1.3 If you are a corporate entity, references to the term “you” and “your” shall also include your employees, representatives and agents.
1.4 The PDPA requires us to inform you of your rights in respect of your personal data that is being processed or that is to be collected and further processed by us and the purposes for the data processing. The PDPA also requires us to obtain your consent to the processing of your personal data. In light of the PDPA, we are committed to protecting and safeguarding your personal data.
2. COLLECTION OF PERSONAL DATA
2.1 The term “personal data” means any information in our possession or control that relates directly or indirectly to an individual to the extent that the individual can be identified or are identifiable from that and other information in our possession such as name, address, telephone number, NRIC No, date of birth, email address, etc. The types of personal data collected depend on the purpose of collection. We may “process” your personal data by way of collecting, recording, holding, storing, using and/or disclosing it.
2.2 Your personal data may be collected from you during your course of dealings with us in any way or manner including pursuant to any transactions and/or communications made from/with us. We may also collect your personal data from a variety of sources, including without limitation, at any meetings, events, seminars, conferences, talks, road shows, customer satisfaction surveys organised and/or sponsored by us, as well as from publicly available sources.
2.3 In addition, we may also receive, store and process your personal data which are provided or made available by any third parties, credit reference bodies, regulatory and law enforcement authorities, for reasons including delivery of our products and/or services, performance of conditions of agreements and/or to comply with our legal and regulatory obligations.
3. PURPOSE OF ACQUIRING AND PROCESSING YOUR PERSONAL DATA
3.1 The personal data as provided/furnished by you to us or collected by us from you or through such other sources as may be necessary for the fulfilment of the purposes at the time it was sought or collected, may be processed for the following purposes (collectively referred to as the “Purposes”):
- to communicate with you;
- to assess, process and provide products, services and/or facilities to you;
- to facilitate, process, deal with, administer, manage and/or maintain your relationship with us;
- to consider and/or process your application for admission/scholarship/transaction with us;
- to provide academic and educational services to you;
- to verify your qualifications, educational background and/or examination results;
- to provide ancillary services such as visa application and insurance coverage throughout your tenure of studies with us;
- to assist you in placements, internships or attachments with third parties;
- to organise graduations, scholarships, prizes or sponsorships giving ceremonies;
- to operate student bodies such as student associations and alumni;
- to maintain your personal data in our alumni database;
- to manage your use of our facilities such as libraries and computing facilities;
- to enable us to interrogate tests and examination results in order to identify the strengths and weaknesses of students;
- to respond to your enquiries or complaints or resolve any issues and disputes which may arise in connection with any dealings with us;
- to administer and process any payments related to products, services and/or facilities requested by you;
- to facilitate your participation in, and our administration of, any events including meetings, seminars, conferences, talks, road shows, contests, promotions or campaigns;
- to conduct credit reference checks and establish your credit worthiness, where necessary, in providing you with the products, services and/or facilities;
- to carry out due diligence or other monitoring or screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or that may have been put in place by us;
- to administer and give effect to your commercial transactions with us;
- to process any payments related to your commercial transactions with us;
- to provide you with information and/or updates on our products, services, upcoming promotions offered by us and/or events, , conferences, talks and seminars organised by us 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, gifts, newsletters from time to time;
- to send you invitation to join our events and promotions and product launch events as well as conferences, talks and seminars;
- to monitor, review and improve our events and promotions, products and/or services;
- to process and analyse your personal data either individually or collectively with other individuals;
- to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services;
- to share any of your personal data with the auditor for our internal audit and reporting purposes;
- 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 share any of your personal data with a third party necessary for the preparation of legal documents or contract to be entered by you;
- to share any of your personal data with our business partners to jointly develop products and/or services or launch marketing campaigns;
- to share any of your personal data with insurance companies necessary for the purpose of applying and obtaining insurance policy(ies), if necessary;
- to share any of your personal data with financial institutions necessary for the purpose of applying and obtaining credit facility(ies), if necessary;
- to maintain and improve customer relationship;
- to maintain and update internal record keeping, files and contact lists;
- to detect, investigate and prevent any fraudulent, prohibited or illegal activity or omission or misconduct;
- to enable 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 meet 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 us;
- to comply with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies, ministries, statutory bodies or other similar authorities;
- to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
- for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
- for internal administrative purposes;
- for audit, risk management and security purposes;
- for our storage, hosting back-up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Malaysia; and/or
- for other purposes required to operate, maintain and better manage our business and your relationship with us,
3.2 We may also process your sensitive personal data such as religious belief and medical details for reporting purposes to the Ministry of Education and any other relevant authorities.
