PDPA Notice

1. INTRODUCTION

Jesselton International Sdn Bhd and its group of companies (“Jesselton International”) respect your right to privacy and we respect all personal data you provide to us. We are commited to protecting the personal data supplied by you to us. Jesselton International is bound by the Personal Data Protection Act 2010 (“PDP Act”) and all other applicable law in Malaysia in respect of privacy protection which sets out a number of principles concerning personal data and consumer protection in Malaysia.

For the purpose of this Privacy Policy, “personal data” shall have the meaning as ascribed to it in the PDA Act which means any information in respect of commercial transactions, which:-

• is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose;
• is recorded with the intention that it should wholly or partly be processed by means of such equipment; or
• is recorded as part of a relevant filing system or with the intention that it should form part of relevant filing system,

That relates directly or indirectly to a data subject, who is identified or identifiable from that information or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject; but does not include any information that is processed for the purpose of a credit reporting business carried on by a credit reporting agency under the Credit Reporting Agencies Act 2010.

2. TYPES OF PERSONAL DATA COLLECTED

During the course of your transaction and dealings with Jesselton International, you may be requested to furnish from time to time to Jesselton International, directly or through online forms and/or other electronic methods, your personal data, which may include your name, gender, age, marital status, date of birth, race, nationality, identity card number, passport number, visa information, correspondence address, email address, telephone contact number, occupation, income range, credit card or bank account information, financing details for the purchase of the property of Jesselton International’s housing development project and/or other information relevant to the purposes listed in Paragraph 3(a) below.

The types of personal data collected will be depending on the nature of your dealings or transaction with Jesselton International.

3. PURPOSE OF COLLECTION

• Jesselton International may collect, retain, use and otherwise process your personal data for the following purposes: –
• providing you with services under any business of Jesselton International; or
• processing your application or registration under any program and/or activities organized or conducted by Jesselton International or in connection with your employment application; or
• notifying you of services or launches of properties or products whether present or future, updates and promotions including delivery of notices and sending any advertising and/or marketing material, to you (including notices through social medias); or
• sale of the products and/or properties offered by Jesselton International, to you which shall include all matters relevant for the completion of the sale and purchase transactions, delivery of vacant possession, defect rectification works and other post vacant possession services; or

• entering into any transactions, agreement or instruments in the ordinary course of business of Jesselton International; or
• discharging Jesselton International’s contractual obligations in the oridinary course of business Jesselton International; or
• property and/or estate management; or
• collection of any payments due and payable to Jesselton International including late interest charges; or
• credit assessments and other background verification that may be necessary or appropriate for Jesselton International’s business or employment purposes; or
• human resource management; or
• sending you services, products or promotional information related to other third parties which Jesselton International thinks you may be interested; or
• discharging Jesselton International’s duties and obligations under the Companies Act 2016 and any other applicable law, regulation, direction and guideline applicable to Jesselton International; or
• for other legitimate business activities of Jesselton International; or
• in anticipation of, and in the course of an actual or potential sale, reorganization, consolidation, merger, or amalgamation of all or part of Jesselton International’s business or operations; or
• for any other purpose that is incidental or ancillary or in furtherance to the above purposes.

• To facilitate any of the purposes of Paragraph 3(a) above, it is obligatory for you to supply Jesselton International with sufficient personal data as required by Jesselton International. If you fail to supply the personal data as required:-

• Jesselton International will not be able to provide you with the necessary notices, services and/or products requested;
• Jesselton International will not be able to process your application or registration for any of the necessary services, products, programs and/or activities; and/or
• Jesselton International will not be able to enter into the necessary transaction, agreement or dealing with you or in your favour.

• If you do not want Jesselton International to disclose, transfer, use or process otherwise your personal data for any of the purposes listed in Paragraph 3(a) above or if you wish to withdraw your consent in full or in part or limit the processing of your personal data, you may contact Jesselton International in writing at the particulars set out in Paragraph 7(c) below.

4. DISCLOSURE

Jesselton International my disclose your personal data to the following categories of third party as may be required for any of the above purposes as stipulated in Paragraph 3(a) or for other legitimate purposes: –

• Companies Commission of Malaysia, Bank Negara Malaysia, Official Assignee’s Office of the Insolvency Department of Malaysia, any other person, body or government agency under the requirements of any applicable law or order, direction or regulation of any regulatory or appropriate authorities;
• any related companies and subsidiaries within Jesselton International;
• Jesselton International’s business partners and affiliates;
• Jesselton International’s auditors, consultants, accountants, lawyers or other financial or professional advisers including any relevant financial institutions;
• Jesselton International’s agents, contractors, sub-contractors, network operations, third party service or product providers;
• third party property management companies;
• any financial institutions, lawyers and professional advisers appointed by you;
• any other persons under a duty of confidentiality to Jesselton International; and/or
• any other entities that Jesselton International may think fit.

5. SECURITY POLICY

Jesselton Group shall take practical steps to safeguard your personal data against any loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction by having regard:

• to the nature of the personal data and the harm that would arise;
• to the place or location where the personal data is stored;
• to any security measures incorporated into any equipment in which the personal data is stored;
• to the measures taken for ensuring the reliability, integrity and competence of personnel having access to the personal data; and
• to the measures taken for ensuring the secure transfer of the personal data.

Jesselton International shall ensure that any security policy developed or implemented by Jesselton International complies with the security standard required under the PDA Act and any applicable law that may from time to time be in force.

It may be necessary to transfer your personal data to other entities or service providers located in countries outside Malaysia. This may happen where Jesselton International’s servers or suppliers and service providers are based outside Malaysia or where you use the services from countries outside Malaysia. In these instances, Jesselton International will take steps to ensure that your privacy rights are respected in accordance with this Privacy Policy.

6. DURATION OF RETENTION

Jesselton International will retain any personal data supplied by you as long as the purpose it was collected for remains valid or otherwise permitted by any applicable law that may from time to time be in force.

If any personal data is no longer required for the purpose for which it was processed, Jesselton International shall take all reasonable steps to ensure that it is destroyed or permanently deleted.

7. RIGHT OF ACCESS AND CORRECTION

Under the PDP Act, you have the right of access to your personal data held by Jesselton International upon payment of a prescribed fee as per the Personal Data Protection (Fees) Regulation 2013.

If you know that your personal data held by Jesselton International is inaccurate, incomplete, misleading or not up-to-date, you may make a data correction request in writing to Jesselton International. You may submit your written request or any inquiries in writing to Jesselton International at the following address:

BY PROVIDING YOUR PERSONAL DATA TO JESSELTON INTERNATIONAL AND RELATED COMPANIES, YOU HEREBY AGREE THAT JESSELTON INTERNATIONAL SHALL PROCESS YOUR PERSONAL DATA IN ACCORDANCE WITH ALL OF THE FOREGOING