LEMMY PROPERTY MANAGEMENT SDN BHD
– PERSONAL DATA NOTICE –
LEMMY PROPERTY MANAGEMENT SDN BHD WEBSITE TERMS OF USE
Lemmy PROPERTY MANAGEMENT Sdn Bhd (“Lemmy”) values your privacy and is committed to protecting your personal data. In compliance with the Personal Data Protection Act 2010 of Malaysia and regulations in relation thereto (“PDPA”), this notice (“Privacy Notice”) is issued to all our valued customers and prospective customers to explain to you how Lemmy collects and processes your personal data in compliance with PDPA and inform you of your rights with regards to your personal data that have been and/or will be collected and processed by us.
PERSONAL DATA COLLECTED
For the purposes of this Privacy Notice, kindly note that “personal data” refers to any information which relates directly or indirectly to you and/or your transaction(s) with us. Personal data includes your name, age, identity card number, passport number, address, gender, date of birth, basic details of your children, marital status, occupation, income range, contact information, email address, employer, race, ethnic origin, nationality, type of products subscribed to, type of loans applied for in relation to the purchase of property(ies), and such other information about yourself and your transaction(s) with us.
SOURCE OF PERSONAL DATA
We may obtain your personal data directly from you, indirectly from third parties such as authorised agents and/or from print, digital channels (including but not limited to website, social media and mobile apps) and/or from other sources in respect of which you have given your consent to disclose such personal data relating to you, through verbal and/or written communications with us and/or authorised agents, or in any other manner in connection with any transaction, arrangements and/or enquiries made with Lemmy. Such sources described may include booking forms, registration forms, online forms, agreements you have signed, name cards or any identity materials that you have distributed voluntarily and business directory(ies) or listing(s) that you have subscribed to share your information.
IMPACT OF NON-PROVISION OF PERSONAL DATA
Where indicated, it is obligatory for you to provide your personal data to us to enable us to process your request for our products and services. Should you choose not to provide all or any part of such obligatory personal data, we may not be able to process your request or provide you with our products or services. In this respect we wish to inform you of the following consequences:-
1. we will/may not be able to provide you with the notices, and current and future services and products requested by you;
2. we will/may not be able to enter into the necessary Sales and Purchase Agreement in relation to the sale of property(ies) and/or other product(s); and/or
3. we will or may not be able to update you on our latest product and/or launches.
PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA
We have collected and/or will collect, record, use, disclose and store (“process”) your personal data within or outside Malaysia over the course of your present and/or future dealings with Lemmy. As our valued customer and/or prospective customer, we have kindly requested that you provide your personal data to, amongst others, enable us to respond to your enquiries, effect the commercial transaction requested by you, ensure seamless client relationship management, deliver the necessary notices in connection with your purchased product and/or our new product launches with our business partners, and plan and subsequently provide future products and services in connection with our business.Your personal data will be collected and processed by us within or outside Malaysia for, amongst others, the following purposes:
1. to process your interest/request for any of our products and services, to respond to any enquiries and to deliver notices in relation to your dealings with Lemmy and to deliver notices in relation to our services or products and to market such services or products whether present or future, to you;
2. to execute the necessary agreement in order to effect your requested commercial transaction to purchase the products and/or property(ies) from us;
3. to fully deliver any particular service or product offered by us and to manage your relationship with Lemmy;
4. to conduct marketing and client profiling activities in connection with our services and related products and to communicate and provide latest information regarding our products, services, upcoming events, promotions and advertising, marketing and commercial materials which may be of interest to you;
5. to conduct credit assessments and other background checks as deemed necessary or appropriate by us;
6. for our internal record keeping and management;
7. to process and collect any payments related to products and services requested by you;
8. for purposes connected with the detection, prevention and prosecution of crime (including but not limited to fraud, money-laundering and bribery);
9. to meet any legal or regulatory requirements relating to our provision of services and products and any disclosure requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code binding upon Lemmy;
10. for research, benchmarking and statistical analysis;
11. for vacant possession, keys handover, property/estate management, customer care and/or defect rectification works;
12. any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us; or
13. for any other purpose that is required or permitted by any laws, regulations, guidelines including the requirements of any governmental or regulatory authorities.
