1.1 Early Autism Project Malaysia, The Hope Project and Autism at Home (“we”, “us”, or “our”) are committed to protecting the privacy of the individuals we encounter in conducting our business. “Personal Data” applies to personal information about individuals (clients, vendors, distributors, suppliers, service providers, joint venture/business partners, job applicants, employees) held by us.
1.2 We will only process your Personal Data in accordance with the Personal Data Protection Act 2010 (“PDPA”) as well as this Policy.
1.3 We are required pursuant to the PDPA, to inform you how your information is collected and used and your choices with respect to your Personal Data. The PDPA also requires us to obtain your consent to the processing of your Personal Data. Therefore, we are committed to protecting and safeguarding your Personal Data.
1.4 By providing your Personal Data to us and/or continuing to access our website, you declare that you have read and understood this Policy and agree to us processing your Personal Data in accordance with the manner provided in this Policy.
1.5 By providing reasonable notice, we reserve the right to modify, amend and/or update this Policy, from time to time. The relevant amendments will be notified to you via announcements on the website or other appropriate means. Please accordingly check the website from time to time. Any amendments to this Policy will be effective upon notice to you. By continuing to access the website and/or use the services of the website after being notified of any amendments to this Policy, you will be treated as having agreed to and accepted those amendments.
1.6 If you do not agree to this Policy or any amendments to this Policy, we may not be able to render all services to you and you may be required to terminate your relevant agreement with us and/or stop accessing or using the Site.
2. CONTACT DETAILS:
If you have any questions or queries arising concerning this Policy or would like to submit a complaint or correction request or data access regarding your Personal Data, you may contact us at the contact details below:
Data Protection Officer
Address: Early Autism Project Malaysia, 30 Jalan Keruing, Bukit Bandaraya, Bangsar, 59100 Kuala Lumpur, Malaysia
Contact No.: +60 3 2094 0421
Email Address: firstname.lastname@example.org
3. COLLECTION OF PERSONAL DATA
Personal Data means any information in our control or possession that directly or indirectly relates to an individual who is identifiable. Your Personal Data may be collected through via your dealings with us including any transactions and/or communications with/from us. Your Personal Data may also be collected through a range of sources, including but not limited to any events, road shows, seminars, customer satisfaction surveys organised and/or sponsored by us, as well as from publicly available sources.
4. PURPOSE OF ACQUIRING AND PROCESSING YOUR PERSONAL DATA
The purpose of acquiring the Personal Data is to enable us to understand your required services and/or needs, to conduct our business and to provide better customer service and products and/or services.
The purposes for which we may collect and/or use the Personal Data includes the following –
- to communicate with you so as to provide the relevant services or related products and administer, manage, maintain and operate such services and/or products including any renewals (as relevant);
- to assess, process and provide products and/or services;
- to manage our business operations and infrastructure, and comply with internal policies and procedures, including finance and accounting, audit related, billing and collections; data and website hosting, IT systems; business continuity;
- for audit, compliance, investigation and inspection purposes;
- to conduct background and identity checks, so as to verify your identity, in order to respond to your request;
- to respond to your complaints and/or enquiries and accordingly resolve any issues which may arise;
- to provide information and/or updates on our services, products, upcoming promotions offered by us and/or events organised by us and selected third parties, from time to time, which may be of interest to you;
- to facilitate your participation in, and our administration of, any events including contests, promotions or campaigns;
- to send you seasonal greetings messages from time to time;
- to share any of your Personal Data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
- to comply with applicable laws and regulatory obligations (including laws outside of Malaysia);
- to share any of your Personal Data with our joint venture/business partners to jointly develop products and/or services or launch marketing campaigns;
- for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
- for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
- to transfer or assign our rights, interests and obligations under any agreements entered into with us;
- to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
- to carry out verification and background checks as part of any recruitment and selection process in connection with your application for employment with us; and/or
- for any other purposes required to operate, maintain and better manage our business and your relationship with us, which we notify you of at the time of obtaining your consent; and you agree and consent to us using and processing your Personal Data for the purposes in the manner as identified in this Policy. If you do not consent to us processing your Personal Data for one or more of the purposes, please notify us. (See the “Contact Details: Who to contact about your Personal Data” section above.)
5. CONSEQUENCES OF NOT CONSENTING TO THIS POLICY
The collection of your Personal Data by us may be mandatory or voluntary in nature depending on the purposes for which your Personal Data is collected. Where it is obligatory for you to provide us with your Personal Data, and you fail or choose not to provide us with such data, or do not consent to the above or this Policy, we will not be able to provide products and/or services or otherwise deal with you.
