information we collect may be used:

♦ To process your payment for goods or services ordered on our site or to fulfill such orders.
♦ To provide our customer support service and to verify any claims or requests you make if you use our customer support service.
♦ To enforce our terms and conditions and prevent or detect hacking activities, security breaches or safety risks in connection with our websites.
♦ To send service announcements and messages.
♦ To aggregate information to generate anonymous statistics regarding the use of our website.
♦ For our own internal marketing and demographic studies and to help us improve our website.
♦ In the event of an actual or proposed (including as part of negotiations for any) merger, or business combination or sale of substantially all of our assets or a business operation to which such information relates or as provided under bankruptcy or applicable insolvency laws or by the enforcement of equitable rights.

If your personally identifiable information or email address changes, you may correct and update your Membership profile details via the Member’s menu option ‘MEMBER LOGIN > Edit Profile & Password’ which is accessible when you are logged on to the TRC Website. If you no longer wish to be a Member of the TRC Website, you can email TRC Customer Support at the following email: admin AT TheRouletteCode DOT COM to request for a deactivation of your account. Upon confirmation of such a request, all your personal data will be removed from our system. Transaction records that are required for the integrity of our overall system will however not be deleted – these will remain in our database but will have no reference to you personally. After deactivation, you will no longer be able to login or access any information.

 

3. EMAILS YOU RECEIVE FROM TRC

As part of the TRC Website, TRC sends Members newsletters and emails but you can choose not to receive them by unsubscribing. You may also receive email notifications when there is a transaction that involves your account and you will also receive emails related to the TRC Website which are sent out to all members regardless of your preference. These emails are only sent to you if and when necessary and are not marketing or promotional emails.

 

4. CHOICE / OPT-OUT

You may opt out of any or all of the newsletters and emails we send you.

 

5. HOW WE USE PERSONAL DATA WE COLLECT

Any visitor to the TRC Website anywhere in the world can view your public profile information and content that you have willingly shared.

The over-riding principles we apply are these:

We, and (where relevant) our online processing agents, will not supply your personal data to a third party for commercial exploitation except as consented to by you in accordance with prevailing law.

Profile Information. Once a Member selects a location, some or all of the information held for that Member, except for the email address, telephone numbers and passwords, will be publicly available at the listing for that location.

Your home location, in terms of your town / city, state / county and country, and any other location specific information you submit to the TRC Website must be considered at all times to be publicly available information. However, address details submitted to the TRC Website are not made publicly available.

Email addresses. We do not directly make your email address available to anyone on any screen of the TRC Website. Members may change the email address at any time. No tracking technologies are used within / in conjunction with emails nor do we share, sell, rent or trade with third parties for their promotional purposes.

Un-validated Memberships. If you register for the TRC Website, and you receive a validation email, but fail to validate your Membership then we may contact you via email at periods of 24 hours, 7 days, and 30 days at your registered email address to notify you of the invalid status. Should you fail to respond to these notifications then we may send you one final notice before the un-validated Membership is removed.

Advertising. The TRC Website may include display or editorial advertising for other businesses. However, we do not use, nor provide to third parties, anonymous demographic data provided by Members to these advertisers.

Telephone numbers. You may enter a contact telephone number in your profile. Your number will never be disclosed to any third party without your prior consent. Should we introduce an additional service which utilises telephone numbers, or we wish to provide you with informational content via your mobile phone, you will be given the option to agree to this, as we believe it should be your choice what services you receive.

Credit Card information. We work with the leading Merchant Providers in the industry who specialize in Fraud and Data Verification. We share your billing information with such companies insofar as necessary for the processing of your payment or to prevent or detect fraud. These companies have agreed not to retain, share, store or use your personally identifiable information for any secondary purpose.

TRC companies and subsidiaries. We may share data supplied by you (or collected about you) with our subsidiaries and other companies owned by us, but only for the purposes described in this policy.

Changes in TRC’s business. If all of the assets which TRC uses to operate its business (or substantially all of them) are acquired by a third party, we may transfer personal data we then hold to that party.

Place of processing. The computers and companies that process data on our behalf are based in the United States. Thus, your personal data (which may include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or concerning health or sex life) may be transferred to, processed and held both inside and outside of Malaysia. Some countries may not have as well developed data protection laws in place to protect your information, but we will ensure your personal data is treated in compliance with those laws and this Privacy Policy.

