Company Policies

1. Acceptance of Terms

1.1

By accessing, browsing, or using the Langkawi Hot Spot website and/or booking any service offered by Langkawi Hot Spot Vacation Sdn Bhd ("the Company", "we", "us", or "our"), you ("the Customer", "you", or "your") acknowledge that you have read, understood, and agree to be bound by these Terms and Conditions.

1.2

If you do not agree to these Terms and Conditions, you must immediately cease use of our website and services.

1.3

These Terms and Conditions apply to all services provided by the Company, including but not limited to tour packages, transportation services, activity bookings, and corporate tour programmes.

2. Definitions

• a) "Service" refers to any tour package, activity, transportation service, corporate programme, or other service offered by the Company.
• b) "Booking" refers to a confirmed reservation of a Service made through the Company's official channels.
• c) "Booking Confirmation" refers to the document or communication issued by the Company confirming a Booking.
• d) "Force Majeure" refers to any event beyond the reasonable control of the Company, including but not limited to natural disasters, pandemics, war, terrorism, government restrictions, or extreme weather.

3. Services and Booking

3.1

All bookings must be made through the Company's official communication channels, including its website, email, telephone, or authorised booking platforms.

3.2

A Booking is only confirmed upon receipt of the Booking Confirmation and the required payment or deposit from the Customer.

3.3

The Company reserves the right to decline any Booking at its sole discretion without assigning any reason.

3.4

The Customer shall provide accurate and complete information at the time of Booking. The Company shall not be held liable for any consequences arising from inaccurate or incomplete information provided by the Customer.

4. Pricing and Payment

4.1

All prices quoted are in Malaysian Ringgit (MYR) unless otherwise stated. Prices are subject to change without prior notice until a Booking is confirmed.

4.2

A deposit or full payment may be required at the time of Booking, as specified in the Booking Confirmation. The balance of payment must be settled prior to the scheduled service date.

4.3

All published prices are inclusive of applicable taxes unless explicitly stated otherwise. Any additional costs, including but not limited to personal expenses, optional activities, and travel insurance, shall be borne by the Customer.

4.4

Late or non-payment may result in the cancellation of the Booking at the Company's discretion.

5. Customer Obligations

5.1

The Customer shall comply with all instructions, guidelines, and safety protocols provided by the Company or its authorised representatives during the provision of Services.

5.2

The Customer shall arrive at the designated meeting point or location at the time specified in the Booking Confirmation. Failure to appear (no-show) will result in the Booking being forfeited with no refund.

5.3

The Customer is responsible for ensuring that they are physically and medically fit to participate in the booked activity or tour. The Customer shall disclose any relevant medical conditions at the time of Booking.

5.4

The Customer shall behave in a manner that does not endanger themselves, other participants, staff, or third parties. The Company reserves the right to terminate or refuse Service to any Customer whose behaviour is deemed unsafe, disruptive, or unlawful, without refund.

5.5

The Customer is responsible for carrying valid identification documents (e.g., passport, MyKad) as required for the booked Service.

6. Changes and Cancellations by the Customer

6.1

Requests to change or cancel a Booking must be submitted in writing through the Company's official communication channels.

6.2

Changes to Bookings are subject to availability and approval by the Company. Additional charges may apply.

6.3

Cancellation charges shall apply in accordance with the Company's Refunds and Cancellation Policy, available at refunds-and-cancellation.html.

7. Changes and Cancellations by the Company

7.1

The Company reserves the right to modify, postpone, or cancel any Service due to unforeseen circumstances including but not limited to extreme weather, safety concerns, government restrictions, insufficient participants, or operational issues.

7.2

In the event of a cancellation by the Company, the Customer will be offered rescheduling or a full refund of the affected Service.

7.3

The Company shall not be liable for any additional costs incurred by the Customer, including accommodation, flights, visa fees, or other travel arrangements made independently.