DISCLOSURE OR TRANSFER OF PERSONAL DATA
Your personal data provided to us will be kept confidential and where we consider it necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your personal data to another member of companies of Lemmy group of companies (“Lemmy Group”) within or outside Malaysia, under conditions of confidentiality and similar levels of security safeguards including ensuring that access to your personal data is restricted to employees of Lemmy and/or the related member of Lemmy Group who are responsible for processing your personal data and only personal data deemed necessary is released to such employees. In addition to Lemmy Group, your personal data may be disclosed or transferred to the following categories of third parties within or outside Malaysia under conditions of confidentiality and similar levels of security safeguards and you hereby consent to such disclosure and transfer of your personal data and authorise the release of your personal data to the following categories of third parties:-
1. our business partners and affiliates who may be providing the services or products in connection with our business, for instance third party hotel operators;
2. any bank or financial institution connected via the use of any of your credit card or debit card in any transactions made with us;
3. auditors, consultants, lawyers, insurance companies, banks and other financial advisers, information technology software vendors, event organisers and other professional advisers appointed by us to provide services to us or on our behalf;
4. any of our sub-contractors or third party service or product providers as we may deem necessary or appropriate;
5. any third party property management companies/entities appointed by us in respect of the management of property that our customers have purchased;
6. any government agencies, statutory authorities, local councils, industry; or
7. any person to whom we are compelled or required to disclose to under the laws of any country or in response to any regulatory or governmental agency.
In the event of a proposed and/or actual disposal of business, acquisition, merger, re-organisation or financing exercise in connection with any member of Lemmy Group (“Relevant Transaction“), your personal data may or will be required to be disclosed or transferred to an appointed third party as a result of such Relevant Transaction.
COOKIES AND INTERNET TAGS
Lemmy may collect information regarding your visits to Lemmy Websites and Lemmy Social Media without users expressly and/or actively submitting or consenting to the provision and/or collection of such information. Such information may be collected using information collection and tracking technologies including but not limited to cookies (“Cookies”) and/or other similar type(s) of technology (“Tracking Technologies”). Lemmy may also appoint third party vendors including Google that collect and/or track such information on our behalf. Cookies are small text files that we place in your computer or device to store your preferences. They do not contain any personally identifiable information about you. They help us personalise your experience when you return to our Website, and they are required for certain portions of our Website. Your internet browser via other Tracking Technologies may also transmit to Lemmy and/or its appointed third party vendor similar information, such as the URL of the website you just visited. Lemmy uses Cookies and Tracking Technologies to:-
1. help us remember and understand your preferences based on previous or current website activity which enables us to provide you with improved services;
2. process the items/details entered by you in sign up forms (register interest);
3. keep track of and deliver advertisements relevant to you on websites across the Internet; and
4. help us compile aggregate data about website traffic and website interaction so that we can offer better website experiences and tools in the future,(collectively referred to as “Remarketing Purposes”).
By accessing or using Lemmy Websites, you agree that we can place Cookies on your device and access them for purposes explained above.. You can set your browser option so that you will not receive cookies and you can also delete existing cookies from your browser. However, you may find that some parts of the Website will not function properly if you have refused cookies or similar tracking technologies. If you wish to block cookies, go to http://www.allaboutcookies.org/ to find out how, or check your browser’s instructions.
COLLECTION OF INFORMATION BY THIRD-PARTY SITES
This Website may contain links to other sites whose information practices may be different than ours. You should consult the other sites’ privacy notices, as we have no control over information that is submitted to, or collected by, these third parties or their use of your information.
