Personal Data Protection Policy

1. Introduction ("we" or "our") is committed to protecting the privacy and personal data of our users. This Personal Data Protection Policy ("Policy") outlines how we collect, use, disclose, and protect personal data in accordance with the laws and regulations of Malaysia, including the Personal Data Protection Act 2010 ("PDPA").

2. Scope
This Policy applies to all personal data collected, processed, or stored by in Malaysia. It applies to individuals who use our website, mobile applications, or any other services provided by (collectively referred to as "Services").

3. Collection of Personal Data
We may collect personal data directly from you when you interact with our Services, including but not limited to:

Contact information (e.g., email address, phone number)
Location information
Payment information
Recycled Materials

4. Use of Personal Data
We collect and use personal data for the following purposes:

Providing and improving our Services
Processing and fulfilling your requests or orders
Communicating with you regarding our Services
Sending you promotional materials and updates
Conducting research and analysis to enhance our Services
Complying with legal obligations and regulatory requirements

5. Disclosure of Personal Data
We may disclose personal data to the following third parties, within the constraints of the PDPA and
other applicable laws:

Service providers and business partners who assist us in delivering our Services Government authorities, regulatory bodies, or law enforcement agencies as required by law or Any other third party with your consent or as permitted by law

6. Data Security
We implement reasonable security measures to protect personal data against unauthorized access, disclosure, alteration, or destruction. These measures include but are not limited to:

Implementing access controls and restrictions
Regularly monitoring and auditing our systems
Conducting employee training on data protection
Employing secure data storage and transmission methods
However, please note that no method of transmission or storage is 100% secure, and we cannot guarantee absolute security of personal data.

7. Retention of Personal Data
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law. When personal data is no longer required, we will dispose of it securely and in compliance with applicable laws and regulations.

8. Rights of Individuals
Under the PDPA, you have certain rights regarding your personal data. You have the right to:

Access your personal data held by us
Request correction of inaccurate or incomplete personal data
Object to the processing of your personal data
Request the deletion or restriction of your personal data
Withdraw consent for the processing of personal data, where applicable

To exercise your rights or make any inquiries related to your personal data, please contact us using
the details provided in Section 10.

9. Updates to the Policy
We may update this Policy from time to time to reflect changes in our practices or legal obligations.
We encourage you to review this Policy periodically. Any significant changes will be communicated
through our website or other appropriate means.

10. Contact Us
If you have any questions, concerns, or requests regarding this Policy or the handling of your
personal data, please contact us at:

[email protected]
G-3A, Kanvas Retail @ Prima 15, Jalan Teknokrat 6, Cyberjaya 63000, Selangor, Malaysia

We will endeavour to respond to your inquiries and requests promptly and in accordance with
applicable laws and regulations.

By using our Services, you acknowledge that you have read and understood this Personal Data
Protection Policy and agree to the collection, use, and disclosure of your personal data as described

Anti-Bribery & Corruption Policy

  • 1.         Policy statement

    2.        Who is covered by the policy?

    3.        What is bribery?

    4.        Gifts and hospitality

    5.         What is not acceptable?

    6.         Facilitation payments and kickbacks

    7.         Donations

    8.         Your responsibilities

    9.         Record-keeping

    10.       How to raise a concern

    11.        What to do if you are a victim of bribery or corruption

    12.       Protection

    13.       Review

    14.       Potential risk scenarios: "red flags"


Policy statement

1.1 It is the policy of Blue Bee Technologies Sdn Bhd ("Company") to conduct all of the Company's business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.

1.2 We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which the Company operates in respect of the Company's conduct both in the members' respective local jurisdictions and abroad including the Malaysian Anti-Corruption Commission Act 2009 (“Act”).

1.3 The purpose of this policy is to:

(a)set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and

(b)provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

1.4 Bribery and corruption are punishable for individuals (in certain jurisdictions by up to 10 years' imprisonment) and if we are found to have taken part in corruption we could face considerable fines (which in certain jurisdictions are unlimited), and we could be excluded from tendering for public contracts and face damage to our reputation.

1.5 In this policy, “third party” means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.


This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, casual workers, agents, sponsors, or any other person associated with the Company, or any of our subsidiaries (direct or indirect) or their employees, wherever located (collectively referred to as “employees” in this policy).


What is bribery?

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.


Gifts and hospitality

4.1 This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties.

4.2 Bona fide hospitality and promotional or other business expenditure which seeks to improve the image of the Company, its products and services, or to establish cordial relations, is recognised as an established and important part of doing business. Examples of bona fide hospitality and promotional items would include greetings, hampers or gifts provided during festive periods as well as products involving or demonstrating local/regional expertise.

4.3 The giving or receipt of gifts is not prohibited, if the following requirements are met:

(a) it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

(b) it complies with applicable local law;

(c) it is given in our name, not in your name;

(d) it is appropriate in the circumstances. For example, in Malaysia and Singapore, it is customary for small gifts to be given at Lunar New Year;

(e) it is given openly, not secretly;

(f) it does not include cash or a cash equivalent (such as gift certificates or vouchers);

(g) gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of the Company’s management team; and

(h) taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time.

4.4 We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.


What is not acceptable?

It is not acceptable for you (or someone on your behalf) to:

(a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

(b) give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure);

(c) accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;

(d) accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

(e) threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

(f) engage in any activity that might lead to a breach of this policy.


Facilitation payments and kickbacks

6.1 We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

6.2 If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Company’s management team.

6.3 Kickbacks are typically payments made in return for a business favour or advantage. All employees must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by any member of the Company.



We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices. No donation of any kind may be offered or made without the prior approval of the Company’s management team.


Your responsibilities

8.1 You must ensure that you read, understand and comply with this policy.

8.2 The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

8.3 You must notify the Company’s management team as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further "red flags" that may indicate bribery or corruption are set out in section 14 of this policy.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other employees if they breach this policy. 



9.1 You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

9.2 You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our rules and specifically record the reason for the expenditure.


How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised to the Company’s management team.


What to do if you are a victim of bribery or corruption

It is important that you tell the Company’s management team as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.



12.1 Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

12.2 We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Company’s management team immediately. 



13.1 We reserve the right to review or amend this policy at any time.

13.2 All employees are responsible for the success of this policy and should ensure they adhere to it and that they use it to disclose any suspected danger or wrongdoing.

13.3 Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the head of legal.

13.4 This policy does not form part of any employee’s contract of employment and it is subject to change.


Potential risk scenarios: “red flags”

The following is a list of possible red flag scenarios that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
If you encounter any of these red flag scenarios while working for us, you must report them promptly to the Company’s management team:

(a) you become aware that a third party engages in, or has been accused of engaging in, improper business practices;

(b) you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials;

(c) a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;

(d) a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

(e) a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;

(f) a third party requests an unexpected additional fee or commission to "facilitate" a service;

(g) a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;

(h) a third party requests that a payment is made to "overlook" potential legal violations;

(i) a third party requests that you provide employment or some other advantage to a friend or relative;

(j) you receive an invoice from a third party that appears to be non-standard or customised;

(k) a third party insists on the use of side letters or refuses to put terms agreed in writing;

(l) you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;

(m) a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us; or

(n) you are offered an unusually generous gift or offered lavish hospitality by a third party.

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(Blue Bee Technologies Sdn Bhd - 1181695-X)