PERSONAL DATA PROTECTION POLICY

Introduction
1. BRDB Developments Sdn. Bhd. (Company No. 5521-A) and its group of companies (“BRDB Group”) are committed to protecting the personal data supplied by you to BRDB Group to ensure compliance with the legal and regulatory requirements in accordance with the Personal Data Protection Act 2010 (“Act”).
2. For the purpose of this Personal Data Protection Policy, "personal data" shall have the meaning as ascribed to it in the Act which means any information in respect of commercial transactions, which:-
  1. is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose;
  2. is recorded with the intention that it should wholly or partly be processed by means of such equipment; or
  3. is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system,
  that relates directly or indirectly to a data subject, who is identified or identifiable from that information or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject; but does not include any information that is processed for the purpose of a credit reporting business carried on by a credit reporting agency under the Credit Reporting Agencies Act 2010.
3. This Personal Data Protection Policy is issued in both English Language and Bahasa Malaysia. In the event of any inconsistencies between the English version and the Bahasa Malaysia version, the English version shall prevail.
Types of Personal Data Collected
1. During the course of your transaction and dealings with BRDB Group, you may be requested to furnish from time to time to BRDB Group, directly or through online forms available through the websites of BRDB Group and/or other electronic methods, your personal data, which may include your name, gender, age, marital status, date of birth, race, nationality, identity card number, passport number, visa information, correspondence address, email address, telephone contact number, occupation, income range, credit card or bank account information, financing details for the purchase of the property of BRDB Group’s housing development project and/or other information relevant to the purposes listed in Item C(1) below.
2. The types of personal data collected will be depending on the nature of your dealings or transaction with BRDB Group.
Purpose of Collection
1. BRDB Group may collect, retain, use and otherwise process your personal data for the following purposes:-
  1. providing you with services under any business of BRDB Group; or
  2. processing your application or registration under any program and/or activities organized or conducted by BRDB Group or in connection with your employment application; or
  3. notifying you of services or launches of properties or products whether present or future, updates and promotions including delivery of notices and sending any advertising and/or marketing material, to you (including notices through social media platforms); or
  4. sale of the products and/or properties offered by BRDB Group to you which shall include all matters relevant for the completion of the sale and purchase transactions, delivery of vacant possession, defect rectification works and other post vacant possession services; or
  5. tenancies entered into between BRDB Group and you, which shall include all matters relevant for the completion of the tenancies, delivery of vacant possession of the tenanted premises, and other matters with regard thereto; or
  6. entering into any transactions, agreements or instruments in the ordinary course of business of BRDB Group; or
  7. discharging BRDB Group’s contractual obligations in the ordinary course of business of BRDB Group; or
  8. property and/or estate management; or
  9. collection of any payments due and payable to BRDB Group including late interest charges; or
  10. credit assessments and other background verification that may be necessary or appropriate for BRDB Group’s business or employment purposes; or
  11. human resource management; or
  12. sending you services, products or promotional information related to other third parties which BRDB Group thinks you may be interested; or
  13. discharging BRDB Group’s duties and obligations under the Companies Act 2016, the Capital Markets and Services Act 2007 and any other applicable law, regulation, direction and guideline applicable to BRDB Group; or
  14. internal record keeping; or
  15. in anticipation of, and in the course of an actual or potential sale, reorganization, consolidation, merger, or amalgamation of all or part of BRDB Group’s business or operations; or
  16. for any other purpose that is incidental or ancillary or in furtherance to the above purposes.
  that relates directly or indirectly to a data subject, who is identified or identifiable from that information or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject; but does not include any information that is processed for the purpose of a credit reporting business carried on by a credit reporting agency under the Credit Reporting Agencies Act 2010.
2. To facilitate any of the purposes of Item C(1) above, it is obligatory for you to supply BRDB Group with sufficient personal data as required by BRDB Group. If you fail to supply the personal data as required:-
  1. BRDB Group will not be able to provide you with the necessary notices, services and/or products requested;
  2. BRDB Group will not be able to process your application or registration for any of the necessary services, products, programs and/or activities; and/or
  3. BRDB Group will not be able to process your application or registration for any of the necessary services, products, programs and/or activities; and/or
3. If you do not want BRDB Group to disclose, transfer, use or process otherwise your personal data for any of the purposes listed in Item C(1) above or if you wish to withdraw your consent in full or in part or limit the processing of your personal data, you may contact BRDB Group in writing at the particulars set out in Item G(3) below.
Disclosure
1. BRDB Group may disclose your personal data to the following categories of third party as may be required for any of the above purposes as stipulated in Item C(1) or for other legitimate purposes:-
  1. Companies Commission of Malaysia, Bank Negara Malaysia, Securities Commission of Malaysia, Official Assignee’s Office of the Insolvency Department of Malaysia, any other person, body or government agency under the requirements of any applicable law or order, direction or regulation of any regulatory or appropriate authorities;
  2. any related companies and subsidiaries within BRDB Group;
  3. BRDB Group’s business partners and affiliates;
  4. BRDB Group’s auditors, consultants, accountants, lawyers or other financial or professional advisers including any relevant financial institutions;
  5. BRDB Group’s agents, contractors, sub-contractors, network operations, third party service or product providers;
  6. third party property management companies;
  7. any referee whose details are provided by you;
  8. any financial institutions, lawyers and professional advisers appointed by you;
  9. any other persons under a duty of confidentiality to BRDB Group; and/or
  10. any other entities that BRDB Group may think fit.
Security Policy
1. BRDB Group shall take practical steps to safeguard your personal data against any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction by having regard:-
  1. to the nature of the personal data and the harm that would arise;
  2. to the place or location where the personal data is stored;
  3. to any security measures incorporated into any equipment in which the personal data is stored;
  4. to the measures taken for ensuring the reliability, integrity and competence of personnel having access to the personal data; and
  5. to the measures taken for ensuring the secure transfer of the personal data.
2. BRDB Group shall ensure that any security policy developed or implemented by BRDB Group complies with the security standard required under the Act and any applicable law that may from time to time be in force.
Retention Standard
1. Any personal data supplied by you will be retained by BRDB Group as long as necessary for the fulfilment of any of the purposes stated in Item C(1) above or otherwise permitted by any applicable law that may from time to time be in force.
2. If any personal data is no longer required for the purpose for which it was processed, BRDB Group shall take all reasonable steps to ensure that it is destroyed or permanently deleted.

Right of Access and Correction

Under the Act, you have the right of access to your personal data held by BRDB Group on payment of fee as follows:-

Item	Description	Maximum Fee (RM)
1	Data access request for a data subject’s personal data with a copy	10
2	Data access request for a data subject’s personal data without a copy	2
3	Data access request for a data subject’s sensitive personal data with a copy	3
4	Data access request for a data subject’s sensitive personal data without a copy	5

Personal data supplied by you to BRDB Group must be accurate, complete and not misleading. If you know that your personal data held by BRDB Group is inaccurate, incomplete, misleading or not up-to-date, you may make a data correction request in writing to BRDB Group.

You may send your data access request, data correction request or any inquiries to BRDB Group in writing at the following address:

Attention	:	Company Secretary
Correspondence Address	:	Level 11 Menara BRDB 285 Jalan Maarof Bukit Bandaraya 59000 Kuala Lumpur
Telephone No.	:	03-2688 2888
Facsimile No.	:	03-2284 3988

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