1. Collection and Processing of Personal Data
We hereby inform you that we, Industrial Malaysia, our affiliated business partners, including but not limited to our associated firms (whether or not controlled by us), as data user(s), as the term is defined in the Personal Data Protection Act 2010, have or will collect, record, hold, store, use, disclose and/or process (collectively referred to as “Process”) one, or all of the following categories and/or types of personal information about you, when you use our services:
- Master data: name, gender, date of birth, citizenship, marital status, nationality, race, ethnic origin, identification card/passport details, qualifications, occupation, employer, former employer(s), voice recordings, photographs or other images;
- Contact details: home & correspondence addresses, phone number for home, mobile and work, email address, work address.
- Employment and compensation/financial information: such as amount, currency, number of payments per year, bank account details, income tax file numbers, income range; details of applicable bonus, incentives and commission plans, EPF details, types of loans applied for in relation to a purchase of property, as well as introducer’s name, address and identity card number;
- any other such information as we deem necessary or appropriate from time to time in connection with your commercial relationship with us;
2. Sources of Information
- Information provided or submitted by you through, among others, as applicable the Registration Form, Letters of Appointment, business contracts, etc – received via email, or facsimile, manual or online submission, webpage, sales forms, etc;
- as applicable, publicly available or publicly accessible information; and
- such other written or verbal communications or documents delivered to us prior to, and during, the course of our contractual, or pre-contractual, dealings with you
3. Purpose of Processing Personal Data
We will process the Personal Data that you have provided to us for the following purposes, including but not limited to:
the delivery of notices, services and/or products to you;
the entry into the necessary agreement(s) and/or contract(s) in marketing and/ administration of real estate properties/listings through us;
- user or client/customer management procedures;
- those purposes specifically provided for in any particular service/product offered by us;
- credit assessments and other background checks of users as we may determine to be necessary or appropriate;
- our internal record keeping;
- collection of outstanding payments from clients and/or customers;
- public safety and/or prevention of crime, including but not limited to fraud, money laundering, bribery;
- meeting any legal or regulatory requirements relating to our provision of services and products; and/or to make disclosure(s) under the requirements of any applicable law, regulation, direction, court order, by-law guideline, circular, code applicable to us or any of our affiliates and associated co-agency estate agency firms/business partners (whether or not controlled by us),
- for research, training, benchmarking, market analysis including statistical analysis purposes and other like purpose;
- vacant/legal possession, keys handover, tenancy administration, customer care;
- conducting marketing and client profiling activities in connection with our services and related products;
- post vacant/legal possession, delivery-related services, such as customer loyalty programs, and/or to enable us and/or our selected authorized third parties to send you information/bulletins by email, telecommunication (telephone calls and text messages) or via social media concerning related and/or unrelated products and services offered by us and our business partners which may include, but are not limited to, the above-mentioned purposes which we consider will, or may, interest you.
(collectively known as “Purpose”)
4. Storage and Security
We store your Personal Data in hard and/or soft copy. Soft copy data is stored on, amongst others, the file server, e-mail server, personal computers, notebooks, tapes and compact discs. Reasonable security procedures are in place, which, among others, confines access to your Personal Data to only our staff and authorised agents / affiliated business partners on a strictly need to know basis such as administration, finance, sales and/or customer service departments. We may retain the Personal Data and that of other individual(s) that you provide to use for a reasonable period in accordance to commercial requirements; at all times subject to prevailing legal requirements.
5. Disclosure of Personal Data
The Personal Data provided to us will, generally, be kept confidential; however, you hereby consent and authorize us to provide and/or disclose your Personal Data to the following categories of parties;
- any person who we are compelled or required to do so under law or in response to a legitimate instruction from a competent or government agency;
- pursuant to an order of a court of competent jurisdiction;
- any related companies and/or subsidiaries including those established in the future;
- where applicable, third parties including our associated business partners of Ping Properties, who/which provide related services or products in connection with our estate agency practice business;
- government agencies, statutory authorities and industry regulators;
- our auditors, consultants, accountants, lawyers or other financial or professional advisors;
- our sub-contractors or third parties’ service and/or product providers as we may determine to be necessary or appropriate;
- third party tenancy administration companies/entities in respect of the tenancy administration of a property that customers have purchased; and/or our appointed service providers in relation to our loyalty programs, for the purpose of gift redemption and services.
We shall keep and Process your Personal Data in a secure manner. We will take all reasonable steps to ensure that such information is kept confidential. We will not sell, rent or trade your Personal Data. We endeavour to, where practical, implement the legally mandated and/or appropriate administrative and security safeguards and procedures in accordance with the applicable laws and regulations in order to prevent the unauthorized or unlawful processing of your Personal Data and the accidental loss or destruction of, or damage to, your Personal Data.
7. Data Transfer and Sharing
In addition, you will appreciate that the nature of our products and services are such that it may be necessary, where we consider it appropriate, for the purposes of data storage or Processing or providing any service or product on our behalf to you, to transfer your Personal Data to our affiliates and/or associated business partners including our co-agency estate agency companies (whether or not controlled by us) and/or third party service or product providers within or outside the country in which we are established, under conditions of confidentiality and similar levels of safeguards.
8. Impact resulting from failure to supply and consent to the Processing of Personal Data
It is obligatory for you to provide all categories of Personal Data which we request from you for the said Purpose. Failure to supply and consent to the Processing of the Personal Data in relation to the Purpose will:
- result in us being unable to provide you (i.e Client(s) /Customers / Prospective Clients/Customers; including candidates applying for a job at Ping Properties, etc) with the information, notices, services and/or products requested; and/or
- result in us and/or our selected authorized third parties to send you information by email, telecommunication (telephone calls and text messages) or via social media concerning related or unrelated products and services offered by us and our affiliated business partners which we consider will or may interest you.
9. Your Rights of Access and Correction
You have the right to, subject to payment of the prescribed fees where applicable, request for access to and/or correct your Personal Data and/or limit the Processing thereof. In this respect, you may:
- check whether we hold or use your Personal Data and request access to such data;
- request that we correct any of your Personal Data and request access to such data;
- request that your Personal Data be retained by us only as long as is necessary for the fulfilment of the purposes for which it is collected;
- request that we specify or explain our policies and procedures in relation to Personal Data and the categories of Personal Data processed by us;
- 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 person to whom written requests for access to Personal Data or correction and/or deletion of Personal Data or for information regarding policies and procedures and types of Personal Data is:
Privacy Officer: The administrator
Email Address: firstname.lastname@example.org