PDP Notice
PERSONAL DATA PROTECTION AND COOKIES NOTICE FOR WEBSITE
1. Kumpulan Wang Persaraan (Diperbadankan), its respective wholly-owned subsidiaries (which will include but not limited to, KWEST Sdn Bhd and Prima Ekuiti (UK) Limited (“PEUK”)) and special purpose entities (collectively “KWAP”, “we”, “us” or “our”) will process your personal data for purposes of your use of our services via our websites (“Site”), your participation in any events, programmes, trainings, workshops, seminars, surveys and all other events organised by KWAP, and/or any other forms of engagement with KWAP. Your personal data will be obtained from:
- the forms and supporting documents that you had filled / submitted, have to or may be required to fill / submit;
- your interaction and communication with KWAP through various methods including emails, social media and letters, telephone calls and conversations you have with KWAP’s personnel and/or our authorised agents, whether via the Site or otherwise;
- your participation in any contests and/or events organised by us; and/or
- the public domain and third parties such as statutory bodies, or government agencies and/or service providers.
2. Your personal data that could be collected and processed includes but is not limited to the following:
- your identity and background (including your name, NRIC / passport numbers or copies thereof, occupation, place of work or study, date of birth, age, gender, race, religion, nationality, academic information information regarding social media, user identification (ID) and account, photograph, travel history and medical information) – save and except for residents of the United Kingdom (“UK”) or European Economic Area (“EEA”), from whom more limited identity and background data will be collected;
- your contact information (including your telephone number, email, mailing addresses and fax number);
- your family information (including their name, relationship with you, their NRIC / passport numbers or copies thereof, age, gender, date of birth and occupation);
- your emergency contact information (including their name, relationship with you and contact details);
- information generated from your use of the Site, including information obtained from cookies such as location data, your IP address, the time and date you visit the Site, pages viewed and other relevant information;
- your professional qualifications and/or experience, job title and/or employer;
- your financial details (including banking details); and/or
- any other personal data that you provide to us for the purpose of a commercial transaction or in connection with a business relationship between you and KWAP.
3. By accessing and using the Site and/or communicating and interacting with KWAP, you consent to KWAP processing your personal data in accordance with this Personal Data Protection Notice (“Notice”) (save and except for residents of the UK and EEA, whose consent is not required where other legal bases apply, as explained below):
For residents of the UK or EEA
KWAP may collect, use and share your information on one or more of the following legal bases:
- as necessary to comply with our respective legal obligations;
- to protect your vital interests, or those of others;
- as necessary in the public interest;
- as necessary for our (or others’) respective legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data, including:
- to send you invitations to events, and/or email updates;
- to promote and carry out the functions of KWAP;
- to manage our relationships with our expert advisers or any vendors or potential vendors;
- to organise and manage stakeholder briefings;
- to comply with KWAP’s internal policies; and
- to protect KWAP (including our rights and/or property) or others, including in the context of investigations or regulatory enquiries.
- to perform our contractual obligations, or to take steps at your request prior to entering into a contract with you; and
- with your consent, unless we have another legal basis upon which to do so.
4. Where applicable, we will process your personal data and information for the following purposes:
- to facilitate your use of and access to the Site;
- to analyse your usage of the Site and other trends;
- to increase the Site’s functionality and user friendliness;
- to request feedback and/or to otherwise contact you about your use of the Site;
- for contact and communications purposes, including responding to any queries and complaints as well as for emergencies;
- to process your registration and participation in respect of any contests, events and/or surveys organised by KWAP;
- for the purposes of being featured in official publications to be published on the Site, social media platforms and internal portals, including but not limited to KWAP annual report publications and announcements, or external publications including news portals and media outlets;
- for the purposes of compliance, audit and risk assessments;
- for administrative and operational purposes;
- to report and investigate complaints and prevent suspicious transactions, prohibited activities and other illegal activities including but not limited to fraud, bribery and money laundering;
- to protect and enforce KWAP’s rights under applicable laws or to defend KWAP’s rights under law and/or to obtain legal advice;
- for identification, verification and security purposes;
- for compliance with KWAP’s internal policies;
- to perform our obligations in respect of any commercial transaction entered into with you or with any of our vendors; and/or
- for any other purpose that is incidental, ancillary or in furtherance to the above purposes.
