Privacy Notice pursuant to Personal Data Protection Act 2010 (“PDPA”)
This privacy notice (“Notice”) is issued to all existing and/or prospective customers, suppliers, vendors, contractors and service providers of each company in the Beverly Group pursuant to PDPA which came into effect on 15th November 2013.
For the purposes of this Notice,
“Affiliates” means any firm, company, corporation or other organisation which is directly or indirectly controlled by any company in the Beverly Group and where the term “control” when used with respect to any organisation means the possession, directly or indirectly, of power to direct or cause the direction of the management and policies of such organisation, whether through the ownership of shares or by contract or otherwise.
“Beverly Group” means the holding company, subsidiaries, associated, related and affiliated companies of Beverly Group Sdn Bhd as well as their subsidiaries, associated and affiliated companies (both local and international), whether present or future.
“Personal Data” means all information in respect of commercial transactions that relates directly or indirectly about an individual who is identified or identifiable from that information alone, or from that information and any other information which the Beverly Group may have including any sensitive personal data and expression of opinions about individuals.
“Processing” means collecting, recording, holding or storing data, organizing, adapting or altering data, using, referring to, retrieving or consulting data, disclosing or transferring data or otherwise making the data available to third parties, aligning, combining, correcting, erasing, destructing or destroying data.
“Google” means a trademark of GOOGLE INC, computer services, namely, providing software interfaces available over a network in order to create a personalized on-line information service; extraction and retrieval of information and data mining by means of global computer networks; creating indexes of information, indexes of web sites and indexes of other information sources in connection with global computer networks; providing information from searchable indexes and databases of information, including text, electronic documents, databases, graphics and audio visual information, by means of global computer information networks
The expressions “we”, “us” or “our” used herein refers to each or any one company in the Beverly Group.
Collection of your Personal Data
In the course of your dealings with us, we may request and collect your Personal Data which includes but is not limited to the following:-
- name and/or company name;
- nationality and identification number and/or passport number;
- profession, company name, job title, and income;
- marital status and family members’ details;
- personal interests or preferences such as language, product or content interests, communicating and marketing preferences;
- contact details such as contact number, email address, postal address;
- date of birth, age and gender;
- information related to any property you may have purchased from us or any company in the Beverly Group or have registered your interest with us or any company in the Beverly Group for updates and enquiries;
- your photographs or images captured by way of video surveillance installed in our premises;
- bank accounts details, account details, income tax file reference no., income range, types of loan applied for in relation to the purchaser of products, introducer’s name;
- information of your agents and loan details;
- username, password and other identifiers when you register at our website; and
- any other information of which you may be identifiable from or which may identify you that we deem necessary from time to time in connection with the commercial relationship between you and us.
- End user location, search history, YouTube history, and data from sites that partner with Google
- Google Ads Personalization Setting
- City
- Latitude (of city)
- Longitude (of city)
- Browser minor version
- Browser User-Agent string
- Device brand
- Device model
- Device name
- Operating system minor version
- Platform minor version
- Screen resolution
Sources of your Personal Data
We collect your Personal Data from yourself and a variety of legitimate sources, including but not limited to:-
- information provided by you, inter alia, registration forms, sales forms, website;
- third parties such as third party service providers, business partners, credit references agencies and publicly available sources of information;
- your provision of Personal Data at events sponsored or organized by us or any company in the Beverly Group;
- your participation in our questionnaires and surveys;
- your provision of business cards or Personal Data that are given to the employees, clients or business associates of any company in the Beverly Group;
- your voluntary distribution of materials about your personal information;
- agreements and contracts for sale and purchase of properties of any company in the Beverly Group or for the services to be provided by any company in the Beverly Group;
- your provision of Personal Data to purchase or with the prospect to purchase the properties of any company in the Beverly Group;
- the lawyers, consultants, auditors, accountants, bankers and/or any other parties with whom you or we are dealing with; and
- such other written and/or verbal communications between you and us or any of the company in the Beverly Group and/or the authorized agents of any company in the Beverly Group.
- Google signals data collection from your Google Activity
- Google Ads Personalization Setting
- Granular location and device data collection
Purpose of Collecting your Personal Information
The Personal Data will be collected, processed and used by us for the following purposes (collectively known as “Purpose”):-
- to communicate with you;
- to provide products and/or services to you;
- to respond to your enquiries or complaints;
- to process your purchase and/or contest entry;
- to provide you with information and/or updates on the present and future property developments, other products, services and/or promotions offered by the Beverly Group and selected third parties which may be of interest to you from time to time by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
- to send you seasonal greetings messages from time to time;
- to send you invitation to join the Beverly Group’s membership, events and promotions and property launch events;
- to monitor, review and improve the Beverly Group’s membership, events and promotions, products and/or services;
- to provide you with post vacant possession services, such as club house services, security and customer loyalty programmes;
- to process and analyse your Personal Data either individually or collectively with other individuals;
- to conduct market research or surveys, client profiling activities, planning and statistical analysis within the Beverly Group in relation to the Beverly Group’s present and future property developments, other products and/or services;
- to share any of your Personal Data with the auditor for the Beverly Group’s internal audit purposes;
- to share any of your Personal Data with a third party for purposes of assisting you pursuant to your financial application, where necessary;
- to share any of your Personal Data pursuant to any agreement or document which you have duly entered with the Beverly Group for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
- to share any of your Personal Data with a third party necessary for the preparation of legal documents or contract to be entered by you with the Beverly Group;
- to share any of your Personal Data with a third party necessary for the purpose of applying and obtaining insurance policy(ies), where necessary;
- to maintain and improve customer relationship;
- to maintain and update internal record keeping;
- for registration for a user account with the Beverly Group;
- for internal administrative purposes;
- for audit and risk management purposes;
- for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
- for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
- for enabling the Beverly Group to perform its obligations under the agreement or document which you have duly entered into with the Beverly Group including but not limited to attending to the registration with the relevant authorities on your behalf, delivery of vacant possession, defect rectification works and perfecting the transfer of the separate individual/strata title in your favour;
- for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to the Beverly Group;
- to enforce or defend the Beverly Group’s rights and your rights under, and to comply with, the Beverly Group obligations under the applicable laws, legislation and regulations; and/or
- for other purposes required to operate and maintain the Beverly Group’s business,
and you agree and consent to us, using and processing your Personal Data in the manner as identified in this Notice.
