Data Privacy Policy Notice

With regard to the processing of your Personal Data, this Personal Data Protection Notice (“Notice”) sets out the policies of Jelawang Capital Sdn. Bhd. (“JC”), its subsidiary and affiliate entities (collectively referred to as the “Company”) in relation to the collection of Personal Data from you. JC shall have the sole discretion to amend the Notice from time to time, and such amended notice shall be published by JC on its official website.

1. “Personal Data” shall have the same meaning in the Personal Data Protection Act 2010 (as may be amended from time to time) (“Act”) in this Notice refers to information about you, from which you are identifiable, including but not limited to your name, date of birth, correspondence address, telephone number, mobile phone number, identity card or passport number, religion, race, religious or customary festivals you celebrate, your image or photograph, gender and work/employment/business information, contact details, any information generated during your engagement with the Company and includes any sensitive personal data.
2. In addition to the Personal Data that you provide to the Company directly, the Company may collect your Personal Data from a variety of sources such as the information in any registration forms or other forms, from third party sources such as advertising websites, agencies, referrals from other third parties, when you submit your information on the Company’s or other related websites (“Websites”) or information otherwise generated upon your engagement/communication with the Company.
3. In some circumstances, your Personal Data may be collected indirectly from monitoring devices or by other means for example, building and location access control and monitoring systems, closed circuit television, telephone logs and recordings and email and Internet access logs.
4. By engaging/communication with and utilisation of the services of the Company, you hereby consent to the processing of your Personal Data and, where you have provided Personal Data of other individuals, you further confirm that you have duly obtained the consent of or for such individuals to the processing of the Personal Data by the Company in accordance with this Notice.
5. The Company does not offer any services to nor will the Company knowingly or intentionally collect or process personal data from individuals under the age of 18. If you are under the age of 18, you are not permitted to use the services of the Company or submit your personal data to the Company.
6. It is necessary for the Company to collect and process your personal data for the purposes listed below. The Company will not be able to effectively provide the services to you if you do not consent to, limit or withdraw your consent to the processing of your personal data by the Company.

7. You hereby acknowledge and agree that the Company collects, uses, processes and retains your Personal Data for the following purposes (“Purposes”):-
   • General administrative and record keeping purposes;
   • Providing services offered by the Company to you;
   • Audit and compliance purposes;
   • Risk management and security purposes;
   • Development, promotion and marketing of programs and initiatives by or in relation to the Company and all works relating to that;
   • Providing and monitoring access to the workplace, related facilities and systems;
   • Internal investigations and legal proceedings, including reference checks with the relevant statutory bodies;
   • Rules and regulatory approvals and compliance; and/or
   • For such other purposes as may be required or permitted by law.

8. Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than Malaysia for the Purposes, including where the Company’s servers are located outside of Malaysia. You hereby consent to the transfer of your Personal Data out of Malaysia as described herein.

9. The Company may engage other companies, service providers or individuals to perform functions on its behalf, and consequently may provide access to or disclose your Personal Data to such service providers or third parties. The third parties referred to in this Section include (without limitation):-
   • third parties to whom the Company outsources certain of its internal functions, such as its information technology vendors and media/marketing agencies;
   • third parties that the Company engages in respect of services that it will offer to you and/or the general public;
   • the Company’s legal advisors, insurers and auditors;
   • other related entities under the Company;
   • legislative, governmental, regulatory and statutory bodies as may be required and permitted under the law; and
   • such other third parties to whom the Company may be required to disclose your Personal Data, based on the contractual terms with such third parties and/or applicable policies.

10. The Company is committed to protecting your personal data and have taken appropriate technical, contractual and organisational measures to safeguard your personal data from any loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction.

11. You may, by giving written notice to the Contact Information set forth below, request to access and/or correct your Personal Data. The Company has the right to refuse an access or correction request for the reasons provided under law.

12. You may, by giving written notice to the Contact Information set forth below, limit the processing of your Personal Data for the Purposes. Please note that where you choose to limit the processing of your Personal Data, this may affect the Company’s ability to perform certain functions in respect of your engagement with the Company.

13. The Company will retain your Personal Data in compliance with this Notice for the duration of your relationship with the Company and for any further period as required for the Company’s business purposes or where required to by law or policies or contractual terms applicable to the Company.
14. Subject to any law or regulation or policies or contractual obligations requiring the Company to retain your Personal Data, the Company will delete your Personal Data after receiving a request to withdraw your consent to the processing of your Personal Data or after it is no longer required for the abovementioned purposes.

15. If you have any inquiries or complaints in respect of your Personal Data collected and processed by the Company, please contact:
    • Name: Muhammad Hisyam Abdullah
    • Designation: Head of Legal
    • Email Address: [email protected]

16. This Notice is issued in English and Bahasa Malaysia versions as required under Section 7(3) of the Act. In the case of inconsistencies, the English version shall prevail.

By virtue of your utilisation of the Company’s services and/or continued interaction with the Company, you acknowledge that you have read and understood this Notice and agree and consent to the collection, use, processing and retention of your Personal Data by the Company as described in this Notice.