GROUP PRIVACY NOTICE
The Lion Property values your privacy and strives to protect your personal data in compliance with the Personal Data Protection Act 2010 (“PDPA”).
For the purposes of this Privacy Notice, please note that :
- Lion Property including its subsidiaries, associated companies and joint-ventures are covered by this policy.
- Data Subject, Data User and Data Processor have the same definitions as provided by PDPA.
1.0 What Kind of Personal Data We Collect
1.1 We may need to and/or may be required to process your personal data which includes any data that relates directly or indirectly to you (depending on the nature of your interaction with us).
1.2 Examples of personal data :
a) Name, NRIC, passport or other identification number, age and job title;
b) Contact details such as mailing address, email address and telephone number;
c) Financial information such as bank account details and loan commitment;
d) Information relevant to customers survey such as preferences and interests;
e) Transactional data such as purchasing history, bank account and credit cards details;
f) Closed Circuit Television (CCTV) or security surveillance recordings, photographs and video recordings;
g) Information relating to any other individuals such as spouse, family members and former superior.
2.0 How We Collect Your Personal Data
2.1 In general, your Personal Data is collected in the following ways :
a) when you submit any form including but not limited to application, registration or declaration forms;
b) when you register your personal details in the logbook or computer terminal at any of our receptionist counters or security posts upon entry into our premises or when attending events organized by us outside our premises;
c) when you use our products or services;
d) when you communicate verbally or in writing with our employees including sales representatives, customer service officers and our authorized agents. Example, telephone calls, letters, emails, face-to-face meetings and social media platforms;
e) when you take part in our customer surveys, competitions and promotions;
f) when you interact with us via social media, our websites or use services on our websites;
g) when you request that we contact you or request that you be included in an email or other mailing list;
h) when you register for future employment opportunities or you submit an employment application for any of the advertised vacancies in Lion Property, directly to the company advertising the vacancies or via our authorized agents;
i) when your images are captured by our CCTV cameras during your presence within our premises or via photographs or videos taken by us or our representatives at events organized by the Group;
j) when we receive your Personal Data which we seek in connection with your relationship with us, including for job applications or our products and services, for example, from business partners, public agencies, former employers, referral intermediaries, credit reporting agencies and relevant authorities;
k) when you have given your consent to any sources of personal data other than those stated above.
3.1 By submitting your personal data to us, you consent us in processing the data in accordance with this Privacy Notice.
3.2 All personal data provided by you is taken as accurate, complete and up to date.
3.3 To the extent that personal data relating to other individuals is provided by you to us, you represent and warrant that you are authorised to provide such data and have obtained their consent to the processing of their Personal Data in accordance with this Privacy Notice.
4.0 How We Use the Data
4.1 In general, we use your personal Data for one or more of the following purposes :
a) to respond to your queries, feedback, complaints and requests;
b) to verify your identity and background;
c) to assess and process your application/request for our products and services;
d) to verify your financial standing/creditworthiness;
e) to enable us to consider whether to provide or continue to provide to you any of our products and services;
f) to manage and maintain your customer loyalty program membership with us;
g) to provide you with information on our or third party products, services and offers;
h) to improve and/or develop our products and services ;
i) to administer competitions, campaigns and promotions;
j) to update and improve the accuracy and completeness of our records;
k) to protect and enforce our contractual and legal rights and obligations under your agreements with us in connection with any claims, actions or proceedings including recovery of debts owing to us;
l) to facilitate conduct of investigations into disputes, fraud or anti-money laundering;
m) to smoothen facilities management (including but not limited to maintaining the security of our premises and recording entries and exists);
n) to prevent, detect, investigate and prosecute crimes;
o) to manage the safety and security of our premises, assets, employees and public members (including but not limited to CCTV surveillance and conducting security clearances);
p) to meet disclosure requirements of any laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Lion Property.
4.2 If you are an employee, owner or director of a vendor or supplier (including agent, contractor and external service provider) :
a) assessing your suitability as a vendor or supplier for Lion Property;
b) managing quotations, proposals and project tenders;
c) processing orders;
d) processing and payment of invoices and bills;
e) managing business operations.