SAFEGUARDS
We are committed to keeping and processing your personal data in a secure manner at all times. We endeavour, where reasonably practicable, to review and implement appropriate and up-to-date administrative and security safeguards and procedures in accordance with the applicable laws and regulations to prevent unauthorised or unlawful processing of your personal data and any accidental loss or destruction of, or damage to, your personal data.
YOUR RIGHTS OF ACCESS AND CORRECTION TO YOUR PERSONAL DATA
You have the right to request access to and/or the correction of your personal data held by us and in this respect, you may:
1. check whether we hold or use your personal data and request access to such personal data;
2. request that we correct any of your personal data that is in your opinion inaccurate, incomplete, misleading or out-of-date;
3. subject always to our contractual rights and obligations under applicable laws, request that your personal data is retained by us only as long as necessary for the fulfilment of any one or more purposes described in Section 4 hereof;
4. request that we specify or explain our policies and procedures in relation to the types of personal data handled by us and/or methods of handling such personal data;
5. subject always to our contractual rights and obligations under applicable laws, object or request to limit the disclosure or use of your personal data for marketing purposes or whereupon we will not use your personal data for these purposes; and
6. withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable notice period.
We will use reasonable efforts to comply with your request to access or correct your personal data within a reasonable time period of receiving such request. Where applicable we will notify you with reasons in the event we are not able to accede to your request. Kindly note in acceding to the corrections requested, we may require further documentary evidence of such new personal data.
CONTACTING LEMMY PROPERTY MANAGEMENT SDN BHD ABOUT YOUR PRIVACY
Kindly submit all enquiries and written requests for access to your personal data, for correction and/or deletion of your personal data, to limit the processing of your personal data or for information regarding our policies and procedures in relation to the types of personal data handled by us and/or methods of handling such personal data using the following contact points for matters related to Lemmy to [email protected].
CHANGES TO PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time without prior notice. The revised Privacy Policy will be posted to this page so that you are aware of the information we collect, how we use it, and under what circumstances we may disclose it. You are advised to check this Privacy Policy on a regular basis.
CONFLICT
In the event of any conflict between this English language Privacy Notice and its Malay language Privacy Notice, the terms in this English language Privacy Notice shall prevail.
Lemmy PROPERTY MANAGEMENT Sdn Bhd (“Lemmy”) values your privacy and is committed to protecting your personal data. In compliance with the Personal Data Protection Act 2010 of Malaysia and regulations in relation thereto (“PDPA”), this notice (“Privacy Notice”) is issued to all our valued customers and prospective customers to explain to you how Lemmy collects and processes your personal data in compliance with PDPA and inform you of your rights with regards to your personal data that have been and/or will be collected and processed by us.
PERSONAL DATA COLLECTED
For the purposes of this Privacy Notice, kindly note that “personal data” refers to any information which relates directly or indirectly to you and/or your transaction(s) with us. Personal data includes your name, age, identity card number, passport number, address, gender, date of birth, basic details of your children, marital status, occupation, income range, contact information, email address, employer, race, ethnic origin, nationality, type of products subscribed to, type of loans applied for in relation to the purchase of property(ies), and such other information about yourself and your transaction(s) with us.
SOURCE OF PERSONAL DATA
We may obtain your personal data directly from you, indirectly from third parties such as authorised agents and/or from print, digital channels (including but not limited to website, social media and mobile apps) and/or from other sources in respect of which you have given your consent to disclose such personal data relating to you, through verbal and/or written communications with us and/or authorised agents, or in any other manner in connection with any transaction, arrangements and/or enquiries made with Lemmy. Such sources described may include booking forms, registration forms, online forms, agreements you have signed, name cards or any identity materials that you have distributed voluntarily and business directory(ies) or listing(s) that you have subscribed to share your information.
IMPACT OF NON-PROVISION OF PERSONAL DATA
Where indicated, it is obligatory for you to provide your personal data to us to enable us to process your request for our products and services. Should you choose not to provide all or any part of such obligatory personal data, we may not be able to process your request or provide you with our products or services. In this respect we wish to inform you of the following consequences:-
1. we will/may not be able to provide you with the notices, and current and future services and products requested by you;
2. we will/may not be able to enter into the necessary Sales and Purchase Agreement in relation to the sale of property(ies) and/or other product(s); and/or
3. we will or may not be able to update you on our latest product and/or launches.
PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA
We have collected and/or will collect, record, use, disclose and store (“process”) your personal data within or outside Malaysia over the course of your present and/or future dealings with Lemmy. As our valued customer and/or prospective customer, we have kindly requested that you provide your personal data to, amongst others, enable us to respond to your enquiries, effect the commercial transaction requested by you, ensure seamless client relationship management, deliver the necessary notices in connection with your purchased product and/or our new product launches with our business partners, and plan and subsequently provide future products and services in connection with our business.Your personal data will be collected and processed by us within or outside Malaysia for, amongst others, the following purposes:
1. to process your interest/request for any of our products and services, to respond to any enquiries and to deliver notices in relation to your dealings with Lemmy and to deliver notices in relation to our services or products and to market such services or products whether present or future, to you;
2. to execute the necessary agreement in order to effect your requested commercial transaction to purchase the products and/or property(ies) from us;
3. to fully deliver any particular service or product offered by us and to manage your relationship with Lemmy;
4. to conduct marketing and client profiling activities in connection with our services and related products and to communicate and provide latest information regarding our products, services, upcoming events, promotions and advertising, marketing and commercial materials which may be of interest to you;
5. to conduct credit assessments and other background checks as deemed necessary or appropriate by us;
6. for our internal record keeping and management;
7. to process and collect any payments related to products and services requested by you;
8. for purposes connected with the detection, prevention and prosecution of crime (including but not limited to fraud, money-laundering and bribery);
9. to meet any legal or regulatory requirements relating to our provision of services and products and any disclosure requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code binding upon Lemmy;
10. for research, benchmarking and statistical analysis;
11. for vacant possession, keys handover, property/estate management, customer care and/or defect rectification works;
12. any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us; or
13. for any other purpose that is required or permitted by any laws, regulations, guidelines including the requirements of any governmental or regulatory authorities.
DISCLOSURE OR TRANSFER OF PERSONAL DATA
Your personal data provided to us will be kept confidential and where we consider it necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your personal data to another member of companies of Lemmy group of companies (“Lemmy Group”) within or outside Malaysia, under conditions of confidentiality and similar levels of security safeguards including ensuring that access to your personal data is restricted to employees of Lemmy and/or the related member of Lemmy Group who are responsible for processing your personal data and only personal data deemed necessary is released to such employees. In addition to Lemmy Group, your personal data may be disclosed or transferred to the following categories of third parties within or outside Malaysia under conditions of confidentiality and similar levels of security safeguards and you hereby consent to such disclosure and transfer of your personal data and authorise the release of your personal data to the following categories of third parties:-
1. our business partners and affiliates who may be providing the services or products in connection with our business, for instance third party hotel operators;
2. any bank or financial institution connected via the use of any of your credit card or debit card in any transactions made with us;
3. auditors, consultants, lawyers, insurance companies, banks and other financial advisers, information technology software vendors, event organisers and other professional advisers appointed by us to provide services to us or on our behalf;
4. any of our sub-contractors or third party service or product providers as we may deem necessary or appropriate;
5. any third party property management companies/entities appointed by us in respect of the management of property that our customers have purchased;
6. any government agencies, statutory authorities, local councils, industry; or
7. any person to whom we are compelled or required to disclose to under the laws of any country or in response to any regulatory or governmental agency.
In the event of a proposed and/or actual disposal of business, acquisition, merger, re-organisation or financing exercise in connection with any member of Lemmy Group (“Relevant Transaction“), your personal data may or will be required to be disclosed or transferred to an appointed third party as a result of such Relevant Transaction.
