PERSONAL DATA PROTECTION NOTICE & CHOICE PRINCIPLE NOTIFICATION AND CONSENT PURSUANT TO SECTIONS 7 AND 6, RESPECTIVELY, OF THE PERSONAL DATA PROTECTION ACT 2010 (‘PDPA”)


ENGLISH VERSION


Dear Sir / Madam,


Setia City Mall is managed by Compass Property Management Sdn Bhd (“the Company”, "we", "our" or "us"). The Company treats your personal data and your privacy with respect and integrity. This Notice has been prepared in connection with the requirements of the PDPA.


1.    Collection of Personal Data


You are hereby informed that we will record, hold, store, use, disclose and/or process (collectively, referred to as "Process") personal information about you in connection with your participation in the activities or events organized by us (which shall include without limitation lucky draws, redemption programmes). In particular, we will Process some, one or all of the categories of personal information about you which shall include without limitation your name, email address, contact details and such other information as we deem necessary or appropriate from time to time in connection with your participation in the activities or events organized by us ("Personal Data").


If you disclose to us any personal information (whether within the definition of Personal Data above or otherwise) of another individual, we shall assume, without independent verification and in reliance on your representation herein to us, that you have obtained such individual's consent for the disclosure of such information as well as the Processing of the same in accordance with the terms of this notification.


2.    Sources of Information


The Personal Data will be obtained from application forms you complete, other written or verbal communications or documents delivered to us during the course of our dealings with you or such other sources which we see fit from time to time.


As the accuracy and integrity of the Personal Data depends largely on the information you provide to us, kindly inform us as soon as practicable if there are any errors in your Personal Data or if there have been changes to your Personal Data.


3.    Processing


We will Process your Personal Data for the following purposes:


(a) for the Company’s record-keeping in the ordinary course of its business;
(b) to administer the activities or events organized by us and to contact and communicate with you and/or such other persons duly authorised to represent you;
(c)  to enable the Company to inform you and/or such other persons duly authorised to represent you regarding Setia City Mall’s products, services, upcoming events, promotions, advertising, marketing and commercial materials via emails, SMS, telephone or such other forms of communications as maybe permitted under law and/or to be used in, to provide and/or to improve the services of the Company, analysing consumption patterns and choices, market surveys, processing invoices and payments (including card payments) and providing such other services to enhance and support the relationship with you and/or such other persons as duly authorised to represent you;
(d) to enable the Company’s compliance with its obligations under any law, rule, regulation, by-law, order, guideline, directive, policy and such other requirements in force and as amended from time to time relating to the conduct of the business or activities of the Company; and
(e) such other purposes as we deem necessary or appropriate from time to time.

4.    Storage and Security


We store your Personal Data in hardcopy and/or softcopy. Softcopy data is stored on, amongst others, the file server, e-mail server, personal computers, notebooks, tapes and compact disc.


There are corporate security policies and procedures in place which among others confines access to your Personal Data to authorised personnel only on a strictly need-to-know basis to the relevant department such as the administration, finance, sales and/or customer service] departments of the Company.


We may retain the Personal Data and that of other individuals that you provide to us for a reasonable period in accordance with commercial requirements and at all times subject to prevailing legal requirements.


5.    Disclosure and Processing


In general, we will not disclose your Personal Data to any third party unless you have notified us in writing that you do consent to such disclosure. Therefore, if you envisage that any third party will be contacting us to request for your Personal Data, you must notify us in advance and provide your written consent for us to disclose your Personal Data.


Please note that it may be necessary for us to disclose your Personal Data:


(a) to the relevant authorities to meet legal and regulatory requirements;
(b) to the Company’s successor in interest, sponsors, advertisers, solicitors, insurers, adjusters, other advisers, suppliers, contractors and/or service providers, for purposes such as procurement of advise, conducting marketing analytics;
(c) to the Owners of Setia City Mall, Company’s parent company, related and associated companies, affiliates and business partners, some of whom may be outside Malaysia, who may undertake administrative, management and operational functions for or on behalf of the Company in respect of or arising from the commercial transaction or to support and/or participate in sales, marketing, promotion and/or joint advertising efforts;
(d) in the event of any sale of business, disposal, acquisition, merger or reorganisation involving the Company or in relation to the sale of the Setia City Mall, to any party as part of the process of sale, disposal, acquisition, merger or reorganisation; and
(e) such other purposes as we deem necessary or appropriate from time to time.

In addition, you will appreciate that we are affiliates of the Lend Lease group which operates in multiple jurisdictions. Accordingly, access to your Personal Data may be granted to other entities within the Lend Lease group and may be transferred out of Malaysia for the purpose stated in Clause 5(c) above.


Please be assured that we will only disclose the minimum amount of information which we deem necessary for the purpose and that we will take all appropriate safeguards to ensure the integrity and security of the Personal Data.


6.    Providing Personal Data: Obligatory or Voluntary


You have the option not to provide the information requested or such additional information requested, other than the information which the Company has indicated as necessary to facilitate your participation in the activities or events organized by us. If you do not complete the required fields or provide the information requested for, the Company will not be able to offer you with the relevant services and/or fulfil your requests or respond to your enquiries.


7.    Access to Personal Data and limiting Processing


You have the right to, subject to payment of the prescribed fees where applicable, request access to and/or request for correction of your Personal Data and/or limit the processing thereof. We must however point out that, in limiting the Processing as requested, the same consequences described in Clause 6 above could result. If this is the case, we will inform you of the consequences in further detail depending on the specific category of Personal Data.


In the event of such request, or if you would like to inquire or have concerns in respect of the Company’s handling of your Personal Data, email us at concierge@setiacitymall.com.