Privacy Policy

Effective Date: September 17, 2020

1. INTRODUCTION

1.1 Persatuan Usahawan Maju Malaysia (‘PUMM’) takes its responsibilities under the privacy laws and regulations of Malaysia (“Privacy Laws”) seriously and is committed to respecting the privacy rights and concerns of all Members of the Association. We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose, and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. Please read this Privacy Policy carefully.

1.2 “Personal Data” or “personal data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include name, identification number, and contact information.

1.3 By registering as a member, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing, and/or processing your personal data as described herein. PLEASE INFORM US IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on our website. We reserve the right to amend this Privacy Policy at any time without reference to you.

2. COLLECTION OF PERSONAL DATA

2.1 Collection of personal data will/may occur when:

1. When you register your membership with us.
2. When you submit any form, including, but not limited to, application forms or other forms relating to any of our activities, whether online or by way of a physical form.
3. When you attend our events and functions and access our forms, use our services, or interact with us via our application or use services provided by us. This includes, without limitation, through cookies which we may deploy when you interact with our application or website.
4. When you interact with us, such as via telephone calls (which may be recorded), messages, letters, fax, face-to-face meetings, mobile applications, social media platforms, and emails.
5. When you enter into any agreement or provide other documentation or information in respect of your interactions with us or when you use our products and services.
6. When you carry out transactions through our Services.
7. When you provide us with feedback or complaints.
   •  when you submit your personal data to us for any reason.

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

2.2 We may collect certain information by automated or passive means using a variety of technologies, which technologies may be downloaded to your device and may set or modify settings on your device. We may collect, use, disclose, and/or process this information only for the Purposes (defined below).

3. TYPES OF DATA COLLECTED

3.1 We may collect various personal data from you in order to serve you better. This includes but is not limited to the following:

• Name
• Email address
• Date of birth
• Business information, industry, and job scope
• Professional qualifications and affiliations
• Bank account and payment information
• Telephone number
• Gender
• Any other information about you when you sign up as a member, as well as information related to how you relate to PUMM
• Professional advices given
• Aggregate data on the activities you engage with.

 

3.2 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing about it. However, opting out of us collecting your personal data or withdrawing your consent may in some way affect your communication with PUMM.

4. MEMBER SUPPORT

4.1 We provide member support through email, calls, and feedback forms. In order to provide customer support, we will ask for your email address and mobile phone number. We only use information received from member support requests for member services and we do not transfer to or share information about such requests with any third parties.

5. SURVEYS

From time to time, we may request information via surveys. Participation in these surveys is completely voluntary, and you, therefore, have a choice whether or not to disclose your information to us. Information requested may include, without limitation, contact information (such as your email address), and demographic information (such as interests or age level). Survey information will be used for the purposes of monitoring or improving the association and will not be transferred to third parties, other than our contractors who help us to administer or act upon the survey and any third parties requiring our support through such information given.

6. USE OF INFORMATION

6.1 We may collect, use, disclose, and/or process your personal data for one or more of the following purposes:

(a) to consider and/or process your application/transaction with us or your transactions or communications with third parties; (b) to manage, operate, provide and/or administer PUMM, as well as your relationship and user account with us; (c) to respond to, process, deal with or complete a transaction and/or to fulfill your requests for certain information and notify you of issues and meeting notices; (d) to protect personal safety and the rights, property or safety of others; (e) for identification and/or verification; (f) to contact you or communicate with you for the purposes of administering and/or managing your relationship with us; (g) to conduct research, analysis, and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling); (h) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on us or on its related corporations or affiliates; (i) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements; (j) to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us; (k) to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction; (l) any other purposes which we notify you of at the time of obtaining your consent.

(collectively, the “Purposes”).

6.2 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.

7. HOW IS INFORMATION PROTECTED?

A variety of security measures are implemented to ensure the security of your personal data on our systems. Your personal data is contained behind secured networks and is only accessible by a limited number of Committee Members who have special access rights to such systems. We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any legal or business purposes. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

8. DISCLOSURE OF DATA

8.1 We will/may need to disclose your personal data to our third party service providers, agents, sponsors, and/or our affiliates or related corporations, and/or other third parties for one or more of the above-stated Purposes. Such third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third parties include, without limitation:

(a) our sponsors, affiliates, and related corporations and associations; (b) contractors, agents, service providers, and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies, and data centers; and (c) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

8.2 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organization such as us to collect, use, or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.

8.3 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site; technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however, there can inevitably be no guarantee of absolute security such as but not limited to when unauthorized disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.

9. DISCLAIMER REGARDING SECURITY AND THIRD-PARTY SITES

9.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE TO THIRD PARTIES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured methodologies and networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.

10. TRANSFER OF INFORMATION OVERSEAS

Your personal data and/or information may be transferred to, stored, or processed outside of your country.

11. CONTACT US

11.1 If you have any questions or concerns about our privacy practices or your dealings with the Services, or any complaint or grievance regarding how we are handling your personal data or about how we are complying with Privacy Laws, we welcome you to contact us through Personal Data Protection Officer at PUMM Penang Secretariat, 019-558 2005.

11.2 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a Privacy Law complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organization to handle. For example, you could insert the subject header as “Privacy Complaint.”

12. CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.