Disclosure to Third Parties
We may disclose your Personal Data to the following third parties including:-
- companies within the Beverly Group and their respective employees;
- your immediate family members and/or emergency contact person as may be notified to the Beverly Group from time to time;
- successors in title to the companies within the Beverly Group;
- any party who is involved in connection with corporate exercises, such as a potential or actual sale/disposal of any business or interest of any companies within the Beverly Group, merger, consolidation, re-organisation or funding exercise relating to any companies within the Beverly Group, or asset sale, or in the event of winding-up of any companies within the Beverly Group;
- the Beverly Group’s business partners and Affiliates that provide related products and/or services in connection with the Beverly Group’s business for joint promotions and/or contests;
- any person under a duty of confidentiality to which has undertaken to keep your Personal Data confidential which the Beverly Group has engaged to discharge the Beverly Group’s obligations to you;
- any party in relation to legal proceedings or prospective legal proceedings;
- the Beverly Group auditors, consultants, lawyers or other financial or professional advisers on a need to know basis for the purpose of those advisers providing advice to the Beverly Group;
- any party nominated or appointed by the Beverly Group either solely or jointly with other service providers, for purpose of establishing and maintaining a common database where the Beverly Group has a legitimate common interest;
- data centres and/or servers located within or outside Malaysia for data storage purposes;
- payment channels including but not limited to financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to the Beverly Group in connection with your purchase of the Beverly Group’s products and/or services;
- government agencies, law enforcement agencies, courts, tribunals, regulatory bodies, 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;
- any provider of public utility or related services, whether or not governmental owned and/or any corporations approved and established for the provision of utility services and facilities, includes without limitation to Tenaga Nasional Berhad, Syarikat Bekalan Air Selangor Berhad, Syarikat Telekom Malaysia Berhad and Indah Water Konsortium Sdn. Bhd.;
- the Beverly Group’s contractors or sub-contractors as may be necessary for discharging the Beverly Group’s duties and obligations under any document or agreement duly entered by you with the Beverly Group;
- the Beverly Group’s appointed product and/or service providers, suppliers or agents, to discharge or perform one or more of the above Purposes;
- any persons, authorities or regulators to whom the Beverly Group is permitted or required to disclose to under the applicable laws; and/or
- 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.
Consequences of Refusal / Failure to Provide Personal Data
The supply of your Personal Data to us is voluntary. However, in the event you choose not to provide your consent or subsequently withdraw your consent to the processing of the Personal Data by us, we will be unable to fulfill our obligations to you in relation to the Purpose.
Please also take note that your failure to provide us your Personal Data may result in the following:-
- our inability to communicate with you or provide the services you require;
- our or your inability to comply with any legal or statutory requirements;
- our inability to provide you with updates about our latest launches and/or products;
- our inability to enter into any contract and/or Sale and Purchase Agreement; and
- our inability to formalize any tender/ letter of awards with regards to the sale of our property, products and/or services.
Your rights of access to, correction, and limiting the processing of your personal data
You may at any time hereafter request to access to your Personal Data and have a copy of it by submitting such request in writing.
If you are of the view that your Personal Data is inaccurate, misleading, incomplete or out-of-date, you may also make a request in writing for correction.
If you do not wish to receive notifications and marketing materials from us or would like us to cease processing your Personal Data in a specified manner, you are entitled to submit a written request for such restriction of the processing of your Personal Data.
We will take reasonable endeavours to comply with your request. We may, however, refuse to comply with the requests under circumstances as permitted by law.
Any abovementioned requests, enquiries or complaints with respect to your Personal Data may be submitted to us in writing, to the following address :-
Name of Company: Beverly Group Sdn Bhd
Designation: Personal Data Protection Officer
Contact No.: 03 4816 1616
Fax No.: 03 4816 1617
Email: [email protected]
Please include the following details in any of your written request which may be used to identify you:-
- name;
- identification number; and
- contact number;
Security of Personal Data
We take reasonable steps to ensure that your Personal Data is protected from damage, unauthorized access, accidental loss and misuse. We also require all our data processors to take reasonable security measures in the processing of your Personal Data.
Data Integrity
You are advised to initiate review of your Personal Data. Upon receipt of your written requests for correction of your Personal Data, we will take reasonable steps to rectify the Personal Data which is inaccurate, incomplete and not up-to-date unless we consider there are justifications for refusing to comply with your requests.
Changes to the Personal Data Protection Notice
We reserve the right to modify, update or amend the terms of this Notice at any time by placing the updated Notice on our website or sales platform. By continuing to deal with us or by engaging us following the modifications, updates or amendments to this Notice, it is deemed that you have accepted such modifications, updates or amendments unless you have expressly stated otherwise in writing to us.
Language
This Notice is issued in both the English and Malay languages. In the event of any inconsistency between these two versions, the English version shall prevail.