3.3 We will seek your separate consent for any other purposes which do not fall within the categories stated above.
3.4 We may also be collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes.
5. DISCLOSURE OF YOUR PERSONAL DATA
We will not sell, rent, transfer or disclose any of your personal data to any third party without your consent. However, we may disclose your personal data to the following third parties, for one or more of the above Purposes:
- Bank Negara Malaysia;
- your immediate family members and/or emergency contact person as may be notified to us from time to time;
- successors in title to us;
- your sponsors, scholarships and/or student loan providers, organisations and/or institutions;
- academic institutions, whether affiliated or otherwise;
- our external counterparts providing external, exchange or other similar educational programme;
- third parties providing you with attachment placements or internships;
- your current, past or prospective employers;
- student associations or alumni;
- 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;
- any party in relation to legal proceedings or prospective legal proceedings;
- our auditors, consultants, lawyers, accountants 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;
- data centres and/or servers located within or outside Malaysia for data storage purposes;
- storage facility and records management service providers;
- 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 products and/or services;
- the Ministry of Education, Immigration Department, Malaysian Qualifications Agency, other government agencies, law enforcement agencies, courts, tribunals, regulatory/professional 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;
- foreign government departments, embassies, government agencies or authorities if you are enrolled in a foreign accredited programme;
- our business partners, third party product and/or service providers, suppliers, vendors, distributors, contractors or agents, on a need to know basis, that provide related products and/or services in connection with our business, or discharge or perform one or more of the above Purposes and other purposes required to operate and maintain our business;
- insurance companies for the purpose of applying and obtaining insurance policy(ies), if necessary;
- 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, participate in our events, conferences, talks and seminars by publishing your name, photographs and other personal data without compensation for advertising and publicity purposes;
- any third party (and its advisers/representatives) in connection with any proposed or actual reorganization, merger, sale, consolidation, acquisition, joint venture, assignment, transfer, funding exercise or asset sale relating to any portion of INCEIF; and/or
- any other person reasonably requiring the same in order for us to operate and maintain our business or carry out the activities set out in the Purposes or as instructed by you.
6. ACCURACY OF YOUR PERSONAL DATA
We take it that all personal data provided by you is accurate and complete, and that none of it is misleading or out of date. You will promptly update us in the event of any change to your personal data.
7. YOUR RIGHTS
7.1 To the extent that the applicable law allows, you have the right to request for access to, request for a copy of, 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. Notwithstanding the foregoing, we reserve our rights to rely on any statutory exemptions and/or exceptions to collect, use and disclose your personal data.
7.2 You have the right at any time to request us to limit the processing and use of your personal data (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes).
7.3 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 effected. 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 or the contract that you have with us will have to be terminated.
8. RETENTION OF YOUR PERSONAL DATA
Any of your personal data provided to us is retained for as long as the purposes for which the personal data was collected continues; your personal data is then destroyed or anonymised from our records and system in accordance with our retention policy in the event your personal data is no longer required for the said purposes unless its further retention is required to satisfy a longer retention period to meet our operational, legal, regulatory, tax or accounting requirements.
9. SECURITY OF YOUR PERSONAL DATA
9.1 We are committed to ensuring that your personal data is stored securely. In order to prevent unauthorised access, disclosure or other similar risks, we endeavour, where practicable, to implement appropriate technical, physical, electronic and procedural security measures in accordance with the applicable laws and regulations and industry standard to safeguard against and prevent the unauthorised or unlawful processing of your personal data, and the destruction of, or accidental loss, damage to, alteration of, unauthorised disclosure of or access to your personal data.
9.3 The Internet is not a secure medium. However, we will put in place various security procedures with regard to the Site and your electronic communications with us. All our employees and data processors, who have access to, and are associated with the processing of your personal data, are obliged to respect the confidentiality of your personal data.
9.4 Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may be routed through a number of countries before being delivered ? this is the nature of the World Wide Web/Internet.
9.5 We cannot and do not accept responsibility for any unauthorised access or interception or loss of personal data that is beyond our reasonable control.
10. PERSONAL DATA FROM MINORS AND OTHER INDIVIDUALS
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
(c) We recommend you to 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 Site. Cookies may be used to save your preferences for your ease and convenience when using the Site. Third party advertising networks may issue their separate cookies to your hard drive when serving advertisements.
(b) The type of anonymous click stream data collected by us through the cookies may include your Internet Protocol address, web browser software, date and time of visit to the Site, and whether your requests (including search requests and clicking on links to parts of the Site) were met with successfully. All such information collected through cookies are 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, analysing the traffic on the Site and to identify areas for improvement on the Site.
13. CONTACT DETAILS
Personal Data Protection Officer
Address: INCEIF, Lorong Universiti A, 59100 Kuala Lumpur
Contact No.: +6 (03) 7651 4000
Fax No.: +6 (03) 7651 4094
Email Address: firstname.lastname@example.org
Last updated: 19 November 2014