Last revised on 17 July 2017
This data protection policy applies to Arbinger Malaysia which is established in Malaysia. This policy explains how we collect and manage personal data of individuals and comply with the requirements of the Personal Data Protection Act 2010 of Malaysia (“PDPA”).
Data Protection Policy
We will collect, use or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes has been notified. We may also collect, use or disclose personal data if it is required or authorised under applicable laws.
Collection of Personal Data
We collect personal data from clients, customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, face to face meetings, marketing events, email messages, telephone conversations, through our websites or provided by third parties. If you contact us, we may keep a record of that contact.
We collect these personal data when it is necessary for business purposes or to meet the purposes for which you have submitted the information.
We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy. If you are acting as an intermediary or otherwise on behalf of a third party or supply us with information regarding a third party (such as a friend, a colleague, an employee etc), you undertake that you are an authorised representative or agent of such third party and that you have obtained all necessary consents from such third party to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.
Use of Personal Data
We use personal data for the following purposes:
- to provide our services
- to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection)
- to maintain contact with clients and other contacts
- to keep clients and other contacts informed of the services we offer, industry developments, service offerings, seminars and other events we are holding, that may be of interest to them
- for general management and reporting purposes, such as invoicing and account management
- for recruitment purposes
- for purposes related to the employment of our personnel and providing internal services to our personnel
- all other purposes related to our business.
Disclosure of Personal Data to Third Parties
We do not disclose personal data to third parties except when required by law, when we have your consent or deemed consent or in cases where we have engaged the third party such as Arbinger’s partners, data intermediaries or subcontractors specifically to assist with our firm’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.
Access to and Correction of Personal Data
Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA. We may charge for a request for access in accordance with the requirements of the PDPA.
Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.
Please contact our Data Protection Officer for issues regarding access and correction of personal data. Please allow 30 days for your request to be processed.
Withdrawal of Consent
You may choose to unsubscribe from mailing lists. You may also elect not to receive further marketing information from us by contacting our Data Protection Officer. Please allow 30 days for your request to be processed. Please take note that should you choose to withdraw your consent, we may no longer be in a position to continue to provide updates.
Accuracy of Personal Data
We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.
Security and Protection of Personal Data
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Transfer of Personal Data outside of Malaysia
We will ensure that any transfers of personal data to a territory outside of Malaysia will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
We may disclose personal data to our global Arbinger offices, where it is necessary (i) to meet the purpose for which you have submitted the information; or (ii) to enable you to be provided with information at a later date which may be of relevance and interest to you based on the nature and purpose of your voluntary requests. We may also transfer all data in our possession to a successor-in-interest to our business or assets.
Privacy on Our Web Sites
This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.
We reserve the right to modify or amend this Policy at any time. The effective date will be displayed at the beginning of this Policy. To keep you informed, we will notify changes to this Policy by prominently identifying the alteration for a period of not less than two weeks on our home page at https://www.arbingersea.com