1. Introduction

1. 1. The Privacy Policy herein applies to the Zeon Properties Sdn Bhd’s information gathering and will be processed in accordance to the Personal Data Protection Act 2010, the applicable regulations, guidelines, orders made under the PDPA and any statutory amendments or re-enactments made of the PDPA from time to time (“the PDPA”).
   2. Any reference to “we”, “our” or “us” in this Privacy Policy shall include any member of the Website Owner and its affiliates (including but not limited to its subsidiaries, related, associated and affiliated companies, whether such companies are residing, situated, carrying on business, incorporated or constituted within or outside Malaysia) (hereinafter referred to as Zeon Properties Sdn Bhd)
   3. The Zeon Properties Sdn Bhd reserves the right, at its sole discretion, to modify, update and/or amend this Privacy Policy from time to time with reasonable prior notice to you. If any, the Zeon Properties Sdn Bhd will notify you of any amendments via announcements on the Zeon Properties Sdn Bhd’s website (“Website”) or other appropriate means as determined by the Zeon Properties Sdn Bhd. Any amendments to this Privacy Policy will be effective upon notice to you. By continuing to use the services and/or access to the Website after being notified of any amendments to this Privacy Policy, you will be deemed to have agreed to and accepted those amendments.
   4. If you do not agree to this Privacy Policy or any amendments to this Privacy Policy, you may be required to stop accessing this website and to terminate the relevant agreement in relation to Zeon Properties Sdn Bhd and Zeon Properties Sdn Bhd may not be able to render all services to you.

2. Collection of Personal Data

2. 1. “Personal Data” includes but not limited to, name, contact details, address, email address, NRIC number or passport number, bank account information, income tax number, banking facility information and/or all such other data relating directly or indirectly to an individual, including but not limited to the Zeon Properties Sdn Bhd’s customers, employees, agents, brokers, contractors, suppliers, subsidiaries, affliates, associates, jointly controlled companies and/or other members within Zeon Properties Sdn Bhd group of companies. Zeon Properties Sdn Bhd may “process” your Personal Data by way of collecting, recording, holding, storing, using or disclosing it.
   2. The relevant Personal Data might be collected during the user’s course of dealings with the Zeon Properties Sdn Bhd in any manner or way including but not limited to any dealings, transactions and/or communications made from/with the Zeon Properties Sdn Bhd. The Personal Data may also be collected from a variety of sources, including but not limited to any events, talks, surveys, road shows by the Zeon Properties Sdn Bhd and/or from the cookies used on the website.
   3. In furterene, the Personal Data may also be received, stored and processed by Zeon Properties Sdn Bhd when provided or made available by any third parties, credit reference bodies, regulatory and law enforcement authorities, for reasons including delivery of the Zeon Properties Sdn Bhd’s products and/or services, performance of conditions of agreements and/or to comply with the Zeon Properties Sdn Bhd’s legal and regulatory obligations.

