This Personal Data Protection Notice (“ Notice”) describes how Eastern & Oriental Berhad, E&O Property Development Berhad, Tanjung Pinang Development Sdn Bhd, E&O Trading Sdn Bhd and their respective subsidiaries, related corporations, associated companies, affiliates and jointly controlled entities as well as their representatives (collectively referred to as “ E&O Group”) collect, use, process and disclose your Personal Data. For the purposes of this Notice, the terms “ Personal Data”, “ sensitive personal data”, “ collect”, “ use”, “ disclose” and “ processing” shall have the same meaning as prescribed in the Persona Data Protection Act 2010 (“ Act”) (as may be amended from time to time) and its corresponding regulations, guidelines, notices and/or practices issued thereunder.

For the purposes of this Notice, the terms “ we”, “ our” and “ us” shall refer to any company or representative within E&O Group and the terms “ you” or “ your” shall refer to yourself and/or such other persons or companies represented by you of which you are providing Personal Data.

Description of Personal Data and Sources of Personal Data




1. “ Personal Data” means a variety of personal data (including sensitive personal data and biometric data), information about you, from which you are identifiable, including but not limited to your name, National Registration Identification Card (“ NRIC”) number or passport number, address, telephone number, email address, date of birth, age, or any information about you which you have provided to the E&O Group including but not limited to registration forms, purchase forms, booking forms and/or any information about you that has been or may be collected, stored, used and processed by the E&O Group from time to time.

   
   

   The list of Personal Data stated above is not exhaustive and may include other Personal Data depending on the nature of dealings or transaction with E&O Group.




2. In addition to the Personal Data you provide to the E&O Group directly, the E&O Group may also collect your Personal Data from a variety of sources (in printed or electronic forms through digital and/or mobile platforms), including without limitation:

   
   
   1. when you register your interest in any E&O Group projects or properties, when you purchase a property from the E&O Group, from the E&O Group’s property agents or other third-party property agents, when you interact and communicate with the E&O Group at exhibitions, events, roadshows or otherwise, from companies under the E&O Group, when you make enquiries, or by using the Website as defined under Clause 21 of this Notice. Cookies used on the Website may also collect your Personal Data. If you do not wish for your Personal Data to be collected via cookies on the Website, you may deactivate cookies by deleting your browsing history and clearing the cache from your internet browser.
   2. from the forms submitted or filled in by you or on your behalf to us (including without limitation, due diligence questionnaire form, employment application form, curriculum vitae and/or resume) via any Platform as defined under Clause 3(n) of this Notice and/or physical documents;
   3. healthcare service providers or professionals and medical certificates or records;
   4. when you visit our Premises (as defined under Clause 3(o) of this Notice) in person;
   5. via any Platform and/or cookies;
   6. from any information or document submitted or provided by you to us for any of the Purposes as defined under Clause 3 of this Notice (such as your NRIC or passport);
   7. when you inquire about job vacancies and opportunities with us;
   8. when you contact us through various methods such as telephone calls, emails and/or the Platform;
   9. from the E&O Group’s closed-circuit television (“CCTV”);
   10. information obtained during your job interview with us;
   11. your referees and former employers;
   12. from time attendance module and access cards;
   13. any third parties (including without limitation credit reference bodies, recruitment agencies, background check agencies, regulatory and law enforcement authorities and other third party sources); and/or
   14. from all other communications between you and us and all other information that you may provide to us from time to time.



Purposes of Processing




3. The E&O Group may use and process your Personal Data for the purposes relating to the business and activities of the E&O Group which shall include, without limitation: -

   
   
   1. where you have purchased or tenanted or leased a property from the E&O Group or you are a licensee or licensor of the E&O Group or where you have supplied or provided any services to the E&O Group:
      