COOKIES AND INTERNET TAGS
Lemmy may collect information regarding your visits to Lemmy Websites and Lemmy Social Media without users expressly and/or actively submitting or consenting to the provision and/or collection of such information. Such information may be collected using information collection and tracking technologies including but not limited to cookies (“Cookies”) and/or other similar type(s) of technology (“Tracking Technologies”). Lemmy may also appoint third party vendors including Google that collect and/or track such information on our behalf. Cookies are small text files that we place in your computer or device to store your preferences. They do not contain any personally identifiable information about you. They help us personalise your experience when you return to our Website, and they are required for certain portions of our Website. Your internet browser via other Tracking Technologies may also transmit to Lemmy and/or its appointed third party vendor similar information, such as the URL of the website you just visited. Lemmy uses Cookies and Tracking Technologies to:-
1. help us remember and understand your preferences based on previous or current website activity which enables us to provide you with improved services;
2. process the items/details entered by you in sign up forms (register interest);
3. keep track of and deliver advertisements relevant to you on websites across the Internet; and
4. help us compile aggregate data about website traffic and website interaction so that we can offer better website experiences and tools in the future,(collectively referred to as “Remarketing Purposes”).
By accessing or using Lemmy Websites, you agree that we can place Cookies on your device and access them for purposes explained above.. You can set your browser option so that you will not receive cookies and you can also delete existing cookies from your browser. However, you may find that some parts of the Website will not function properly if you have refused cookies or similar tracking technologies. If you wish to block cookies, go to http://www.allaboutcookies.org/ to find out how, or check your browser’s instructions.
COLLECTION OF INFORMATION BY THIRD-PARTY SITES
This Website may contain links to other sites whose information practices may be different than ours. You should consult the other sites’ privacy notices, as we have no control over information that is submitted to, or collected by, these third parties or their use of your information.
SAFEGUARDS
We are committed to keeping and processing your personal data in a secure manner at all times. We endeavour, where reasonably practicable, to review and implement appropriate and up-to-date administrative and security safeguards and procedures in accordance with the applicable laws and regulations to prevent unauthorised or unlawful processing of your personal data and any accidental loss or destruction of, or damage to, your personal data.
YOUR RIGHTS OF ACCESS AND CORRECTION TO YOUR PERSONAL DATA
You have the right to request access to and/or the correction of your personal data held by us and in this respect, you may:
1. check whether we hold or use your personal data and request access to such personal data;
2. request that we correct any of your personal data that is in your opinion inaccurate, incomplete, misleading or out-of-date;
3. subject always to our contractual rights and obligations under applicable laws, request that your personal data is retained by us only as long as necessary for the fulfilment of any one or more purposes described in Section 4 hereof;
4. request that we specify or explain our policies and procedures in relation to the types of personal data handled by us and/or methods of handling such personal data;
5. subject always to our contractual rights and obligations under applicable laws, object or request to limit the disclosure or use of your personal data for marketing purposes or whereupon we will not use your personal data for these purposes; and
6. withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable notice period.
We will use reasonable efforts to comply with your request to access or correct your personal data within a reasonable time period of receiving such request. Where applicable we will notify you with reasons in the event we are not able to accede to your request. Kindly note in acceding to the corrections requested, we may require further documentary evidence of such new personal data.
CONTACTING LEMMY PROPERTY MANAGEMENT SDN BHD ABOUT YOUR PRIVACY
Kindly submit all enquiries and written requests for access to your personal data, for correction and/or deletion of your personal data, to limit the processing of your personal data or for information regarding our policies and procedures in relation to the types of personal data handled by us and/or methods of handling such personal data using the following contact points for matters related to Lemmy to [email protected].
CHANGES TO PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time without prior notice. The revised Privacy Policy will be posted to this page so that you are aware of the information we collect, how we use it, and under what circumstances we may disclose it. You are advised to check this Privacy Policy on a regular basis.
CONFLICT
In the event of any conflict between this English language Privacy Notice and its Malay language Privacy Notice, the terms in this English language Privacy Notice shall prevail.