3. PURPOSE OF ACQUIRING AND PROCESSING THE PERSONAL DATA

• Personal Data that you voluntarily provide to Zeon Properties Sdn Bhd on Zeon Properties Sdn Bhd Websites and the other related channels may be processed for the following purposes (hereinafter collectively referred to as “Purposes”) :-
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  (a) to communicate with you;
• (b) to provide products and/or services to you;
• (c) to respond to your enquiries or complaints;
• (d) to process your purchase and/or contest entry;
• (e) to provide you with information and/or updates on the present and future property developments, other products, services and/or promotions offered by the Zeon Properties Sdn Bhd 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;
• (f) to send you seasonal greetings messages from time to time;
• (g) to send you invitation to join the Zeon Properties Sdn Bhd’s membership, events and promotions and property launch events;
• (h) to monitor, review and improve the Zeon Properties Sdn Bhd’s membership, events and promotions, products and/or services;
• (i) to provide you with post vacant possession services, such as club house services, security and customer loyalty programmes;
• (j) to process and analyse your Personal Data either individually or collectively with other individuals;
• (k) to conduct market research or surveys, client profiling activities, planning and statistical analysis within the Zeon Properties Sdn Bhd in relation to the Zeon Properties Sdn Bhd’s present and future property developments, other products and/or services;
• (l) to share any of your Personal Data with the auditor for the Zeon Properties Sdn Bhd’s internal audit purposes;
• (m) to share any of your Personal Data with a third party for purposes of assisting you pursuant to your financial application, where necessary;
• (n) to share any of your Personal Data pursuant to any agreement or document which you have duly entered with the Zeon Properties Sdn Bhd for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
• (o) 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 Zeon Properties Sdn Bhd;
• (p) to share any of your Personal Data with a third party necessary for the purpose of applying and obtaining insurance policy(ies), where necessary;
• (q) to maintain and improve customer relationship;
• (r) to maintain and update internal record keeping;
• (s) for registration for a user account with the Zeon Properties Sdn Bhd;
• (t) for internal administrative purposes;
• (u) for audit and risk management purposes;
• (v) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
• (w) for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;
• (x) for enabling the Zeon Properties Sdn Bhd to perform its obligations under the agreement or document which you have duly entered into with the Zeon Properties Sdn Bhd 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;
• (y) 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 Zeon Properties Sdn Bhd;
• (z) to enforce or defend the Zeon Properties Sdn Bhd’s rights and your rights under, and to comply with, the Zeon Properties Sdn Bhd obligations under the applicable laws, legislation and regulations;
• (aa) for other purposes required to operate and maintain the Zeon Properties Sdn Bhd’s business;
• (bb) to manage, verify and complete transactions with you;
• (cc) to manage and verify your membership for Zeon Properties Sdn Bhd customer loyalty scheme (where applicable);
• (dd) to understand and analyse Zeon Properties Sdn Bhd sales, and your needs and preferences;
• (ee) to develop, enhance, market and provide products and services to meet your needs;
• (ff) For Zeon Properties Sdn Bhd credit control service and/or collection of debts due and owing to Zeon Properties Sdn Bhd .
• (gg) to enable you to participate in promotions and contests;
• (hh) to process exchanges or product returns;
• (ii) to respond to your requests or complaints; and/or
• (jj) to process your payment transactions
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  (collectively referred to as the “Purposes”), and you agree and consent to the usage and processing of your Personal Data for the Purposes in the manner as identified in this Privacy Policy.

4. CONSEQUENCES OF NOT CONSENTING TO THIS PRIVACY POLICY

• If you do not supply the Zeon Properties Sdn Bhd with your Personal Data and/or that sufficient Personal Data is not supplied and/or is not satisfactory to us and/or you do not consent to the above or this Privacy Policy, then your application or request for any of the above Purposes may not be accepted or acted upon or your request to browse some information on the Websites, or the use of, or subscription to, or purchase of any products and/or services offered by Zeon Properties Sdn Bhd may be denied or affected and/or the Zeon Properties Sdn Bhd will not be able to:
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  (a) to process your purchase of any of the Zeon Properties Sdn Bhd’s products and/or services;
• (b) accept and process your entry to any contest;
• (c) communicate with you;
• (d) provide you with the Zeon Properties Sdn Bhd’s products and/or services requested;
• (e) update you on the Zeon Properties Sdn Bhd’s latest products, services and/or promotions; and/or
• (f) allow you to access certain sections of the Website where log in is required,
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  and you may be required to terminate your agreement or discontinue your business relationship with the Zeon Properties Sdn Bhd.

