PERSONAL DATA PROTECTION NOTICE
In compliance with the Malaysian Personal Data Protection Act 2010 (“PDPA”), we, VisionEthics, a company provides advisory services on integrity, governance and corruption prevention in Kuala Lumpur, Malaysia (“Company”) respect your right to privacy. We are committed to the protection of your Personal Data and your privacy.
This Personal Data Protection Notice (“Notice”) sets out how our Company collects, uses and protects your Personal Data obtained through your engagement of our services, through your email or other communication with us, through our general business contact with you, through your participation in our events, seminars and/or other promotional activities, and through our Company’s website at www.visionethics.com/= (“Website”) (collectively referred to as “Engagement”). This Notice does not address information collected through other sources such as personal contacts.
For the purpose of this Notice, the terms ‘Personal Data’ and ‘processing’ shall have the meaning prescribed in the PDPA.
1. PERSONAL DATA WE COLLECT
1.1. The “Personal Data” that you provide or have provided to the Company includes your name, contact details, address, email address, national registration identity card number (NRIC No.) or passport number, designation, company name and all other details provided by you in the documents which we have collected or received from you, or which we will collect or receive from you, and/ or from the information you have provided to us, in your emails and/or in any correspondence between you and us.
1.2. In addition to the Personal Data that you provide to the Company directly (whether when engaging us to provide our services or during any communication with the Company or at any time), the Company may also collect your Personal Data from various other sources, including without limitation, from online search tools, publicly available information systems, public records searches, information obtained from third parties through lawful sources including but not limited to Companies Commission of Malaysia, National Registration Department of Malaysia, Insolvency Department of Malaysia, CTOS Data System or at events organised or attended by members of the Company.
1.3. In respect of Personal Data of third parties such as your spouse and family members, you warrant that you have obtained their consent allowing us to process their Personal Data and you will extend a copy of this Notice to them.
2. HOW WE USE THE PERSONAL DATA WE COLLECT
2.1. By engaging the Company, you hereby agree and consent to the Company using and processing your Personal Data provided to the Company, in the manner and for the purposes as described below:
a. to provide our advisory services on integrity, governance and corruption prevention to you;
for preparing any document or instrument which may be required for the purposes set out in sub-paragraph (a) above and
b. to provide such necessary information to any regulatory or governmental authorities as required by statutory, regulatory or governmental requirements;
c. for the Company’s internal administrative purposes including historical and conflict checking purposes;
d. for the Company to correspond with you in the course of our business either as a client or as business contact; and
e. for the Company to comply with its obligations under law or any regulations imposed by regulatory or governmental authorities. (collectively, “Purposes”)
2.2. It is voluntary for you to supply your Personal Data to the Company. However, if you do not wish to provide your Personal Data, the Company may not be able to:
a. provide you the services that you require; and
b. communicate effectively with you.
2.3. The Company may also use and process your Personal Data for other purposes such as:
a. to send you materials such as season greeting cards, newsletters, articles, write-ups and other updates, distribute information of events, conferences, talks and seminars which may be of interest to you; and
b. potential referees to editors / researchers in legal ranking publications and journals and potential clients who request for referees of past work in our credential statements, tenders and submissions, if any, by way of email or mail.
2.4. If you do not agree or consent to the Company processing your Personal Data for the purposes set out in this paragraph 2.3, please notify the Company by contacting the Company via the contact details set out in paragraph 7.1 below.
3. DATA WE SHARE
3.1. Your Personal Data provided to the Company or obtained by the Company shall be kept confidential by the Company. However, it may be necessary for the Company to engage third party companies, service providers or individuals to perform certain services on the Company’s behalf. In such event, you hereby agree and consent that the Company may disclose and transfer your Personal Data to the third parties, within or outside Malaysia, including without limitation, as follows:
a. banks and/or financial institutions;
b. insurance providers;
c. storage facility providers;
d. external advisors and other professional advisors, such as company secretaries, accountants, auditors or tax agents; and
e. such other party as the Company deems necessary for the purposes mentioned in paragraph 2 above.
3.2. The Company shall also disclose and transfer the information to any statutory bodies, regulatory bodies and / or governmental authorities where legally required to do so.
4. EMAIL AND WEBSITE
4.1. Any Personal Data contained in the emails and “Contact Us” messages sent via the Company’s Website to the Company shall be used and processed in the manner set out in this Notice. The content of the messages shall be strictly monitored by the Company.
4.2. 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.
4.3. The privacy practises set out in this Notice are for the purposes of your Engagement with us only. The Company’s Website may contain links to other sites and pages. The Company shall not be responsible for any Personal Data or information that you may provide to other entity via the links.
5. REQUEST FOR ACCESS AND INQUIRIES
5.1. You may at any time request for access to, or request for rectification or correction of your Personal Data, subject to payment of certain fees, or limit the processing of your Personal Data by the Company, as the case may be, however subject to the exceptions and restrictions as may be contained under the applicable law. If you wish to do so, please contact us in the manner as described below.
5.2. You may also contact the Company if you have any inquiries or complaints in respect of your Personal Data provided to the Company.
5.3. Please note that the Company has the right to refuse your request to access and / or make any correction to your Personal Data to the extent permitted under the applicable law.
6.1. If we do not receive any notification from you concerning our processing of your Personal Data, we shall proceed to continue to process the same for the Purposes as set out, on the basis that you have consented to our processing of your Personal Data in accordance with our Notice.
6.2. The Company reserves the right to amend or modify this Notice from time to time. Please check our Personal Data Protection Notice frequently and particularly before you submit additional information. All revisions to this Notice will be posted on the Website through a link from the homepage.
6.3. This Personal Data Protection Notice is issued in both English and Bahasa Malaysia. In the event of any inconsistencies or discrepancies between this English version and the Bahasa Malaysia version, this English version shall prevail.
7. CONTACT US
7.1. For questions or comments about our Personal Data Protection Notice, or if you need assistance accessing or updating information we have collected about you, please contact:
Telephone : +603 2722 4630
Email :[email protected]
Address: Spaces Platinum Sentral, Jalan Stesen Sentral 2, Level 3, 4 & 5, Block D, Platinum Sentral, 50470, Kuala Lumpur,Malaysia.
Dated: 1 March 2021