COLLECTION OF PERSONAL DATA

Pursuant to the requirement of the Personal Data Protection Act 2010, KSL City Management Sdn Bhd and its respective subsidiaries, associate companies, and jointly controlled entities (the terms “we” or “us” or “our” or KSL) are issuing this notice to all our valued customers/prospective customers.

NATURE AND DEFINITION OF PERSONAL DATA

Personal Data means information in respect of commercial transaction that relates directly or indirectly to an individual (“data subject”), who is identified from that information alone or with other information including any sensitive personal data and expression of opinion about a data subject. Examples of Personal Data includes but not limited to information such as name, age, address, identity card number, passport number, gender, date of birth, marital status, occupation, contact number and email address.

NATURE AND DEFINITION OF SENSITIVE PERSONAL DATA

Sensitive Personal Data means any personal information consisting information including but not limited to physical or mental health or condition of a data subject, political views, his religious beliefs or other beliefs of a similar nature, the commission or alleged commission by him of any offence or any other personal data. We shall not process any of your sensitive personal unless explicit consent has been obtained from you.

PURPOSE OF COLLECTING YOUR PERSONAL DATA

Your Personal Data will be/is being collected, used and otherwise processed for but not limited to the following purposes : -

1. communication with you;
2. Sending update of events, promotions, marketing materials and information of our future expansions;
3. Conducting research on your preference or performing statistical and analysis of your behaviour to try to meet your needs better;
4. Making such disclosers as may be required by law;
5. for administration purposes.

SOURCE OF PERSONAL DATA

Your Personal Data will be collected, processed and used by us are sourced from wholly legitimate and transparent means such as :

1. official registration forms (either electronic or printed) for road shows, showcases exhibitions or any other promotional events;
2. official Request for Information forms that are provided to you by our employees or agents;
3. any emails or any correspondences that we have received from you requesting for information or making any inquiries;
4. any forms that you have submitted on our website or any websites contracted by us;
5. any referrals from a person which have included their verifiable personal contact details;
6. Business cards that were dropped or given to our employees, agents, brokers or associates; or
7. any documents (including but not limited to statutory forms and returns) that were submitted to us for processing.

At no time will any personal data be purchased by us or in any way commercially acquired through the purchase or trading of illegitimate and illegal Personal data, databases or lists.

FAILURE OF NOT PROVIDING YOUR PERSONAL DATA

The failure to supply such Personal Data will :

1. result in us being unable to provide customers / prospective customers with the notices, services and/or products requested;
2. result in us being unable to update you on our latest product and/or launches;
3. affect the ability for us to comply with any applicable law, regulation, direction, court order, by laws, guidelines and/or codes applicable to us.

DISCLOSING YOUR PERSONAL DATA

The information we gather is not sold, given to, or otherwise shared with other organizations for commercial or any other purposes. We do, however, send out e-mails on behalf of selected organizations to those of our subscribers who have opted in to receive these messages. We send the messages directly, so at no time do the advertisers get to see users’ personal data unless users respond or reply to the advertisements or mailing themselves.

Your personal data will be kept confidential at all times by us but you hereby irrevocably consent and authorize us to disclose your personal data to the following categories of parties for the Purposes set out under Section 4 above to the following either in Malaysia or out of Malaysia:

1. to any related, affiliated and subsidiaries of KSL in or out of Malaysia, including those incorporated in the future;
2. to our business partners and online affiliates that provide related service or products in connection of our business;
3. to our advisers, including auditors, consultants, advocated and solicitors, lawyers or other financial or professional advisers;
4. to any agent, contractor or service provider to whom we may have outsourced services to, subject always that such parties acknowledge the confidentiality and rights of the data user and to comply with the provisions of the Act;
5. to regulatory authorities or notified bodies providing quality certification of our products upon their request;
6. to any persons, government agencies, statutory authorities and/or industry regulators whom we are compelled or required to do so
7. to any relevant parties, please refer to “Appendix A2-List of Non-Governmental bodies/agencies/local authorities and private institutions”;
8. our appointed service providers in relation to our loyalty programme, for the purpose of delivery of gift redemption and services; and/or
9. our third party service providers, third-party management companies, sub-contractors or other parties as may be deemed necessary by us to facilitate your dealings with us.

Third parties are legally tasked with processing your personal data in line with principles specified by us. When using your personal data for the purposes stated in Section 4, we will require the third parties to handle your personal data using the same level of care that we apply. We will also require them to only use your personal data according to our instructions and directions.

Third parties are also held legally responsible for securing your personal data at an appropriate level of security in relation to applicable data protection laws and widely accepted industry standards.

DATA TRANSFER AND SHARING

Where we consider it necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your personal data to another member of our Group or third party service or product providers within or outside Malaysia, in which we are established, under conditions of confidentiality and similar levels of security safeguards.

DATA INTEGRITY

It is your responsibility to ensure that all your personal data submitted to us are accurate, not misleading, updated and complete in all aspects. You shall by notice in writing to us of any changes to your personal data supplied to you by us to ensure that all your personal data is kept up-to-date. We shall not be held liable or responsible for any personal data submitted by you to us that is inaccurate, misleading, incomplete or not updated.

RETENTION OF YOUR PERSONAL DATA

We shall retain your personal data for as long as necessary for the Purposes above mentioned and/or as otherwise permitted by applicable law. We shall destroy and/or delete any personal data from our system in the event such data is no longer required for the Purposes and/or as otherwise permitted by applicable law.

SECURITY MEASURES

We respect every customer’s right to privacy and security of information. As such, we shall take appropriate and reasonable measures to protect the personal data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction when processing the personal data.

ACCESS TO YOUR PERSONAL DATA AND CORRECTION

You have the right to request access to and correction of information about you held by us and in this respect, you may :

1. check whether we hold or use your personal data and request access to such data;
2. request that we correct any of your personal data that is inaccurate, incomplete or out-of-date;
3. request that your personal data is retained by us only as long as necessary for the fulfillment of the purposes for which it was collected;
4. request that we specify or explain its policies and procedures in relation to data and types of personal data handled by us;
5. communicate to us your objection to the use of your personal data for marketing purposes whereupon we will not use your personal data for these purposes; and
6. withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period.

The customers may access and request for correction of the Customer’s personal data and to contact us with any enquiries or complaints in respect of the Customer’s personal data as follows:

Marketing Department

The Customer’s personal data may be disclosed to our parent company, subsidiaries, related and/or associated company, licenses, business partners and/or service providers for any of the above Purposes or any other purpose for which the Customer’s personal data was to be disclosed at the time of its collection or any other purpose directly related to any of the above Purposes.

It is obligatory that the Customer supplies us with the personal data. If the Customer fails to supply us with the requested personal data, we may not be able to process the personal data for any of the above “Purposes”.