6. DISCLOSURE OF YOUR PERSONAL DATA
Your Personal Data will not be disclosed, sold, rented or transferred to any third party without your consent. However, your Personal Data may be disclosed to the following third parties, for one or more of the above purposes:
- Early Autism Project Malaysia’s related affiliates either in Malaysia or overseas;
- your immediate family members and/or emergency contact person as may be notified to us from time to time;
- successors in title to us;
- any data centres and/or servers located within or outside Malaysia for data storage purposes or otherwise;
- any party in relation to legal proceedings or prospective legal proceedings;
- any person under a duty of confidentiality to which has undertaken to keep your Personal Data confidential which we have engaged to discharge our obligations to you;
- our consultants, auditors, accountants, lawyers or other financial or professional advisers appointed in connection with our business on a strictly confidential basis, appointed by us to provide services to us;
- any party nominated or appointed by us either solely or jointly with other service providers, for purpose of establishing and maintaining a common database where we have a legitimate common interest;
- payment channels including but not limited to financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to us in connection with your purchase of our services and/or products;
- government agencies, law enforcement agencies, courts, tribunals, regulatory bodies, industry regulators, Ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities;
- our joint venture/business partners, third-party product and/or service providers, suppliers, vendors, contractors, data processors or agents, that provide related products and/or services in connection with our business, or discharge or perform one or more of the purposes required to operate and maintain our business, including but not limited to call centers, telecommunication companies, logistics companies, information technology companies and data centers; insurance companies for the purpose of applying and obtaining insurance policy(ies), if necessary;
- to third-party credit reporting or employment agencies as part of the recruitment and selection process and/or otherwise in connection with your application for employment with us; financial institutions for the purpose of applying and obtaining credit facility(ies), if necessary;
- financial institutions, merchants and credit card organisations in connection with your commercial transactions with us;
- the general public when you become a winner in a contest by publishing your name, photographs and other Personal Data without compensation for advertising and publicity purposes;
- in the event of a potential, proposed or actual sale/disposal of any of our business or interest, merger, acquisition, consolidation, re-organisation, funding exercise or asset sale relating to us, or in the event of winding-up , your Personal Data may be required to be disclosed or transferred to a third party as a result of, or in connection with, the transaction.
- You hereby acknowledge that such disclosure and transfer may occur and permit us to disclose and transfer your Personal Data to such third party and its representatives and/or advisors and/or any other person reasonably requiring the same in order for us to operate and maintain our business or carry out the activities.
7. ACCURACY AND SECURITY OF YOUR PERSONAL DATA
We will take appropriate technical, organisational, physical and legal measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be completely secure. If you have reason to believe that your transaction with us is no longer secure (such as the security of any Personal Data you might have with us has been compromised), please immediately notify us. (See the “Contact Details: Who to contact about your Personal Data” section above.)
When we provide Personal Data to a service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Data.
We cannot and do not accept responsibility for any unauthorised access or interception or loss of Personal Data that is beyond our reasonable control.
8. YOUR RIGHTS
8.1 Subject to the exceptions provided under the PDPA, you have the right to request for access to, request for a copy of, a request to update or correct, your Personal Data held by us. We may charge a small fee (such amount as permitted by the PDPA) to cover the administration costs involved in processing your request to access your Personal Data.
8.2 In respect of your right to access and/or correct your Personal Data, we have the right to refuse your request to access and/or correct your Personal Data for the reasons permitted under the law, such as where the expense of providing access to you is disproportionate to the risks to your privacy, or where the rights of others may also be violated, amongst other reasons.
8.3 You have the right at any time to request to opt-out from receiving marketing-related communications, by contacting us. (See the “Contact Details: Who to contact about your Personal Data” section above.)
8.4 In addition, you also have the right, by notice in writing, to inform us on your withdrawal (in full or in part) of your consent given previously to us subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be affected. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we will not be able to continue with your existing relationship with us and/or the contract that you have with us will have to be terminated.
9. RETENTION OF YOUR PERSONAL DATA
We take reasonable measures to ensure that your Personal Data is retained for as long as the purposes for which the Personal Data was collected continues, unless its further retention is required to satisfy a longer retention period as required or permitted by law.
10. PERSONAL DATA FROM MINORS AND OTHER INDIVIDUALS
To the extent that you have provided (or will provide) Personal Data about your family, spouse and/or other dependents, you confirm that you have explained to them that their Personal Data will be provided to, and processed by, us and you represent and warrant that you have obtained their consent to the processing (including disclosure and transfer) of their Personal Data in accordance with this Policy and, in respect of minors (i.e. individuals under 18 years of age) or individuals not legally competent to give consent, you confirm that they have appointed you to act for them, to consent on their behalf to the processing (including disclosure and transfer) of their Personal Data in accordance with this Policy.
11. TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF MALAYSIA
Our information technology storage facilities and servers may be located in other jurisdictions outside of Malaysia. This may include, but not limited to, instances where your Personal Data may be stored on servers located outside Malaysia. In addition, your Personal Data may be disclosed or transferred to entities located outside Malaysia or where you access the Site from countries outside Malaysia. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in Malaysia under the laws of Malaysia. You hereby expressly consent to us transferring your Personal Data outside of Malaysia for such purposes. We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of Malaysia shall not use your Personal Data other than for that part of the Purposes and to adequately protect the confidentiality and privacy of your Personal Data.
12.1 External links
(a) If any part of the Site links you to other websites, those websites do not operate under this Policy and we do not accept any responsibility or liability arising from those websites.
(b) Likewise, if you subscribe to an application, content or a product from our strategic partner and you subsequently provide your Personal Data directly to that third party, that Personal Data will be subject to that third party’s privacy/personal data protection policy (if they have such a policy) and not to this Policy.
(c) We recommend that you read and understand the privacy/personal data protection statement/policy posted on those other websites in order to understand their procedures for collecting, processing, using and disclosing personal data and before submitting your Personal Data to those websites.
(a) We employ an industry standard technology called “cookies”. The cookie is a small piece of information stored on the hard drive of your computer or device for record-keeping purposes and is used by us to track your visits to the website. Cookies may be used to save your preferences for your convenience when using the website. Third party advertising networks may issue their separate cookies to your hard drive when serving advertisements.
(b) The type of anonymous clickstream data collected by us through the cookies may include your Internet Protocol address, web browser software, date and time of visit to the website, and whether your requests (including search requests and clicking on links to parts of the website) were met with success. All such information collected through cookies is not Personal Data and you cannot be identified from this information. Such information is only used for the purpose of managing and creating a better user experience and to identify areas for improvement on the website.