8. Intellectual Property

8.1

All content on the Company's website, including text, graphics, logos, images, photographs, videos, and software, is the property of the Company or its licensors and is protected by Malaysian and international intellectual property laws.

8.2

No content from the Company's website may be reproduced, duplicated, copied, sold, resold, or exploited for any commercial purpose without the Company's prior written consent.

8.3

Photographs, videos, or other content captured by the Company during the provision of Services may be used for marketing and promotional purposes. If the Customer does not consent, they must notify the Company in writing prior to the service date.

9. Limitation of Liability

9.1

The Company shall provide Services with reasonable skill and care. However, to the maximum extent permitted by law, the Company shall not be liable for any loss, damage, injury, or death arising from:

• a) The Customer's own negligence or failure to follow instructions.
• b) The actions or omissions of third-party service providers not under the Company's direct control.
• c) Force Majeure events.
• d) Pre-existing medical conditions of the Customer.
• e) Loss or damage to personal belongings.

9.2

The Company's total liability to the Customer in respect of any Booking shall not exceed the total amount paid by the Customer for that Booking.

9.3

Nothing in these Terms and Conditions shall exclude or limit liability for death or personal injury caused by the Company's negligence, fraud, or any other liability that cannot be excluded under applicable law.

10. Indemnification

10.1

The Customer agrees to indemnify, defend, and hold harmless the Company, its directors, officers, employees, agents, and affiliates from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable legal fees) arising out of or in connection with the Customer's use of the Services or breach of these Terms and Conditions.

11. Force Majeure

11.1

The Company shall not be liable for any failure or delay in performing its obligations where such failure or delay results from Force Majeure events, including but not limited to natural disasters, epidemics, pandemics, war, terrorism, civil unrest, government actions, strikes, or extreme weather conditions.

11.2

In the event of Force Majeure, the Company will use reasonable endeavours to mitigate the effects on the Customer, including offering alternative dates or arrangements where practicable.

12. Governing Law and Jurisdiction

12.1

These Terms and Conditions shall be governed by and construed in accordance with the laws of Malaysia.

12.2

Any dispute arising out of or in connection with these Terms and Conditions shall first be referred to mediation. If mediation is unsuccessful, the dispute shall be submitted to the exclusive jurisdiction of the courts of Malaysia.

13. Amendments

13.1

The Company reserves the right to amend these Terms and Conditions at any time. The amended Terms and Conditions will be posted on the Company's website with the updated effective date. Continued use of the Company's services after such changes constitutes acceptance of the amended Terms and Conditions.

14. Severability

14.1

If any provision of these Terms and Conditions is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect.

15. Entire Agreement

15.1

These Terms and Conditions, together with the Booking Confirmation, the Refunds and Cancellation Policy, and any other policies referenced herein, constitute the entire agreement between the Company and the Customer in relation to the Services.

16. Contact Information

For any questions regarding these Terms and Conditions, please contact us:

• Langkawi Hot Spot Vacation Sdn Bhd
• No 33C, Persiaran Banyan Square, Jalan Bukit Banyan, Bukit Banyan, 08000 Sungai Petani, Kedah
• Email: langkawihotspot@gmail.com
• WhatsApp: +6012 590 9975

1. Introduction

1.1

Langkawi Hot Spot Vacation Sdn Bhd ("the Company", "we", "us", or "our") is committed to protecting the privacy and personal data of our customers, website visitors, and business partners. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in compliance with the Personal Data Protection Act 2010 ("PDPA") of Malaysia and applicable international data protection regulations.

1.2

By using our website or services, you consent to the collection and use of your personal data as described in this Privacy Policy. If you do not agree, please do not use our website or provide your personal data.

