Privacy Statement
Last revised: 23 November 2023
Introduction
At PFP Legacy Sdn. Bhd., we recognise that your privacy is important and we are committed to maintaining the confidentiality of the personal information that you give us through this website.
This Privacy Policy explains how we protect personal data gathered via this Website. To process, administer and/or manage your relationship with us, we will necessarily need to collect, use, disclose and/or process your personal data and/or personal data provided by you. We protect your personal data by complying with all the relevant data protection laws and regulations of Malaysia and ensure compliance by our staff with strict standards of security and confidentiality.
By using this Website you are agreeing to the use of your information as described in this Privacy Policy. If you object to our practises and policies, please do not use this website.
This Privacy Policy may be supplemented or amended from time to time and will update this webpage accordingly.
Information collection
As a visitor, you do not have to submit any personal information in order to use the Website. This Website only collects personal information that is specifically and voluntarily provided by visitors for the purpose the personal information is collected. Such information may consist of, but is not limited to, your name, current job title, company address, email address and telephone and fax numbers. Do not provide personal information to us, unless you consent to our use of that information for its legitimate business purpose.
We may also store and maintain any content that you provide, including but not limited to postings on any blogs, forums, wikis and other social media applications and services that we may provide.
Personal Data Collection
The term “personal data” means any information in our possession or control that relates directly or indirectly to an individual to the extent that the individual can be identified or are identifiable from that and other information in our possession such as name, address, and personal contact details etc. The types of personal data collected depend on the purpose of collection. We may “process” your personal data by way of collecting, recording, holding, storing, using and/or disclosing it.
Your personal data may be collected from you during your course of dealings with us in any way or manner including pursuant to any transactions and/or communications made from/with us. We may also collect your personal data from a variety of sources, including without limitation, at any meetings, events, seminars, conferences, talks, road shows, customer satisfaction surveys organised and/or sponsored by us, as well as from publicly available sources.
In addition, we may also receive, store and process your personal data which are provided or made available by any third parties, credit reference bodies, regulatory and law enforcement authorities, for reasons including delivery of our services, performance of conditions of agreements and/or to comply with our legal and regulatory obligations. We may also store and maintain any content that you provide, including but not limited to postings on any blogs, forums, wikis and other social media applications and services that we may provide.
Purpose of Personal Data Collected
We may collect, use and process your personal data and/or personal data furnished by you for the following purposes (collectively referred to as the “Purposes”):
- to assess, process and provide services to you;
- to facilitate, process, deal with, administer, manage and/or maintain your relationship with us;
- to consider and/or process your application/transaction with us;
- to respond to your enquiries or complaints or resolve any issues and disputes which may arise in connection with any dealings with us;
- to administer and process any payments related to services requested by you;
- to facilitate your participation in, and our administration of, any events including meetings, seminars, conferences, talks, road shows, contests or campaigns;
- to facilitate your participation or posting of any contents in any forums, bulletin boards, discussions, blogs, wikis and other social media applications and services that we may provide;
- to carry out due diligence or other monitoring or screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that may have been put in place by us;
- to administer and give effect to your commercial transactions with us;
- to process any payments related to your commercial transactions with us;
- to provide you with information and/or updates on services offered by us and/or events, conferences, talks and seminars organised by us and selected third parties which may be of interest to you from time to time by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
- to provide you with reference materials through any appropriate communication channels including to allow you to download publications or documents from this Website;
- to send you seasonal greetings messages, corporate gifts (e.g. gifts branded with our logo or business message) and newsletters from time to time;
- to send you invitation to join our events, promotions, mailing lists as well as conferences, talks and seminars;
- to monitor, review and improve our events and services;
- to process and analyse your personal data either individually or collectively with other individuals;
- to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our services;
- to share any of your personal data with the auditor for our internal audit and reporting purposes;
- to share any of your personal data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
- to share any of your personal data with a third party necessary for the preparation of legal documents or contract to be entered by you;
- to maintain and improve customer relationship;
- to maintain and update internal record keeping, files and contact lists;
- to detect, investigate and prevent any fraudulent, prohibited or illegal activity or omission or misconduct;
- to enable us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
- to transfer or assign our rights, interests and obligations under any agreements entered into with us;
- to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
- for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
- for internal administrative purposes; and/or
- for our storage, hosting back-up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Malaysia.
and you agree and consent to us using and processing your personal data for the Purposes in the manner as identified in this Privacy Policy. If you do not consent to us processing your personal data for one or more of the Purposes, please notify us as soon as possible. We will seek your separate consent for any other purposes which do not fall within the categories stated above.
Consequences of Not Consenting to this Privacy Policy
The collection of your personal data by us may be mandatory or voluntary in nature depending on the Purposes for which your personal data is collected. Where it is mandatory for you to provide us with your personal data, and you fail or choose not to provide us with such data, or do not consent to the above or this Privacy Policy, we will not be able to provide our services or otherwise deal with you, if at all.
