CapitaLand's Personal Data Protection Policy
Personal Data Protection Notice
The Personal Data Protection Act 2010 (hereinafter referred to as the “PDPA”) which regulates the processing of personal data in commercial transactions applies to AmTrustee Berhad as trustee of CapitaLand Malaysia Mall Trust (hereinafter referred to as “CMA”, “our”, “us” or “we”). For the purpose of this written notice, the terms “personal data” and “processing” shall have the meaning prescribed in the PDPA. In addition, “CMA Group” shall refer to CMA’s related entities*.
1. This written notice serves to inform you that your personal data is being processed by or on behalf of CMA.
2. The personal data processed by us include the details as requested by us in the relevant activities organized by CMA or as previously provided to us via the various forms, oral communications and written communications.
3. As part of the relevant activities organized by CMA, it is a continuing condition of your participation that you agree to our collecting, using, disclosing and processing your personal data for purposes reasonably required for the operation of the relevant activities organized by CMA and the terms and conditions relating thereto. In particular but without limiting the generality of the foregoing, you agree to our collecting, using, disclosing and processing your personal data for the following purposes:
(a) establishing, maintaining, processing and administering your participation in the relevant activities organized by CMA;
(b) responding to your queries, requests and feedback;
(c) sending you information, updates, advertisements, promotions (including discounts and special offers) and other communications in connection with (i) products, services, offers and promotions relating to products, services, offers and promotions offered any CMA, by CMA Group and/or our marketing partners, and (ii) programmes, events or activities, including programmes or activities relating to CMA, CMA Group and/or our marketing partners unless you have otherwise indicated that you do not wish for us to process your personal data for such purposes;
(d) administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;
(e) conducting surveys so that we may provide you with better services and product offerings which may be of greater relevance to you;
(f) conducting market research for statistical, profiling and statistical analysis based on your purchases and preferences, to help us and/or our marketing partners improve or enhance product and service offerings, and/or identify products and services which may be of interest to you, as well as matching your personal data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services to you, whether by us, CMA Group, or other third parties;
(g) sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services which may be of interest to you unless you have otherwise indicated that you do not wish for us to process your personal data for such purposes;
(h) complying with regulatory requirements, preventing, detecting and investigating crime and analyzing and managing other commercial risks;
(i) protecting and enforcing our contractual and legal rights and obligations;
(j) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and
(k) processing your personal data for purposes which are reasonably related to any of the purposes stated above, including disclosure to and processing by any third party outsourced service providers and/or our marketing partners.
4. If you have provided your contact information and have indicated to us that you consent to receiving marketing or promotional information or other advertising via your contact information (collectively, the “Marcom Activities”), then from time to time, CMA Group, its agents, business partners may contact you using all of your contact information which we may have in our records from time to time (including via voice calls, SMS, fax or other means) in connection with any of the Marcom Activities.
5. Subject to requirements under applicable law, other than to the CMA Group, governmental and/or quasi-governmental departments and/or agencies, regulatory and/or statutory bodies, business partners, our authorized third-party service providers and/or agents who provide services to or in connection with the relevant activities organized by CMA or any of the purposes for which you have previously and subsequently provided your consent, we will not disclose personally identifiable information about you to any third parties. However, you agree that we may share aggregated, non-personally-identifiable information with third parties, such as advertisers or our marketing partners for use in marketing, promotional or other activities as we may determine from time to time.
(a) store your preferences;
(b) record session information, such as items that you have added to your shopping cart;
(c) record user-specific information on what pages you access or visit;
(d) alert you to new areas that we think might be of interest to you when you return to our site; and
(e) record past activity at a site in order to provide better service when you return to our site.
7. If you wish to withdraw your consent to any use of your personal data, or if you have any questions, complaints relating to your personal information, or you would like to obtain access, update and make corrections to your personal information records, please contact us at the numbers below
Designation of Contact Person Data Protection Officer
E-mail address CMAMYDPO@capitaland.com
Phone number 03-2279 9888
Fax number 03-2279 9889
8. It is obligatory that you supply us with the personal data required. If you fail to supply us with the personal data, we may not be able to process your personal data for any of the above purposes.
9. Your personal data may be transferred to a place outside Malaysia including CMA Group.
10. In the event CMA undergoes any corporate restructuring exercise (including without limitation any sale of business, disposal, acquisition, merger or reorganisation involving CMA or the assets of CMA to another party), your personal data may be required to be disclosed and/or transferred to the other party as part of such corporate restructuring exercise. You hereby acknowledge that such disclosure and/or transfer may occur and hereby permit CMA to release your personal data to the other party, its advisers and representatives.
11. You are responsible for ensuring that the personal data you provide us is accurate, complete and not misleading and that such personal data is kept up to date.
12. We may request your assistance to procure the consent of third parties whose personal data is provided by you to us and you agree to use your best endeavors to do so. You shall indemnify us in the event we suffer any loss or damage as a result of your failure to comply with the same.
13. In the event of any inconsistency between the English version and the Bahasa Malaysia version of this notice, the English version shall prevail over the Bahasa Malaysia version.
*CMA’s related entities means –
a) any related corporation of AmTrustee Berhad as trustee of CapitaLand Malaysia Mall Trust or
b) any entity including any individual, corporation and/or a trust (in each case, whether or not having a separate legal personality) whose assets, business and/or operations are sponsored and also managed by CMA’s group of companies (in each case, whether or not the same is being sponsored and also managed on its own or jointly with any third party), as the case may be.