2. Personal Data We Collect

We may collect the following categories of personal data:

• a) Identity Data: Full name, nationality, date of birth, passport number, MyKad number, and gender.
• b) Contact Data: Email address, telephone number, and postal address.
• c) Booking Data: Service details, booking dates, travel preferences, dietary requirements, and special needs.
• d) Payment Data: Credit/debit card details, bank account information, and transaction history. Payment data is processed through secure third-party payment processors and is not stored on our servers.
• e) Technical Data: IP address, browser type, operating system, device information, and cookies collected through our website.
• f) Communication Data: Records of correspondence with us, including email, telephone, and WhatsApp communications.

3. How We Use Your Personal Data

Your personal data is used for the following purposes:

• a) To process and manage your Bookings and provide the requested Services.
• b) To communicate with you regarding your Bookings, inquiries, and service updates.
• c) To process payments and issue refunds in accordance with our Refunds and Cancellation Policy.
• d) To comply with legal and regulatory obligations, including immigration, tourism, and tax requirements.
• e) To improve our website, services, and customer experience.
• f) To send marketing communications and promotional offers, subject to your consent where required by law.
• g) To ensure the safety and security of our customers and staff.
• h) To resolve disputes and enforce our Terms and Conditions.

4. Legal Basis for Processing

4.1

Under the PDPA 2010, we process your personal data based on one or more of the following grounds:

• a) Consent: You have given your consent to the processing of your personal data for one or more specific purposes.
• b) Contractual Necessity: Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
• c) Legal Obligation: Processing is necessary for compliance with a legal obligation to which the Company is subject.
• d) Legitimate Interest: Processing is necessary for the purposes of the legitimate interests pursued by the Company, except where such interests are overridden by your interests, rights, or freedoms.

5. Disclosure of Personal Data

We may disclose your personal data to the following categories of recipients:

• a) Service Providers: Third-party vendors, subcontractors, and partners who assist in providing our Services (e.g., hotels, transport operators, activity providers, payment processors).
• b) Government Authorities: Malaysian immigration, tourism authorities (MOTAC), tax authorities, and law enforcement agencies as required by law.
• c) Professional Advisers: Auditors, lawyers, and insurers who provide professional services to the Company.
• d) Business Transfers: In connection with any merger, acquisition, sale of assets, or restructuring of the Company, your personal data may be transferred to the relevant third party, subject to applicable data protection laws.

5.2

We do not sell, rent, or trade your personal data to third parties for their marketing purposes without your explicit consent.

6. International Data Transfers

6.1

Your personal data may be transferred to, stored, or processed in countries outside Malaysia where our service providers operate. Such countries may have data protection laws that differ from those of Malaysia.

6.2

When transferring personal data internationally, we ensure appropriate safeguards are in place, including contractual arrangements with recipients to protect your personal data in accordance with applicable data protection standards, including the principles of the PDPA 2010 and, where applicable, the EU General Data Protection Regulation (GDPR).

7. Data Retention

7.1

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws and regulations.

7.2

Booking records and related personal data are retained for a minimum period of seven (7) years from the date of the Booking, in compliance with Malaysian tax and accounting regulations.

7.3

Marketing consent records are retained for as long as consent is active and for a period of two (2) years after consent is withdrawn.

8. Data Security

8.1

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• a) Encryption of data in transit (SSL/TLS) and at rest where feasible.
• b) Access controls limiting access to personal data to authorised personnel only.
• c) Regular security assessments and system monitoring.
• d) Staff training on data protection and privacy obligations.

8.2

While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security but will promptly notify you and the relevant authorities in the event of a data breach, as required by the PDPA 2010.

9. Your Rights

Under the PDPA 2010 and, where applicable, international data protection laws such as the GDPR, you have the following rights:

• a) Right of Access: You may request access to the personal data we hold about you.
• b) Right to Correction: You may request the correction of any inaccurate or incomplete personal data.
• c) Right to Withdraw Consent: You may withdraw your consent for the processing of your personal data at any time, subject to legal or contractual restrictions.
• d) Right to Data Portability (GDPR): Where applicable, you may request to receive your personal data in a structured, commonly used, and machine-readable format.
• e) Right to Erasure (GDPR): Where applicable and where there is no overriding legal retention requirement, you may request the deletion of your personal data.
• f) Right to Lodge a Complaint: You may lodge a complaint with the Department of Personal Data Protection Malaysia (JPDP) if you believe your data protection rights have been infringed.

