1. The Personal Data Protection Act 2010 (“PDPA”) come into effect on 15 November 2013 and is meant to regulate the processing of ‘personal data’ and ‘sensitive data’ in commercial transaction.
2. We, Gow Victor & Co. (“GVCO”) values your privacy and recognise the importance of privacy law and strives to protect your personal data in compliance with Malaysian Law.
4. This Privacy Notice shall be displayed at our website and issued to all our existing, immediate and prospective client(s) pursuant to the requirements of the PDPA.
5. In essence, this Privacy Notice explains: -
(a) what kind of personal data we collect and the method/how we collect it;
(b) purpose of collecting your personal data;
(c) how we use your personal data;
(d) the parties that we disclose the personal data to; and
(e) the choices we offer, including how to access and update your personal data.
WHAT KIND OF PERSONAL DATA WE COLLECT AND THE METHOD/HOW WE COLLECT IT
6. In order to enable us to assist with your inquiries and/or provide the Service to you, we may need to process (i.e. collect, hold, record, use and/or disclose) your personal data, which includes any data which relates directly or indirectly to you and/or the Services provided to you. Such personal data includes, but is not limited to your name, job description, address, business, information captured by our GVCO’s cloud-based application/software, the information contained in any of the application form whether you have filled up at our office or at our website and any such other necessary data regarding yourself and your transaction with us (“personal data”).
7. We may obtain such data from you during the course of the Service provided to you and from variety of sources, including but not limited to:
(a) through your relationship with us, for example information provided by you in the application form, when using the Service, when taking part in our customer surveys, competitions and promotions;
(b) through your verbal and written communications with us/and or authorized agents; and
(c) from third parties connected with you, subject to your prior consent.
PURPOSE OF COLLECTING YOUR PERSONAL DATA
8. Your personal data will be process in whatsoever form, inter alia, for the following purposes:-
(a) performance and implementation of any commercial transactions, dealings with you or in connection with any of the Service (online or offline) that GVCO may render to you;
(b) maintenance and upkeep of your client(s)’ database, sales reports, document checklist, account payable and receivable, commission statement and financial data;
(c) your name/picture may be displayed on GVCO’s cloud-based application/software hosted on any third-party cloud platform authorized by GVCO;
(d) to operate our website and information technology software (including the collection of HTTP cookie);
(e) to make disclosure under the requirements of any applicable law, regulation, directive, guidelines, by law or circular government authorities and/or court of competent jurisdiction pertaining to the Service provided to you;
(f) enable us to send you information by e-mail, regular postal, any telecommunication means (including but not limited to telephone calls, text messages and social chat application i.e. wechat, line, qq & whatsapp) about the Service offered by us / our affiliates companies / third parties that we think may interest you but in doing so we maintain control over your personal data and we will not disclose your personal data to such parties without your prior consent; and
(g) for other purpose relevant to the services provided by us or that is incidental to the abovementioned purposes.
DISCLOSURE OF YOUR PERSONAL DATA
9. As part of proving the Service to you, we may disclose your personal data to the following parties:-
(a) our related, affiliated and associate companies and/or organizations, whether situated in or outside Malaysia;
(b) companies and/or organizations that act as our agent/professional advisers (including but not limited to lawyers, accountant and/or other professional advisers) where authorized by you; and
(c) companies and/or organizations to whom we have leased our cloud base platform from;
(d) any person notified by you as authorized to give instructions on your behalf; and
(e) any court, tribunal or authority, whether governmental or otherwise, with jurisdiction over us.
whether in or outside Malaysia for any of the purposes set out above.
10. We will otherwise treat your personal data as private and confidential apart from the parties stated above and we will not disclose your data to any other party except:-
(a) where you have given permission;
(b) where we required or permitted to do so by law;
(c) where required or authorized by any order of court;
(d) where we may transfer rights and obligations under your agreement(s) with us; and/or
(e) where we are required to meet our obligations to any relevant regulatory authority.
SECURITY OF YOUR PERSONAL DATA
11. Information is our assets and therefore we place great importance on ensuring the security of your personal data. We regularly review and implement up-to-date technical and organizational security measures when processing your personal data.
RETENTION OF YOUR PERSONAL DATA
12. We will retain your personal data in compliance with this Privacy Notice and/or the terms and conditions of your agreement(s) with us for the duration of your relationship with us, for such period as may be necessary to protect our interest and/or the interests of GVCO and/or its client(s)/User.
FAILURE TO PROVIDE YOUR PERSONAL DATA
13. The failure to obtain your personal data will lead to the following:
(a) we will not be able to process your application/request;
(b) we will not be able to provide you with the Service needed and requested by you; and
(c) we will not be able to provide you with any notice, services and update in which you have requested.
YOUR RIGHTS TO ACCESS AND CORRECT YOUR PERSONAL DATA
14. Where you wish to have access to your personal data in our possession, or where you are of the opinion that such personal data held by us is inaccurate, incomplete, misleading or where relevant, not up-to-date, you may make a request to us in writing.
15. Should you have any query in relation to this Privacy Notice or how we handle your personal data, please contact us at the following:
In Charge Person:
Mr. Victor Tai Yong Sheng
Write to us at:
LOT 7.16, (UPPER LEVEL), 7TH FLOOR, WISMA CENTRAL, JALAN AMPANG, 50450 KUALA LUMPUR, MALAYSIA
16. We will use reasonable efforts to comply with your request to access or correct your personal data within 21 days of receiving your request in writing and the relevant processing fee (if any).
17. Please note that we may have to withhold access to your personal data in certain situations, for example when we are unable to confirm your identity or where the data requested for is of a confidential commercial nature or in the event we receive repeated requests for the same data. Nevertheless, we will notify you of the reasons for not being able to accede to your request.
18. Please also note that we may exercise our discretion in allowing the corrections requested and/or may require further documentary evidence of the new data to avoid fraud and inaccuracy.
19. You can also assist us to keep your personal data (such as your current mailing address) up to date, as it will enable us to serve you better.
EXERCISING CHOICES OVER THE DISCLOSURE, RETENTION AND USE OF YOUR PERSONAL DATA
20. Subject always to our contractual rights and obligations under relevant laws and regulations, you may exercise your choice in respect of the disclosure, retention and use of your personal data. Should you wish to do so, kindly contact us at the contact details provided above.
REVISION TO PRIVACY NOTICE
21. This Privacy Notice may be revised from time to time. Notice of such revision will be given by such means of communication deemed suitable by us.