4.3 If you submit an application to us as a candidate for employment :
a) to process your application such as checks on background, academic qualifications and employment history; and
b) to facilitate conduct of interview sessions such as hardcopy candidate profile for reference by interviewers.
4.4 If you sit on the Board of Directors of Lion Property of companies :
a) to facilitate your appointment as a board member;
b) to maintain statutory registers;
c) to manage the publication of directors’ profiles in circulars, annual reports or press releases to media, analyst or authorities; and
d) to facilitate the execution of duties and administrative matters.
5.0 Disclosure of Personal Data
5.1 In respect of the purposes above, your personal data may be disclosed to and processed by :
a) companies of the Lion Property (including our appointed agencies);
b) our authorised dealers;
c) data centers and servers for storage purposes;
d) our approved service providers;
e) our professional advisors or consultants including external auditors, legal advisors and financial advisors;
f) Governmental agencies including those of other countries that your personal data is transferred to;
g) Individuals, entities or governmental agencies to whom you have consented the disclosure of your personal data to.
5.2 If you acquire products and/or services from Parkson Credit, your personal data may additionally be disclosed to:
a) Credit information agencies such as RAMCI & CTOS for credit check;
b) JPJ (e-daftar) for JPJ ownership claim registration.
6.0 Transferring of Your Personal Data Overseas
6.1 Please note that it may be necessary for us to transfer your personal data to companies of Lion Group or service providers or governmental agencies outside Malaysia in the course of fulfilling our obligations to you and also in providing you with integrated services or as required by the law.
7.0 Link to Other Websites
7.1 This website may provide you with links to websites of Lion Property of companies and third parties’ websites for your information and convenience. We encourage you to peruse the privacy notice governing each of these websites as we do not have control over the personal data you may provide when visiting such websites.
8.2 The information collected is used to help us to improve and provide a more personalized service level to our users.
8.3 You can decide to accept or not to accept a cookie by adjusting the setting of your browser.
9.0 Use of Social Media
9.1 Social media is not under the jurisdiction of Lion Property and its use is governed by the usage policy of each medium, if any.
10.0 Security of Personal Data
10.1 We value information as our asset and therefore ensuring the security of your personal data is our priority. We regularly review and implement operational security measures when processing your personal data.
10.2 Our employees are committed to handle the personal data securely and with utmost respect, failing which they may be subject to disciplinary action.
11.0 Retention of Your Personal Data
11.1 We will retain your personal data for:
a) the duration of your relationship with us or as needed to enable us to provide you our services/products;
b) a period as necessary to comply with our legal obligations, resolve disputes and enforce our agreements;
c) a period as required by our relevant internal policies or applicable law.
12.0 What if Personal Data Provided by You Is Incomplete
12.1 Your failure or refusal to provide us with personal data may result in us not being able to :
a)process your application/request;
b)provide you with our products or services.
13.0 Your Rights To Access, Correct Your Personal Data and Withdraw Your Consent
13.1 Any request for access to or to correct your data at any time after submission of your data to us and upon obtaining and completing the access or correction form, you may submit the request either by hand delivery or post to :
a) Our Address (for Corporate Office/Group Functions) :
Marketing & Sales Department
Level 2, Lion Office Tower
1 Jalan Nagasari
50200 Kuala Lumpur
b) the respective management office address of the operating company.
In case you wish to withdraw consent given earlier with regards to processing of your personal data, either partially or in full, you may complete and submit the relevant form to the address as mentioned above.
13.2 You may obtain our Data Access Request Form, Data Correction/Update Request Form or Data Withdrawal of Consent Request Form respectively from our operations offices or download from our website.
13.3 We may have to withhold access to your personal data or not able accede to your request to correct data or limit the processing in certain circumstances such as failure to confirm your identity or similar requests have been received repetitively.
13.4 In such cases, we may require further evidence for verification to avoid inaccuracy or fraud.
14.0 Revision to Privacy Notice
14.1 We may revise this notice at any time without prior notice and we may notify you of such revision via our website or other means of communication deemed suitable by us.
15.1 This Privacy Notice is intended to describe the broadest range of our information processing activities, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of Personal Data we can collect or the manner in which we process that data. In those instances, we adjust our internal policies and practices to reflect the requirements of local law and local laws will prevail over terms in this Privacy Statement.