This policy sets out how WhoHAA programme, managed by V2U Network Sdn Bhd will handle personal information in accordance to the Data Protection Act 2010. 

Our Commitment

We are committed to protecting the privacy of our members and advertising sponsors.  We value the trust of those we deal with, and of the public, and recognize that maintaining this trust requires that we be transparent and accountable in how we treat the personal information that you choose to share with us.

In offering WhoHAA programme, we will gather and use personal information, which members expressly offered to WhoHAA upon registering an account with WhoHAA so that members are able to participate in the programme.

All information provided to us or collected will be carefully protected and any use of such information is subject to express or implied consent.

Defining Personal Information

Personal Information is information about an identifiable individual. This includes any information that can be used to distinguish, identify or contact a specific individual. An individual’s opinions or beliefs, as well as facts, about, or related to, the individual may also be considered personal information. Business contact information and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories, are not usually considered personal information.

Where an individual uses his or her home contact information as business contact information as well, we consider the contact information provided to be business contact information, and therefore may not be subject to the same level of protection as personal information.

What Personal Information Do We Collect?

Personal information collected by WhoHAA will include: name, address, telephone number(s), email address (es) and other contact information, date of birth, credit card or bank account information, language preference, demographic information such as age and gender, and communication preferences for marketing purposes.

We will also collect information on how you respond to sponsors’ advertisements such as answers to sponsors’ questions, viewing of sponsors’ video as well as link history to sponsors’ websites.  We also collect information about the redeemable items you redeemed, or purchased of any items from WhoHAA programme.

How Do We Collect Your Personal Information?

We collect most personal information directly from you, for example:

  • in forms or coupons filled out either online or in hard copy
  • via email
  • via online surveys
  • via social media messages or conversations
  • during telephone conversations
  • in voice or image recordings

or we may have accessed to your personal information via referral or recommendation from your contact, whom he/she think you will be interested in WhoHAA programme.

In the event where we collect your personal information from someone else, we will take reasonable steps to let you know how we obtained this information. Your personal information will only be collected and kept in our record upon your consent, which require you to complete our registration process.

If you choose not to provide us with certain personal information, we may not be able to meet your expectations or fulfilment of WhoHAA programme. For example, we cannot send you your redeemed items if we do not have your name and address.

Privacy Practices

Personal information gathered for WhoHAA programme is kept in confidence. Our personnel are authorized to access personal information based only on their need to deal with it for the reason(s) for which it was obtained. Safeguards are in place to ensure that personal information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered.

We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in light of the circumstances.  


How Do We Use Your Personal Information?

WhoHAA collects personal information in order to serve you with contents that we deem of interest to you and to allow us to constantly communicate with you.   We may be required to provide our sponsors with reports on how their sponsored points are being distributed, which you may have participated.  Such reports will not contain identifiable details but an overview of WhoHAA members detail whom responded to their campaigns.

We might use your information for the following purposes:

  • for the immediate reason for which you have given it: for example, to enable us to process your redemption request  / purchase
  • to maintain contact with you about our latest offers; such as marketing activities, promotional offering and / or system maintenance notices
  • any other purpose related to WhoHAA programme.

We may share your personal information with our sponsor if you expressly request us to provide your information to sponsors when you are responding to sponsors campaign.  We may also share your information to sponsors / business partners where necessary to operate WhoHAA programme  in order to provide you with various services, special offers, and for marketing purposes including planning, product development, telemarketing promotions, research and other carefully screened marketing programmes or activities, which we and/or the Business Partners believe are likely to interest you.

Website and Electronic Commerce

We use password protocols and encryption software to protect personal and other information we receive when a service is requested and/or paid for on-line. Our software is routinely updated to maximize protection of such information. Our website uses or may in the future use technology features such as log-in registration, cookies, or click through tracking software. The site also logs information such as IP addresses and browser types. This information is used for analysis purposes and to provide better service for our members.

Updating of Privacy Policy

We will be offering more services & programme in future and will regularly review and update our privacy policy. Please check this site regularly for information on our most up-to-date practices.

Access to Personal Information

You may at anytime view, edit, update your personal information stored in our system by logging into your account.  

Contacting WhoHAA regarding Privacy Policies

Questions, concerns or complaints relating to WhoHAA’s privacy policy on the treatment of personal information can be addressed in writing to : [email protected]