PERSONAL DATA PROTECTION NOTICE
This Personal Data Protection Notice (“Notice”) describes how [insert company name] [and its respective subsidiaries, associate companies and jointly controlled entities] (“the Company”) uses your Personal Data.
In the event of any conflict between the English and other language versions, the English version shall prevail. The Company shall have the right to modify, update or amend the terms of this Notice at any time by [notifying you and/or placing the updated Notice on the the Company website (“Website”) at the following link: [insert the website URL of the Company]]. By continuing to communicate with the Company or use The Company’s services following the modifications, updates or amendments to this Notice, such actions shall signify your acceptance of such modifications, updates or amendments.
Collection of Personal Data
1. “Personal Data” means information about you, from which you are identifiable, including but not limited to your [name, identification card number, telephone numbers, address, email address, date of birth, age, gender, photograph, race, ethnic origin, nationality, passport number, social media contact, marital status, information about your company and your designation in your company, credit/debit card details, your flight and travel details, frequent flyer number or other loyalty program membership number], or any information about you which you have provided to the Company in any correspondence or when you engage the Company for services and/or any information about you that has been or may be directly or indirectly collected, stored, used and processed by the Company from time to time. [The Company may also collect sensitive personal data such as data relating to your health, religion or other similar beliefs, and you hereby expressly consent to the use of such sensitive personal data, and sensitive personal data will form part of the definition of “Personal Data”.]
3. Provision of your Personal Data is mandatory for the Purposes (as outlined below). If you do not provide the Company with your Personal Data, the Company will not be able to provide the services you have requested, such as organising your travel arrangements. Purposes of Processing
4. The Company may use and process your Personal Data to provide you the services you have requested, to perform the contract you have entered into with the Company and for the purposes relating to the business and activities of the Company which shall include, without limitation the following (“the Purposes”):- • to process your travel arrangements or for matters related to your travel arrangements, including for flight and accommodation bookings, making ground arrangements, purchasing insurance, application of visa, etc; • to facilitate your participation in any contests or promotional/marketing events which you have signed up for; • to facilitate your participation in loyalty programs; • for purposes of billing and payments relating to the services you have requested; • to contact and correspond with you regarding various matters pertaining to the services you have requested, such as the status of your travel arrangements, last minute cancellations, etc; • to respond to questions, comments and feedback from you; • for internal administrative purposes, such as auditing, data analysis, and to improve our services; • for purposes of detection, prevention and prosecution of crime; • to enforce or defend the Company’s legal rights and/or to obtain legal advice; • for the Company to comply with its obligations under law whether within or outside Malaysia; and you agree and consent to the Company using and processing your Personal Data in the manner as identified in this Notice. Marketing and promotional purposes
5. Unless you have indicated otherwise, the Company may also use and process your Personal Data for marketing and advertising purposes such as to:- • [send you communications regarding the Company’s latest promotions and services; • Contact and inform you about events, fairs or exhibitions which may be of interest to you; • conduct market surveys] by way of [post, telephone calls, short messaging service (SMS) and/or by email] (“Marketing Purposes”) If you do not consent to the Company processing your Personal Data for the Marketing Purposes, please notify the Company using the contact details stated below. Transfer of Personal Data
6. Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than Malaysia, such as in the following circumstances: § [Where travel arrangements have been made in a country outside Malaysia; § Where personal information is required to be disclosed to various law enforcement agencies and governments for security, customs and immigration purposes; § Where the Company’s service providers, contractors, agents or partners are located outside of Malaysia; § Where the Company’s servers or back-up servers are located outside of Malaysia.] and you understand and consent to the transfer of your Personal Data out of Malaysia as described herein. Disclosure to Third Parties
7. Your personal data may be transferred, accessed or disclosed to third parties for the Purposes or for Marketing Purposes. Further, the Company may engage other companies, service providers or individuals to perform functions on the Company’s behalf, and consequently may provide access or disclose to your Personal Data to such service providers or third parties. The third parties referred to in this section include (without limitation):- (a) [Service providers such as the Company’s information technology (IT) service providers; (b) Contractors in order for the Company to complete a transaction on your behalf; (c) Marketing and advertising agencies; (d) Our professional advisors, including our legal advisors, auditors, accountants and consultants; (e) The Company’s subsidiaries, associate companies and jointly controlled entities; and (f) Regulatory and governmental authorities in order to comply with statutory and government requirements.] Your Personal Data may also be shared in connection with a corporate transaction, such as a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up. Access & Correction Requests and Inquiries
8. Subject to any exceptions under applicable laws, you may request for access to and/or request correction of your Personal Data, request to limit the processing of your Personal Data for Marketing Purposes and/or make any inquiries regarding your Personal Data by contacting:- Please provide designation of the contact person] Email address: Telephone : Facsimile :
9. Please note that if you withdraw your consent for the Company to process your Personal Data for the Purposes, the Company may consequently not be able to transact or contract with you and may be unable to provide you the products or services which you have requested.
10. In respect of your right to access and/or correct your Personal Data, the Company 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. The Company reserves the right to impose a fee for access of your Personal Data in the amounts as permitted under law. [Links to Third-Party Websites
12. As a parent or legal guardian, please do not allow the minor (individuals under 18 years of age) under your care to submit Personal Data to the Company. In the event that such Personal Data is provided to the Company, you hereby consent to the processing of the minor’s Personal Data as his/her parent or legal guardian and personally accept and agree to be bound by this Notice and take responsibility for his or her actions.
13. In some circumstances you may have provided personal data relating to other individuals (such as your spouse, family members, colleagues or friends) and in such circumstances you represent and warrant that you are authorised to provide their personal data to the Company and you have obtained their consent for their personal data be processed and used in the manner as set forth in this Notice and they have been alerted to the contents of this Notice. Acknowledgement and Consent
14. By communicating with the Company, engaging the Company or using the Company’s services, you acknowledge that you have read and understood this Notice and agree and consent to the use, processing and transfer of your Personal Data by the Company as described in this Notice.
I have read this Notice and by signing and returning a copy of this Notice, I expressly agree and consent to the use, processing and transfer of my Personal Data (including sensitive personal data) by the Company as described in this Notice.
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