Log information, Cookies and Web Beacons
This Website collects standard internet log information including your IP address, browser type and language, access times and referring website addresses. To ensure that this Website is well managed and to facilitate improved navigation, we or our service provider(s) may also use cookies (small text files stored in a user’s browser) or Web beacons (electronic images that allow this Website to count visitors who have accessed a particular page and to access certain cookies) to collect aggregate data. Additional information on how we use cookies and other tracking technologies and how you can control these can be found in our PFP Legacy Cookie
Disclosure of Personal Data to Third Parties
We will not sell, rent, transfer or disclose any of your personal data to any third party without your consent. However, we may disclose your personal data to the following third parties, for one or more of the above Purposes:
- your immediate family members and/or emergency contact person as may be notified to us from time to time;
- successors in title to us;
- any person under a duty of confidentiality to which has undertaken to keep your personal data confidential which we have engaged to discharge our obligations to you;
- any party in relation to legal proceedings or prospective legal proceedings;
- our auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our business on a strictly confidential basis, appointed by us to provide services to us;
- any party nominated or appointed by us either solely or jointly with other service providers, for purpose of establishing and maintaining a common database where we have a legitimate common interest;
- data centres and/or servers located within or outside Malaysia for data storage purposes;
- storage facility and records management service providers;
- payment channels including but not limited to banks and financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to us in connection with our services;
- government agencies, law enforcement agencies, courts, tribunals, regulatory/professional bodies, industry regulators, ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities;
- our business partners, third party service providers, vendors, contractors or agents, on a need-to-know basis, that provide related services in connection with our business, or discharge or perform one or more of the above Purposes and other purposes required to operate and maintain our business;
- financial institutions and merchants in connection with your commercial transactions with us;
- any third party (and its advisers/representatives) in connection with any proposed or actual reorganisation, merger, sale, consolidation, acquisition, joint venture, assignment, transfer, funding exercise or asset sale relating to any portion of PFP Legacy Sdn. Bhd.; and/or
- any other person reasonably requiring the same in order for us to operate and maintain our business or carry out the activities set out in the Purposes or as instructed by you.
We recognise that your personal data is valuable and we take all reasonable measures to protect your personal data while it is in our care.
Retention
The personal data you submit to us will only be retained for as long as is required for the purposes for which it was collected or as required by law. Your personal data is then destroyed or anonymised from our records and system in accordance with our retention policy in the event your personal data is no longer required for the said purposes unless its further retention is required to satisfy a longer retention period to meet our operational, legal, regulatory, tax or accounting requirements.
Accuracy of Personal Data
When personal data is collected by us, we assume responsibility for keeping an accurate and up-to-date record of your personal data once you have submitted and verified the data. We do not assume responsibility for verifying the ongoing accuracy of the personal data. You will promptly update us in the event of any change to your personal data. If we are informed by you that any of your personal data which we have collected is no longer accurate, we will only make appropriate corrections based on the updated information provided by you. We are committed to providing reasonable and practical access to you for the opportunity to identify and correct any inaccuracies. When requested and practical, we will delete identifying information from current operational systems.
Your Rights
In addition to the above, to the extent that the applicable law allows, you have the right to request for access to, request for a copy of, request to update or correct, your personal data held by us. We may charge a small fee to cover the administration costs involved in processing your request to access your personal data. Notwithstanding the foregoing, we reserve our rights to rely on any statutory exemptions and/or exceptions to collect, use and disclose your personal data. You have the right at any time to request us to limit the processing and use of your personal data (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes).
You also have the right, by notice in writing, to inform us on your withdrawal (in full or in part) of your consent given previously to us subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be effected. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us or the contract that you have with us will have to be terminated.
Information Security
We have, where practicable, put in place reasonable commercial standards of technology and operational security to protect all information provided by you from unauthorised access, disclosure, alteration, or destruction.
he Internet is not a secure medium. However, we have put in place various security procedures with regard to this Website and your electronic communications with us. All our employees and data processors, who have access to, and are associated with the processing of your personal data, are obliged to respect the confidentiality of your personal data.
Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may be routed through a number of countries before being delivered – this is the nature of the World Wide Web/Internet.
We cannot and do not accept responsibility for any unauthorised access or interception or loss of personal data that is beyond our reasonable control.
Cross Border Transfer
We have, where practicable, put in place reasonable commercial standards of technology and operational security to protect all information provided by you from unauthorised access, disclosure, alteration, or destruction.
Personal data collected by us may be disclosed or transferred to entities located outside Malaysia or where you access this Website from countries outside Malaysia. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in Malaysia under the laws of Malaysia. In addition, our information technology storage facilities and servers may be located in other jurisdictions outside of Malaysia and your personal data may be stored on servers located outside Malaysia. By submitting data to us, you are providing explicit consent for cross border transmission of data collected for the fulfilment of your requests. We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of Malaysia shall not use your personal data other than for that part of the Purposes and to adequately protect the confidentiality and privacy of your personal data.of your personal data.
Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may be routed through a number of countries before being delivered – this is the nature of the World Wide Web/Internet.
We cannot and do not accept responsibility for any unauthorised access or interception or loss of personal data that is beyond our reasonable control.
Changes to this Privacy Policy
We may modify or amend this Privacy Policy from time to time at our discretion with reasonable prior notice to you. We will notify you of any amendments via announcements on this Website or other appropriate means. Please check this Website from time to time to see if there are amendments to this Privacy Policy. When we make changes to this Privacy Policy, we will also amend the revision date at the top of this page. We encourage you to periodically review this Privacy Policy to be informed about how we are protecting your personal data.
Any amendments to this Privacy Policy will be effective upon notice to you. By continuing to communicate with us, use our services, and/or access to this Website after being notified of any amendments to this Privacy Policy, you will be treated as having agreed to and accepted those amendments.
Questions or Complaints
If you have any questions or concerns regarding your privacy, or have any further queries, or would like to make a complaint or data access or correction request in respect of your personal data, please do not hesitate to contact us.