Konexo Malaysia Sdn Bhd (“We”, “Our”, “Us”) is committed to protecting your privacy and personal data.
Our Policy is in compliance with the Personal Data Protection Act 2010 (“PDPA”). For the purposes of PDPA, Konexo Malaysia is the “data user” (i.e. the company who is responsible for and controls the processing of personal data provided by you).
By visiting our website or interacting with us or providing your personal data to us, you are deemed to have read and consent to the data practice described in this Policy.
- COLLECTION OF PERSONAL DATA
- 1.1 We collect and use your personal data provided to us which includes (but is not limited to) your name, address, telephone number, nationality, identification/passport number, date of birth, occupation, bank account details, photograph, email address, particulars of family members and/or other dependants and any other information that may identify your or your family members and/or other dependants, as well as any sensitive personal data, as defined under the PDPA, which includes (but is not limited to) information pertaining to the physical or mental health or condition of the data subject and religious beliefs or other beliefs of a similar nature (collectively referred to as “Personal Data”).
- 1.2 In addition to the Personal Data that you provide to us directly (whether when engaging us to provide our services or during any communication with us), we may also collect your Personal Data from various other sources, including without limitation, from online search tools, information obtained from third parties through lawful sources or at events organized or participated in by us or from the cookies used on the website.
- 1.3 In respect of Personal Data you have provided of third parties such as family members and/or other dependants, you warrant that you have obtained their consent for allowing us to process (including disclosure and transfer) of their personal data and you will extend a copy of this Policy to them. Regarding minors (i.e. individuals under 18 years of age) or individuals not legally competent to give consent, you confirm that they have appointed you to act for them and to consent on their behalf to the processing (including disclosure and transfer) of their Personal Data in accordance with this Policy.
- PURPOSE OF PROCESSING PERSONAL DATA
- 2.1 By engaging with us, you hereby agree and consent to us using and processing your Personal Data which you have provided to us, in the manner and for the purposes (collectively referred to as the “Purposes”) as described below:
- (a) for the purpose of our services to you;
- (b) for preparing any document or instrument which may be required for the purposes of our services to you;
- (c) for us to communicate with you;
- (d) for our internal administrative purposes and / or internal record keeping;
- (e) for organising events and programmes for you;
- (f) for sending material such as newsletters, articles and other updates;
- (g) for sending marketing and promotional materials to you;
- (h) to provide such necessary information to any regulatory or governmental authorities as required by statutory, regulatory or governmental requirements;
- (i) to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
- (j) to enable us to send you information that might interest you by e-mail, telecommunication means (telephone or text messages) or social media; and
- (k) for any purpose incidental, ancillary or in furtherance to the abovementioned purposes.
- 2.2 If you do not agree or consent to us using your Personal Data for the Purposes set out in paragraph 2.1 above, please notify us via the contact details set out in paragraph 9 below.
- 2.3 It is voluntary for you to provide your Personal Data to us. However, if you do not wish to provide your Personal Data, then we may not be able to carry out the Purpose.
- DISCLOSURE OF PERSONAL DATA
- 3.1 Your Personal Data provided to us or obtained by us shall be kept confidential. However, it may be necessary for us to engage third party companies, service providers or individuals to perform certain services on our behalf. In such event, you hereby agree and consent that we may disclose your Personal Data to the third parties, as follows:
- (a) any person to whom we are compelled or required to do so under law or in response to a competent regulatory or government agency;
- (b) government agencies, statutory authorities and industry regulators;
- (c) other Konexo Entities, our parent company Eversheds Sutherland (International) LLP and members of the Eversheds Sutherland network of firms (please see here for further details of the Konexo Entities);
- (d) external advisors and other professional advisors, such as lawyers, auditors, tax consultants, accountants, insurers and other financial or professional advisors;
- (e) banks and financial institutions; and
- (f) any other party that we deem necessary for the Purposes, as outlined in paragraph 2.1 above.
- TRANSFER OF PERSONAL DATA
- 4.1 We operate globally and where we consider it necessary and appropriate, we may transfer your Personal Data to other Konexo Entities, our parent company Eversheds Sutherland (International) LLP, members of the Eversheds Sutherland network of firms or to a third party service or product providers within or outside Malaysia for the performance of the Purpose, under conditions of confidentiality and similar levels of security safeguards. We may also in limited circumstances share your Personal Data with government authorities or others as required to protect our business interest or others, as necessary or as required by applicable law or court order.