9.2

To exercise any of these rights, please contact us using the details provided in Section 15 of this Privacy Policy.

10. Cookies and Tracking Technologies

10.1

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse website traffic, and personalise content. Cookies are small data files stored on your device.

10.2

We use the following types of cookies:

• a) Strictly Necessary Cookies: Essential for the website to function properly.
• b) Analytics Cookies: Help us understand how visitors interact with our website (e.g., Google Analytics).
• c) Marketing Cookies: Used to deliver relevant advertisements and track campaign performance (e.g., Google Ads).

10.3

You may control and manage cookies through your browser settings. Disabling certain cookies may affect the functionality of our website.

11. Third-Party Links

11.1

Our website may contain links to third-party websites, plugins, or services that are not operated by us. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policy of every site you visit.

12. Children's Privacy

12.1

Our services are not directed to individuals under the age of 18, and we do not knowingly collect personal data from children. If a parent or guardian becomes aware that their child has provided us with personal data without their consent, please contact us immediately and we will take steps to remove such data.

13. Changes to This Privacy Policy

13.1

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this Privacy Policy periodically. Continued use of our website or services after any changes constitutes acceptance of the updated Privacy Policy.

14. Governing Law

14.1

This Privacy Policy is governed by the laws of Malaysia, including the Personal Data Protection Act 2010 (Act 709).

15. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact our Data Protection Officer:

• Langkawi Hot Spot Vacation Sdn Bhd
• Data Protection Officer
• No 33C, Persiaran Banyan Square, Jalan Bukit Banyan, Bukit Banyan, 08000 Sungai Petani, Kedah
• Email: langkawihotspot@gmail.com
• WhatsApp: +6012 590 9975

You may also lodge a complaint with:

• Department of Personal Data Protection Malaysia (JPDP)
• Website: www.pdp.gov.my

1. Policy Statement

1.1

Langkawi Hot Spot Vacation Sdn Bhd ("the Company", "we", "us", or "our") is committed to conducting all business activities with integrity, transparency, and in full compliance with all applicable anti-bribery and anti-corruption laws and regulations.

1.2

The Company maintains a zero-tolerance policy towards bribery and corruption in any form. This policy applies equally to all directors, officers, employees, contractors, subcontractors, agents, consultants, and any person or entity acting on behalf of the Company ("Covered Persons").

1.3

This policy reflects the Company's commitment to ethical business practices and its obligations under the Malaysian Anti-Corruption Commission Act 2009 (Act 694), the Malaysian Anti-Corruption Commission (Amendment) Act 2018, and Section 17A of the MACC Act 2009 (corporate liability provision).

2. Scope

2.1

This policy applies to all business activities and operations of the Company, including but not limited to:

• a) Interactions with government officials, regulatory authorities, and public bodies.
• b) Engagements with customers, suppliers, vendors, and business partners.
• c) All domestic and international operations.
• d) All forms of employment, contracting, and agency relationships.

2.2

This policy extends to all subsidiaries, affiliated companies, and joint ventures where the Company has a controlling interest or significant influence.

3. Definitions

• a) Bribery: The offering, giving, receiving, or soliciting of any thing of value to influence the actions of an official or other person in charge of a public or legal duty, or in a business transaction.
• b) Corruption: The abuse of entrusted power for private gain, including but not limited to bribery, embezzlement, fraud, extortion, collusion, and money laundering.
• c) Facilitation Payment: A small payment made to a low-level official to expedite or secure the performance of a routine, non-discretionary action to which the payer is already entitled.
• d) Government Official: Any officer or employee of a government department, agency, or instrumentality; any officer or employee of a public international organisation; any person acting in an official capacity for any of the foregoing; and any political party or party official or candidate for political office.
• e) Gift: Anything of value given or received, including hospitality, entertainment, travel, donations, and sponsorships.

