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PERSONAL DATA PROTECTION NOTICE
e-Lock Corporation Sdn. Bhd (“we” or “us”) respects and is committed to the protection of your personal information and your privacy. This Personal Data Protection Notice (“Notice”) sets out how we collect and process of your personal data.
A. Collection of personal data
Personal data in this Notice refers to personal information capable of identifying you. In the course of your dealings with us, we may request that you provide us with the relevant and necessary personal data for purposes of entering into a transaction with you, to deliver or provide you with our products and/or services, as well as for advertising, marketing and communication purposes.
The collection and processing of personal data may be obligatory or voluntary. You will be notified on whether the collection and processing is obligatory or voluntary.
We will obtain your consent before we collect and process your personal data.
We may not be able to provide you with the necessary assistance, products and/or services if you choose not to provide us with the relevant and necessary personal data.
If you choose not to provide us with your personal data, some of your experience and use of our products and/or services may be affected.
B. What kind of personal data we collect
The personal data collected by us may include (but is not limited to) the following:
Name, contact details, date of birth, identification supporting documents (including NRIC or passport number), gender, nationality and race, preferred language, address, telephone and/or mobile phone number(s), fax number and email address;
Banking information including, but not limited to, information in your credit card and your banking account;
Details of your account with us including but not limited to your user ID and password;
Information about your use of our products and/or services, including, but not limited to, the history of use, and/or previous enquiries for our products and/or services;
Your reviews and opinions on our products and services; and
Your personal interests and preferences to help us tailor offerings on our products and/or services which would suit you best;
Your marketing preferences or information you provide in the course of participating in surveys, competitions, contests, lucky draws or promotional offers; and/or
CCTV images or camera visual recordings collected through the use of closed circuit television and any other security systems.
C. When and how we collect your personal data
We may collect personal data directly from you when you:
Communicate with us;
Submit your information when registering the warranty;
Where you request and/or register your interest, or subscribe for information on our products and/or services or to our publications (for example newsletters);
When you use, purchase and/or subscribe to our products and/or services;
Participate in any of our surveys, competitions, contests, lucky draws or promotional offers;
Respond to any marketing materials we send out;
Commence a business relationship with us (applicable to channel partner or third party vendors);
Visit our offices; and/or
Provide feedback to us (for e.g. via our websites or in hard copy).
We may also collect your personal data from relevant third parties including our affiliates, authorised resellers, and business partners.
C. Purpose of collecting personal data
We may use your personal data for the following purposes, including (but is not limited to):
For providing you with our products and/or services;
For responding to your requests for information;
For entering into the necessary agreement and/or contract in relation to the sale and supply of our products and/or services;
For conducting marketing, surveys and customer profiling activities in connection with our product and/or services;
For internal record keeping;
For establishing and managing any business relationship we have with you;
For responding to your enquiries and complaints and to resolve disputes;
For sending important notices, such as communications about purchases, subscriptions and changes to our terms, conditions, and policies; and
For compliance with all applicable laws and regulations.
E. Disclosure and sharing of your personal data
We may disclose, transfer and/or share your personal data (whether within Malaysia or outside Malaysia) to the following third parties, including but not limited to;
our affiliated companies, business partners including but not limited to, our authorized resellers; and
third party data processors who provide legal, accounting, administrative, storage, telecommunications, payment and/or other services to facilitate and to perform certain business functions.
We may also disclose your personal data if required to do so by law or if the disclosure is necessary (i) for compliance with applicable laws and regulations (ii) comply with a legal or regulatory obligation, (ii) to protect or defend our rights or property.
Except as described herein, we do not permit the sale or transfer of personally identifiable information to third parties.
F. Advertising and Marketing
We may use your personal data for marketing purposes including, but not limited to, contacting you to notify you of our upcoming products and/or services, upcoming events, promotions, and any other relevant marketing and advertising activities by us which may be relevant to you.
If you do not wish to receive any marketing materials and/or information, kindly submit a request to us via the contact details provided under Section J: Access, Correction and Deletion.
G. Personal data Integrity
We will take reasonable steps to make sure that the personal data collected, used or disclosed is accurate, complete, not misleading and up-to-date. If there are any changes to your personal data or if you believe that the personal data we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your personal data.
H. Personal data security
We will take reasonable steps to protect the personal data we hold from loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction.
Reasonable steps will be taken to ensure that the data processors appointed by us will comply with the applicable data privacy laws. The recipients of such personal data are prohibited from using the personal data for any purpose other than for the purpose(s) specified by us.
Whilst we take reasonable steps to protect your personal data, we are unable to guarantee that the personal data will not be subject to interference, misuse or hacking and we shall not be responsible for any loss, misuse or alteration arising as a result of such incidents.
I. Retention of your personal data
Your personal data collected and processed in accordance with this Notice may be retained for a reasonable period, in accordance with the applicable data protection laws.
J. Access, Correction and Deletion
Subject to any exceptions under the PDPA or any applicable laws and regulations, you are entitled to have access and/or make changes to your personal data in our possession.
You may also request for the deletion of your personal data and restrict certain processing of your personal data. When we receive such request, we will cease processing or delete your data unless the processing, including the retention of such data, is necessary for legitimate grounds including for compliance with applicable laws, for legal purposes and for other legitimate business purposes.
Any request for access, alteration and deletion shall be in writing to the contact person as provided below. A request for access to your personal data may be subjected to a payment of a fee, in accordance with the applicable laws and regulations. When communicating your request, please be sure to include your full name, address and telephone number and any other relevant and necessary details for us to ascertain your identity. We may refuse your request if there is insufficient information provided to ascertain your identity.
All access, correction and deletion request shall be communicated to our data protection officer at:
• Name: CFO Office
• Email: email@example.com
• Facsimile: +603-2166 2982
• Address: Business Suite, 19A-26-3, Level 26, UOA Centre, 19 Jalan Pinang, 50450 Kuala Lumpur, Malaysia.
K. Right to Complain
You have the right to lodge a complaint to the relevant supervisory authority and data protection commissions and/or offices if you feel that we have not addressed your concern in a satisfactory manner.
L. Changes to this Notice
Please note that we may amend this Notice from time to time without prior notice. Any changes to the Notice will be reflected on our website together with the effective dates. Any changes to the Notice will be effective upon posting of the revised Notice on our website.
This Notice is governed by and shall be construed in accordance with the laws of Malaysia.
This Notice is prepared in the English and Malay languages. In the event of inconsistency between the English Notice and the Malay Notice, the English Notice shall prevail.