      
      • to process your purchase/tenancy/lease/license/service applications, including for the purposes of preparing the legal documentation in relation thereto;
      • for purposes of billing and payments relating to the property you have purchased;
      • to send notices and communicate with you, including to update you on the progress of the construction of the property you have purchased;
   2. to respond to questions, comments and feedback from you;
   3. for internal administrative purposes, such as auditing, data analysis, and to improve our services;
   4. to send you news releases/ information on the E&O Group and/or to invite you to the E&O Group meetings;
   5. organising, participating in, managing and/or carrying out duties in connection with our events, contests, tournaments, competitions, programmes and other activities organised or sponsored by us or on our behalf (“Events”) and advertising and providing you with information (such as Events, offers or promotions) relating to our and our related corporations’ and business partners’ products and/or services, including without limitation sending you e-newsletters, promotional marketing materials, seasonal/birthday greetings and messages, gifts and/or vouchers;
   6. for the E&O Group to comply with its obligations under law;
   7. ensuring the performance by you of your pre-contractual and contractual obligations to us;
   8. to administer and give effect to the employment/contract for service with you and obtaining professional advice;
   9. conducting background checks and credit reference checks and verifying your credit worthiness, where necessary;
   10. verifying and carrying out financial transactions in relation to payments made by or to you and administering and processing any payments related to products and/or services requested or provided by you;
   11. dealing with administration, billing, complaints and any other purposes relating to your property;
   12. human resource and internal administration and management purposes, including without limitation for purposes related to data storage and management;
   13. purposes related to our company functions;
   14. allowing you to connect to the wifi facilities provided by us or our service provider and/or to access any online platforms or sites owned, operated or managed by us or on our behalf, including without limitation straitsquay portal, Tanjung Pinang Development portal, E&O hotel portal, or E&O’s main website and others (“Platform”);
   15. granting you access to any relevant facilities, including without limitation the premises/facilities owned, operated or managed by us or on our behalf (“Our Premises”);
   16. applying, obtaining and maintaining any relevant insurance policies and credit facilities;
   17. communicating with you, dealing with your inquiries or complaints, resolving any issues/disputes and enforcing our rights including without limitation obtaining professional advise;
   18. publishing photographs or video footages of you, which are captured during your participation in any of the Events or our company functions (with or without your name), on our Platform or social media or at our Premises;
   19. preventing or investigating any illegal, or criminal activities, breaches and complying with any legal or regulatory requirements and/or directions and instructions from any law enforcement officer or governmental and regulatory bodies; and/or (s) such other purposes authorised by you or directly related or ancillary to the foregoing;
   20. the E&O Group may also use and process your Personal Data for other purposes such as to send you updates and news on their latest products, services and promotions, including the latest E&O Group projects and property developments and to inform you about events, exhibitions or roadshows which may be of interest to you, by way of post, telephone calls, short message service (SMS) and/or by email; and/or
   21. such other purposes or directly related or ancillary to the foregoing or not mentioned herein.

   (collectively, “ Purposes”)

   
   

4. Please note that it is necessary for us to collect and process your Personal Data. If you do not provide the E&O Group your Personal Data, the E&O Group will not be able to effectively provide services to you or process your Personal Data for any of the Purposes stated above, if at all.




5. The provision of your Personal Data is voluntary when you register your interest in any E&O Group projects or properties or in any products or services offered by companies under the E&O Group. However, if you do not provide your Personal Data, you will not be able to (i) receive any news or updates on new products, services or promotions offered by the E&O Group including news and updates on new projects and property developments by the E&O Group or (ii) receive any news about latest Events, exhibitions or roadshows organised or participated by the E&O Group.




Transfer of Personal Data




6. Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than Malaysia, to companies under the E&O Group which are located outside of Malaysia and/or where the E&O Group’s servers are located outside of Malaysia provided always that the said jurisdiction outside of Malaysia enforces laws which are substantially similar to the Act or the said jurisdiction outside of Malaysia enforces an adequate level of protection for the procession of Personal Data which is at least equivalent to the level of protection afforded by the Act. You understand and consent to the transfer of your Personal Data out of Malaysia as described herein.




Disclosure of Personal Data




7. We may disclose/transfer/disseminate your Personal Data to the following third parties (who may be located within or outside Malaysia) in connection with or for the fulfilment of any of the Purposes:

   
   
   1. our related corporations, subsidiaries, affiliates and/or our group companies as well as their subsidiaries, associated and affiliated companies and jointly controlled entities, (both local and international), whether present or future;
   2. our business partners, contractors and service providers, including without limitation our storage facility and records management service providers, cloud service providers, Information Technology service providers or/and data analysis and marketing agencies;
   3. healthcare service providers or professionals, clinics and/or hospital;
   4. credit reporting agencies and background check agencies;
   5. joint management body (JMB), management corporation (MC), residents association (RA)/owners body/or other legal entities established or to be established in related projects;
   6. our financial and other professional advisors;
   7. banks, insurance companies, credit card verification providers and payment processors;
   8. governmental (including without limitation semi and quasi-governmental) departments and/or agencies, regulatory and/or statutory bodies and law enforcement officer;
   9. such third party as requested for or authorised by you or as required under laws;
   10. your nominee, immediate family members and/or contact person (in case of emergency) as may be notified to us from time to time;
   11. safety and security personnel;
   12. our actual or potential assignee, assignor, transferee, transferor, acquirer or acquiree in respect of our rights, interests and properties;
   13. third parties due to any actual or potential corporate restructuring or exercise (including without limitation merger, acquisition and/or the restructuring of our business, assets and/or liabilities); and/or
   14. other third parties for any of the Purposes.