4. Legal Framework

4.1

The Company and all Covered Persons are subject to the following key legislation:

• a) Malaysian Anti-Corruption Commission Act 2009 (Act 694): Prohibits the giving or receiving of gratification as an inducement or reward for doing or forbearing to do any act in relation to the affairs of the principal or organisation.
• b) Section 17A — Corporate Liability: A commercial organisation commits an offence if a person associated with it bribes another person with the intention of obtaining or retaining business or an advantage in the conduct of business for the organisation. A defence exists if the organisation can prove it had adequate procedures in place to prevent such conduct.
• c) MACC (Amendment) Act 2018: Introduces provisions for corporate liability, third-party disclosure orders, and enhanced enforcement powers.
• d) Penal Code (Act 574): Contains provisions relating to criminal breach of trust, cheating, and dishonest misappropriation.
• e) Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA): Prohibits the use of proceeds of unlawful activities, including corruption.
• f) Whistleblower Protection Act 2010: Provides protection to persons who disclose information on offences under the MACC Act.

4.2

Where international operations are concerned, Covered Persons must also comply with applicable foreign anti-corruption laws, including but not limited to the United States Foreign Corrupt Practices Act (FCPA) and the United Kingdom Bribery Act 2010.

5. Prohibited Conduct

No Covered Person shall, directly or indirectly:

• a) Offer, promise, give, authorise, or offer to give anything of value to any Government Official or any person to influence or reward any act or decision, or to obtain or retain any business or advantage.
• b) Request, agree to receive, or accept anything of value from any person as an inducement or reward for doing or forbearing to do any act in relation to the Company's business.
• c) Make facilitation payments to any Government Official.
• d) Make or authorise political contributions on behalf of the Company without prior written approval from the Board of Directors.
• e) Make or authorise charitable donations or sponsorships for the purpose of improperly influencing any person or obtaining an improper advantage.
• f) Engage in any form of collusion, bid-rigging, or anti-competitive conduct.
• g) Falsely record, conceal, or fail to report any payment, gift, or transaction related to this policy.
• h) Retaliate against, threaten, or harass any person who reports a suspected breach of this policy in good faith.

6. Gifts and Hospitality

6.1

Modest, reasonable, and occasional gifts and hospitality may be offered or received provided they:

• a) Are not intended or perceived as an inducement or reward for any act or decision.
• b) Are lawful under applicable local laws.
• c) Do not exceed a value of RM500 (Ringgit Malaysia Five Hundred) per instance or RM1,500 in aggregate per person per calendar year.
• d) Are proportionate and consistent with normal business etiquette.
• e) Are accurately recorded in the Company's gift register.

6.2

Gifts and hospitality exceeding the above thresholds must receive prior written approval from the Managing Director or the Company's designated Compliance Officer.

6.3

The following are strictly prohibited:

• a) Cash or cash equivalents (e.g., gift cards, vouchers, cryptocurrency).
• b) Gifts to or from any Government Official without prior approval.
• c) Gifts during pending procurement or regulatory decisions.
• d) Lavish or frequent entertainment of any individual.

7. Facilitation Payments

7.1

The Company strictly prohibits the making of facilitation payments under any circumstances. Facilitation payments are payments made to low-level officials to expedite or secure the performance of routine, non-discretionary actions.

7.2

If a Covered Person is confronted with a demand for a facilitation payment, they must:

• a) Politely decline the demand.
• b) Report the incident immediately to their supervisor and the Compliance Officer.
• c) Document the circumstances in writing as soon as practicable.

8. Political and Charitable Contributions

8.1

Political contributions and charitable donations made on behalf of the Company must receive prior written approval from the Board of Directors.

8.2

Such contributions and donations must not be used as a vehicle to channel bribes or improper advantages and must comply with all applicable laws and regulations.