The information you provide is necessary to us. Unless otherwise stated, all information requested by KWAP is obligatory or relevant to our legitimate interests. If you do not provide all the information as requested and/or do not allow us to process the information accordingly, we will not be able to keep your complete record of information, thus affecting our ability to accomplish the above stated purposes.
When providing us with the information, you represent that such information is accurate, complete, up to date and true. Where you provide personal data of another person, such as those of your dependants or family members, you acknowledge and warrant that you have obtained their consent for us to process their personal data.
For residents of the UK or EEA
When we process data that you provide to us based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To exercise your rights, please contact us using the contact details below.
click here: Access, corrections and complaints
5. Retention of data
KWAP stores data until it is no longer necessary to fulfil the purposes for which it was collected. This is a case-by-case determination that depends on things such as the nature of the data, why it was collected and processed and relevant legal or operational retention needs.
In some circumstances, KWAP may anonymise your information or aggregate it with other information so that it can no longer be associated with you, in which case KWAP may use the information without further notice to you.
6. Sensitive information
By expressly signifying your consent to us, you give us your explicit consent to process your sensitive personal data such as your mental or physical health and condition, religious beliefs and/or misconducts (civil or criminal, if any) for the purposes described above or as required by law.
We may also obtain your sensitive personal information from other parties when it is allowed by law.
For residents of the UK or EEA
- You can choose to provide sensitive information to us about your race or ethnicity, religious or philosophical beliefs, trade union membership, sexual orientation, political opinions, your health, and/or criminal convictions, allegations, proceedings and offenses which relate to you (“Sensitive Information”). This is subject to special protection under EEA and UK law. Where KWAP collects, uses and shares your Sensitive Information in cases where UK / EEA data protection laws apply, it relies upon one or more of the following legal bases:
- with your consent, which you may revoke at any time;
- to establish, exercise or defend legal claims; or
- where the information has already been made public by you.
- Please do not share non-public Sensitive Information with us unless you consent to us holding and using that information.
7. Disclosure of information
KWAP may disclose your personal data to the following parties (including those within and outside of Malaysia) for purposes stated in this Notice:
- your agents and advisors (including but not limited to accountants, auditors, lawyers, financial advisers or other professional advisers) and any other person notified by and authorised by you;
- any person, who is under a duty of confidentiality and/or who has undertaken the responsibility to keep such data confidential;
- any actual or proposed assignee, participant, sub-participant or transferee of any of our rights or obligations;
- third parties appointed by KWAP to provide services to KWAP or on our behalf (including KWAP’s agents, professional advisors, and other such service providers);
- event organisers;
- potential or actual purchasers, successors-in-title of business or shares (wholly or in part) of any of KWAP’s subsidiaries, related corporations, jointly controlled entities and affiliates (including their advisers and representatives) as a result of a potential, proposed or actual sale of business, disposal, acquisition, merger or re-organisation;
- KWAP’s related companies, associated corporations, affiliates and strategic partners; and/or
- other parties, in respect of whom you have consented to the disclosure of your personal data or where disclosure is otherwise required in order to comply with a legal or regulatory obligation.
Save and except for the above, we will not disclose your personal data to any other third parties without your consent. However, we may disclose your personal data in good faith, if such action is necessary to comply with government or law enforcement agency (including those overseas) requirements, court orders or legal processes, or if required by law.
For residents of the UK or EEA
To ensure that your information receives an adequate level of protection when we transfer data to any country which is not the subject of an adequacy decision, KWAP has or will put in place appropriate measures, including standard contractual clauses. If you require further information about this, please contact us using the contact details below:
Tel : +603-21748095
Email : idpm@kwap.gov.my
8. Automated Decision Making
For residents of the UK or EEA
KWAP does not envisage that any decisions will be taken about you by KWAP using automated means, but will notify you by posting an updated version of this privacy notice if this position changes.
9. Right to Complain
For residents of the UK or EEA
UK and EEA data subjects have the right to make a complaint to their national supervisory authority for data protection issues where KWAP is acting as a data controller under UK or EEA data protection laws.
For UK data subjects, this is the UK Information Commissioner’s Office.