- 4.2 Konexo is the name and brand under which the Konexo Entities provide services to clients around the world. For more information on the Konexo Entities and their relationship with Eversheds Sutherland, a global provider of legal services, please click here.
- SECURITY OF PERSONAL DATA
- 5.1 We are committed to ensuring that your Personal Data is stored securely. In order to prevent unauthorised access, disclosure or other similar risks, we endeavour, where practicable, to implement appropriate technical and organisational security measures in accordance with the applicable laws and regulations to prevent the unauthorised or unlawful processing of your Personal Data, and the destruction of, or accidental loss, or damage to, or unauthorised disclosure or access to your Personal Data.
- RETENTION OF PERSONAL DATA
- 6.1 Any of your Personal Data provided to us is retained for as long as the Purpose for which the Personal Data was collected continues.
- 6.2 Your Personal Data will be destroyed from our records and system in the event your Personal Data is no longer required for the said Purpose unless its further retention is required to satisfy a longer retention period to meet our operational, legal, regulatory, tax or accounting requirements.
- YOUR RIGHTS TO REQUEST FOR ACCESS AND INQUIRIES
- 7.1 You have the right to request for access to, or request for rectification or correction of your Personal Data. Should you be made aware of any inaccurate, incomplete or misleading Personal Data, kindly inform us at the details provided in paragraph 10 below.
- 7.2 In respect of your right to access and/or correct your Personal Data, please note that we have the right to refuse your request to access and/or make any correction to your Personal Data for reasons permitted by law.
- 7.3 You have the right at any time to request us to limit or object to the processing and use of your Personal Data (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes).
- 7.4 In addition to the above, you also have the right by notice in writing, to inform us on your withdrawal (in full or in part) of your consent given previously to us.
- 7.5 If you wish to do any of the above, please contact us via the contact details provided in paragraph 10 below.
- ACCURACY OF YOUR PERSONAL DATA
- 8.1 We aim to keep all Personal Data as accurate, complete, not misleading, up-to-date and reliable as possible. Therefore, the accuracy of your Personal Data depends to a large extent on the information you provide. As such, it is a condition of us providing our services to you that you;
- (a) warrant and declare that all your Personal Data submitted or to be submitted to us are accurate, not misleading, updated and complete in all respects for purposes of acquiring our services and you have not withheld any Personal Data which may be material in any respect; and
- (b) promptly update us as and when such Personal Data provided earlier to us becomes inaccurate, incomplete, misleading, outdated or changes in any way whatsoever by contacting us at the contact details mentioned in paragraph 10 below.
- EMAIL AND WEBSITE
- 9.1 Any Personal Data contained in the emails and ‘Contact Us’ messages sent via our website to us shall be used and processed in the manner set out in this Policy. The content of the messages shall be strictly monitored by us.
- 9.2 If you do not wish for your Personal Data to be collected via cookies on the website, please configure your internet browser to delete or deactivate cookies.
- 9.3 Our website may contain links to other sites and pages. We shall not be responsible for any Personal Data or information that you may provide to other entity via the links.
- CONTACT DETAILS
- 10.1 If you have any questions about this Policy, or have further queries, or would like to exercise any of your rights outlined in Paragraph 7 above such as making a complaint or data access or correction request in respect of your Personal Data, you may contact us at the contact details below:
Email: email@example.com (marked for the attention of the Data Steward)
Address: The Data Steward, Konexo Malaysia SDN BHD, Unit 12-02, Tower 8, Avenue 5,The Horizon, Phase 2, Jalan Kampung Kerinchi, Bangsar South, 59200 Kuala Lumpur
- 10.2 In the event of any change in your personal data you are obliged to promptly contact and notify us via the contact details set out in paragraph 10.1 above.
- 11.1 In the event of any conflict between this English language Policy and its corresponding Policy in the Malay language, the terms in this English language Policy shall prevail.
- 12.1 We reserve the right to modify, update and/or amend this Policy from time to time with reasonable prior notice to you. We will notify you of any amendments via announcements on the Website or other appropriate means.
Dated: 17 August 2020