9. Due Diligence

9.1

The Company shall conduct appropriate anti-bribery due diligence on third parties, including agents, consultants, contractors, and business partners, before engaging them to act on behalf of the Company.

9.2

Due diligence shall include, where proportionate and risk-based:

• a) Assessment of the third party's reputation and integrity.
• b) Screening against sanctions lists and publicly available corruption records.
• c) Inclusion of anti-bribery clauses and representations in contracts.
• d) Periodic review of ongoing relationships with third parties.

10. Reporting and Whistleblower Protection

10.1

All Covered Persons are required to promptly report any suspected or actual breach of this policy through the following channels:

• a) Internal Reporting: Email langkawihotspot@gmail.com or contact the Compliance Officer via WhatsApp at +6012 590 9975.
• b) External Reporting: The Malaysian Anti-Corruption Commission (MACC) via the MACC Hotline at 1-800-88-6000 or the MACC Portal at www.macc.gov.my.

10.2

The Company provides protection to whistleblowers in accordance with the Whistleblower Protection Act 2010 (Act 711). Any person who makes a report in good faith and reasonable belief that the information is true shall be protected from civil, criminal, or disciplinary liability.

10.3

The Company strictly prohibits any form of retaliation, victimisation, harassment, or detrimental treatment against any person who reports a suspected breach of this policy. Any Covered Person found to have retaliated against a whistleblower shall be subject to disciplinary action, including termination of employment or contract.

10.4

Reports may be made anonymously. However, anonymous reports may limit the Company's ability to investigate and respond effectively.

11. Investigation

11.1

All reports of suspected breaches will be taken seriously and investigated promptly, confidentially, and impartially by the Company or its appointed investigators.

11.2

During the investigation, all Covered Persons are required to cooperate fully and provide accurate information and documentation.

11.3

The Company shall report confirmed cases of bribery or corruption to the Malaysian Anti-Corruption Commission (MACC) and other relevant authorities as required by law.

12. Consequences of Breach

12.1

Any Covered Person who breaches this policy shall be subject to:

• a) Disciplinary Action: Including warning, suspension, termination of employment, or termination of contract.
• b) Civil Liability: The Company may seek to recover any loss or damage caused by the breach.
• c) Criminal Prosecution: Under the MACC Act 2009, bribery offences carry penalties of up to 20 years imprisonment and a fine of not less than five times the value of the gratification or RM10,000, whichever is greater.
• d) Corporate Liability (Section 17A): If the Company is found to have failed to prevent bribery by an associated person, the Company itself may be prosecuted and subject to a fine of not less than 10 times the value of the gratification or RM1,000,000, whichever is greater.

13. Training and Awareness

13.1

The Company shall provide anti-bribery and corruption training to all employees and relevant Covered Persons upon induction and at least once every two (2) years thereafter.

13.2

Training shall cover, at a minimum:

• a) The content of this policy and the anti-bribery laws of Malaysia.
• b) How to recognise and respond to bribery and corruption situations.
• c) Reporting procedures and whistleblower protections.
• d) Case studies and practical examples relevant to the tourism industry.

13.3

Records of all training undertaken shall be maintained by the Company.

14. Policy Review

14.1

This policy shall be reviewed at least once every two (2) years, or more frequently in the event of changes in applicable laws, regulatory guidance, or business operations.

14.2

Any amendments to this policy shall be approved by the Board of Directors and communicated to all Covered Persons.

15. Contact Information

For any questions regarding this policy, or to report a suspected breach, please contact:

• Langkawi Hot Spot Vacation Sdn Bhd
• Compliance Officer
• No 33C, Persiaran Banyan Square, Jalan Bukit Banyan, Bukit Banyan, 08000 Sungai Petani, Kedah
• Email: langkawihotspot@gmail.com
• WhatsApp: +6012 590 9975
• MACC Hotline: 1-800-88-6000
• MACC Website: www.macc.gov.my