10. Links to third party websites
The Site may contain external links to third parties’ websites. We shall not be responsible for the processing of your personal data by such third parties. If you provide your personal data directly to such websites, the personal data protection policies as made available on those websites shall govern the processing of such personal data.
11. Access, corrections and complaints
If you would like to make any inquiries or complaints or requests to access, correct or limit our processing of your personal data, you may contact our Data Protection Manager as follows:
Tel : +603-21748095
Email : idpm@kwap.gov.my
We will address your concerns as soon as practicable upon receipt of your request. Please note that any request for access or correction of personal data may subject to a fee and will be subject to the prevailing data protection laws in Malaysia.
For residents of the UK or EEA
KWAP may collect, use and share your information on one or more of the following legal bases:
- If you are a resident of the UK or EEA you have the right to:
- Request access to your personal information (commonly known as a data subject access request). This enables you to request a copy of the personal information that KWAP holds about you and to check that it is lawfully processed;
- Request correction of your personal information;
- Request erasure of your personal information. This enables you to ask KWAP to delete or remove personal information where there is no good reason for KWAP to continue to process it;
- Object to processing of your personal information where KWAP is relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
- Request the restriction of processing of your personal information. This enables you to ask KWAP to suspend the processing of personal information about you, for example if you want to establish its accuracy or the reason for processing it;
- Request the transfer of your personal information to another party (in some circumstances, for example if we process your personal data as a result of your consent under UK or EEA data protection laws, or to fulfil a contract with it); and/or
- Withdraw yourconsent to the processing of your personal information at any time where we process personal data on the basis of your consent, without affecting the lawfulness of processing based on consent before its withdrawal.
- If you would like to make any inquiries or complaints, or to exercise your rights under UK or EU data protection laws, you may contact the Data Protection Manager as follows:
Tel : +44 20 3595 1250
Email : privacy@primaekuiti.co.uk
12. Data Controllers
For residents of the UK or EEA
Under UK and EEA data protection laws, a data controller is responsible for deciding how it holds and uses information about you. For residents of the EEA or UK, KWAP, PEUK, KWAP’s respective wholly owned subsidiaries and/or KWAP’s special purpose entities will be a data controller, depending on the relevant processing, and two or more of them may be joint data controllers, when relevant.
If information is collected directly by PEUK, they may be acting as a processor of KWAP. However, in some circumstances, for example where PEUK has a direct relationship with vendors, PEUK may act as a data controller.
Kumpulan Wang Persaraan (Diperbadankan)
Level 36, Integra Tower
The Intermark
348, Jalan Tun Razak,
50400 Kuala Lumpur, Malaysia
General No: +603-21748000
Prima Ekuiti (UK) Limited
Prima Ekuiti,
Suite 2, 9th Floor,
Berkeley Square House,
Berkeley Square, London, W1J 6DD
General No: +44 20 3595 1250
For any inquiries, please contact our Data Protection Manager whose contact details are set out under Section 11 above.
In the event of any inconsistencies between the English version and the Bahasa Malaysia version of this Notice, the English version shall prevail.
Please note that any variation to this Notice shall be communicated to you through suitable modes of communication.
13. Cookies
Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
Cookies may be one of the following:
- Strictly necessary cookies. These are cookies that are required for the operation of a website. They include, for example, cookies that enable you to log into secure areas of a website, use a shopping cart or make use of e-billing services;
- Analytical or performance cookies. These allow websites to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps to improve the way a website works, for example, by ensuring that users are finding what they are looking for easily;
- Functionality cookies. These are used to recognise you when you return to a website. This enables websites to personalise content for you, greet you by name and remember your preferences (for example, your choice of language or region); or
- Targeting cookies. These cookies record your visit to a website, the pages you have visited and the links you have followed. Websites use this information to make the website and the advertising displayed on it more relevant to your interests.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| Cookie Name | Purpose | More information |
|---|---|---|
| Google Analytics | This cookie enables us to estimate our audience size and usage pattern. | Click here |
If you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.
Except for essential cookies, all cookies will expire after twenty-six (26) months from the date of your visit to our Site.
You can control and/or delete cookies as you wish – for details, see About Cookies. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.