Third party Personal Data




8. We may require your assistance in the event the Personal Data relating to other persons is required to process your Personal Data for the Purposes and you hereby agree to use your best endeavors to assist us when required.




9. In the event that Personal Data of any third party is supplied by you to us, you shall ensure that such third party has read this Notice and consented to us collecting his/her Personal Data for any of the Purposes prior to the supply of his/her Personal Data to us.




10. Where another person is providing/submitting any of your Personal Data to us, you agree that you have authorised the disclosure of your Personal Data to us and consented to the processing of your Personal Data by us in accordance with this Notice.




Access to & Correction of and Requests and Inquiries




11. Subject to any exceptions under applicable laws, you may at any time after the submission of your Personal Data to us, for access to your Personal Data by submitting such request to our Personal Data Protection Officer at the address stated below in the event:

    
    
    1. you require access to and/or wish to make corrections to your Personal Data subject to compliance of such request for access or correction not being refused under the provisions of the Act and/or existing laws;
    2. you wish to enquire about your Personal Data; and
    3. you are no longer agreeable to us retaining, holding or storing your Personal Data. However, please note that this may result in us not being able to properly perform or discharge our obligations to you.

    Personal Data Protection Officer

    Legal Risk & Compliance Unit

    C-34-01, Menara Vista Petaling

    No. 137, Jalan Puchong

    58200 Kuala Lumpur

    Malaysia

    
    

    Email address: eoproperties@easternandoriental.com

    Telephone : +603 8682 8220(Corporate)

    Facsimile : +603 8682 8226(Corporate)

    
    

12. In respect of your right to access and/or correct your Personal Data, the E&O Group has the right to refuse your requests to access and/or make any correction to your Personal Data for the reasons permitted under law, such as where the expense of providing access to you is disproportionate to the risks to your or another person’s privacy.




13. You may limit the processing of your Personal Data or request us to cease or not begin processing your Personal Data for purposes of direct marketing. You have the right to withdraw your consent previously given to us (in full or in part) by providing us with a notice in writing subject to any applicable legal restrictions and a reasonable duration of time for the withdrawal of consent to be effected. If you limit the processing or withdraw your consent to any or all use of your Personal Data, it may result in: (i) us being unable to continue to administer any arrangement or contractual relationship in place between you and us; (ii) us being unable to (continue to) perform any of our contractual obligations to you (if any); (iii) us being unable to process your Personal Data for any of the Purposes; and/or (iv) the termination of any arrangements or agreements/contracts between you and us, without any liability on our part.




Links to Third-Party Websites




14. The Website may contain links to third parties' websites. Please note that the E&O Group is not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information directly to such sites, the privacy policy and terms of service on those sites are applicable and the E&O Group is not responsible for the information processing practices or privacy policies of such sites.




Personal Information from Minors




15. The E&O Group does not knowingly collect Personal Data from individuals under 18 years of age. As a parent or legal guardian, please do not allow the minor under your care to submit Personal Data to the E&O Group. In the event that such Personal Data is provided to the E&O Group, you hereby consent to the processing of the minor’s Personal Data and personally accept and agree to be bound by this Notice and take responsibility for his or her actions.




Security Measures




16. E&O maintains appropriate technical and organizational security measures to protect the security of your Personal Data against the loss, misuse, unauthorized access, disclosure or alteration.




Personal Data Retention Period




17. We shall retain your Personal Data for as long as necessary to fulfil any of the Purposes as set out in this Notice and thereafter for as long as we are required to do so under the relevant statutory limitation periods, applicable laws and regulations, as well as our internal policies. We will take all reasonable steps to ensure that your Personal Data is destroyed or permanently deleted once it is no longer required.




Consent




18. 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 hereinabove, on the basis that you have consented to our processing of your Personal Data in accordance with this Notice.




Accuracy of your Personal Data




19. You are responsible for ensuring that the Personal Data you have furnished or provided to us is accurate, complete, not misleading and kept up to date.




Conflict




20. This Notice is issued in both English and Bahasa Malaysia pursuant to the requirements prescribed under the Act. In the event of any conflict between the English version and the Bahasa Malaysia version of this Notice, the English version shall prevail over the Bahasa Malaysia version.




Revisions to this Personal Data Protection Notice




21. E&O reserves the right to change this Notice from time to time. Please check the Notice frequently and particularly before you submit additional Personal Data. All updated Notice will be posted on the E&O Group website (“ Website”) at the following link: http://www.easternandoriental.com, https://www.stp2.my and https://www.striatsquay.com and/or Platforms. Your continued use of our services and the voluntary provision of your Personal Data after such changes have been posted will constitute your acceptance of, and consent to, the updated Notice.