 

6. SHARING INFORMATION

When you use the TRC Website, you may form relationships, send messages, perform searches and queries, and transmit information through various channels. We collect this information so that we can provide you the service and offer personalized features. In most cases, we retain it so that, for instance, you can return to view prior messages you have sent or easily see the list of people whom you have communicated with. You post a User Submission (as defined in the TRC Terms of Website) on the TRC Website at your own risk. Please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other Users with whom you may choose to share your pages and information. Therefore, we cannot and do not guarantee that User Submissions you post on the Site will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. You understand and acknowledge that, even after removal, copies of User Submissions may remain view-able in cached and archived pages or if other Users have copied or stored your User Submissions.

Your name and profile picture thumbnail will be available in all search results on TRC and may be searchable through third party web-sites and third party search engines, and may be automatically notified to third party tracking websites/weblogs.

 

7. CHANGING OR REMOVING INFORMATION

Access and control over most personal information on TRC is readily available via ‘MEMBER LOGIN > Edit Profile & Password’ page when you are logged-in. TRC users may modify or delete any of their profile information at any time by logging into their account. Information will be updated immediately. Please refer to point 2. above regarding DEACTIVATION of your account.

 

8. DATA RETENTION POLICY

  • Except when we believe we are required to retain your personal information by law, we will only retain your personal information during the period in which you use TRC Website. However, we may not know if you have stopped using the Website so we encourage you to contact us for DEACTIVATION if you are no longer using TRC Website.
  • We may retain information that is encrypted or otherwise not personally identifiable for backups, archiving, prevention of fraud and abuse, analytics, or where we otherwise reasonably believe that we have a legitimate reason to do so.
  • If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
  • For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time. Website administrators can also see and edit that information. All personal information are kept as long as you are a member of our Website. Your personal data will only be deleted upon DEACTIVATION as outlined above under point 2.

 

9. WHAT RIGHTS YOU HAVE OVER YOUR DATA

If you have an account on our website, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, accounting, legal, or security purposes.

 

10. INTERNATIONAL DATA TRANSFERS AND SECURITY

TRC.Life is hosted in the United States and is intended for users located both within and outside the United States. If you choose to use the TRC Website from the European Economic Area (EEA) or other countries that have laws governing data collection and use that may differ from U.S. law, note that you are transferring your personal information outside of those regions to the United States for storage and processing. By providing any information, including personal information, on or to TRC Website, you consent to such transfer, storage, and processing. Note that there are risks to permitting such transfers, as the laws of the U.S. or other jurisdictions may not provide you with privacy guarantees, remedies, or other protection equivalent to those of the EEA or the country where you are located.

  • Data security is of great importance to TRC, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website.
  • Steps TRC take to secure and protect your data include:
    • Using 256-bit encryption technology on our storage systems that are password protected.
  • Notwithstanding the security measures that are taken, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to data to TRC via the internet.

We have security measures in place to protect our customer database and access to this database is restricted internally. However, it remains each Member’s responsibility:

♦ to protect against unauthorised access to your personal details;
♦ to ensure against use by anyone else of the TRC Website through the machine that Member uses while they are “logged on” to the TRC Website;
♦ to log off or exit from the TRC Website when not using it;
♦ and to keep his/her password secret.
♦ our Security team can be reached via admin AT TheRouletteCode DOT COM
♦ TRC strives to protect the Personal Information and email address you provide through our site; however no data transmission over the Internet can be guaranteed to be 100% secure

♦ We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on our Website if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

 

11. DISCLOSURE FOR LEGAL REASONS

We reserve the right to communicate a Member’s personal information as we hold to third parties which seek the disclosure of it, and which make a legally-compliant request for its disclosure.

Legal Disclaimer
We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website.

 

12. CONTACTING US
If you have any questions about this privacy statement, the practices of this site, or your dealings with TRC, you can contact us at admin AT TheRouletteCode DOT COM  You can also use this email address if you wish to request from us a copy of the personal data we hold about you or a description of that data from TRC. Please note that we are entitled to charge you a small sum for providing this information.

 

13. LINKS TO THIRD PARTY SITES

Our site may contain links to other sites. TRC is not responsible for the privacy practices, or the content, of those web sites or services of other companies or organizations to which we link or which link to us or which provide goods or services to our users from their web sites

 

14. DATA PROTECTION INFORMATION

You can obtain further information about personal data protection laws by visiting the Official website of the Department of Personal Data Protection at http://www.pdp.gov.my

 

15. CHANGES TO THIS PRIVACY POLICY

If we decide to change our Privacy Policy or email practices, we will post those changes to this privacy statement and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our web site.