5. DISCLOSURE OF YOUR PERSONAL DATA

• The Zeon Properties Sdn Bhd will not disclose any of your Personal Data to any third party without your consent except to the following third parties, for one or more of the above Purposes:
• (a) companies within the Zeon Properties Sdn Bhd and their respective employees;
• (b) your immediate family members and/or emergency contact person as may be notified to the Zeon Properties Sdn Bhd from time to time;
• (c) successors in title to the companies within the Zeon Properties Sdn Bhd;
• (d) 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 Zeon Properties Sdn Bhd, merger, consolidation, re-organisation or funding exercise relating to any companies within the Zeon Properties Sdn Bhd, or asset sale, or in the event of winding-up of any companies within the Zeon Properties Sdn Bhd;
• (e) the [ ]’s business partners and affiliates that provide related products and/or services in connection with the Zeon Properties Sdn Bhd’s business for joint promotions and/or contests;
• (f) any person under a duty of confidentiality to which has undertaken to keep your Personal Data confidential which the [ ] has engaged to discharge the Zeon Properties Sdn Bhd’s obligations to you;
• (g) any party in relation to legal proceedings or prospective legal proceedings;
• (h) the Zeon Properties Sdn Bhd 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 Zeon Properties Sdn Bhd;
• (i) any party nominated or appointed by the Zeon Properties Sdn Bhd either solely or jointly with other service providers, for purpose of establishing and maintaining a common database where the Zeon Properties Sdn Bhd has a legitimate common interest;
• (j) data centres and/or servers located within or outside Malaysia for data storage purposes;
• (k) payment channels including but not limited to financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to the Zeon Properties Sdn Bhd in connection with your purchase of the Zeon Properties Sdn Bhd‘s products and/or services;
• (l) 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;
• (m) 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, Perbadanan Bekalan Air Pulau Pinang, Syarikat Telekom Malaysia Berhad and Indah Water Konsortium Sdn. Bhd.;
• (n) the Zeon Properties Sdn Bhd’s contractors or sub-contractors as may be necessary for discharging the Zeon Properties Sdn Bhd’s duties and obligations under any document or agreement duly entered by you with the Zeon Properties Sdn Bhd;
• (o) the Zeon Properties Sdn Bhd’s appointed product and/or service providers, suppliers or agents, to discharge or perform one or more of the above Purposes;
• (p) any persons, authorities or regulators to whom the Zeon Properties Sdn Bhd is permitted or required to disclose to under the applicable laws; and/or
• (q) 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.

6. ACCURACY OF THE PERSONAL DATA

• The aim is to keep all Personal Data as accurate, complete, not misleading, up-to-date and reliable as possible. Therefore, the accuracy of your Zeon Properties Sdn Bhd Personal Data depends to a large extent on the information you provide. As such, it is a condition of the Zeon Properties Sdn Bhd providing the products and/or services to you that you:
• (a) warrant and declare that all your Personal Data submitted or to be submitted to the Zeon Properties Sdn Bhd are accurate, not misleading, updated and complete in all respects for purposes of acquiring or using the relevant products and/or services and you have not withheld any Personal Data which may be material in any respect and that the Zeon Properties Sdn Bhd is authorized to assume the authenticity and updatedness of the Personal Data given by you when processing the Personal Data submitted by you to the Zeon Properties Sdn Bhd (and the Zeon Properties Sdn Bhd is not obliged to independently verify any of such Personal Data); and
• (b) you understand and agree to, the importance of the need to, update the Zeon Properties Sdn Bhd as and when such Personal Data provided earlier to the Zeon Properties Sdn Bhd becomes inaccurate, incomplete, misleading, outdated or changes in any way whatsoever by contacting the Zeon Properties Sdn Bhd at the contact details below.

7. YOUR RIGHTS

7. 1. Subject to the exceptions provided under the PDPA, you have the right of access to your Personal Data held by Zeon Properties Sdn Bhd on payment of a prescribed fee and to request correction of the Personal Data that is inaccurate, incomplete, misleading or not up-to-date. If you have any questions regarding this Privacy Policy or if you wish to request access to your Personal Data or if you wish to correct your Personal Data or if you wish to withdraw your consent for future marketing communication, you may communicate the same to Zeon Properties Sdn Bhd.
   2. In respect of your right to access and/or correct your Personal Data, the Zeon Properties Sdn Bhd has the right to refuse your request to access and/or correct your Personal Data for the reasons permitted under the law, such as where the expense of providing access to you is disproportionate to the risks to your privacy, or where the rights of others may also be violated, amongst other reasons.
   3. You have the right at any time to request the Zeon Properties Sdn Bhd to limit the processing and use of your Personal Data (for example, requesting the Zeon Properties Sdn Bhd to stop sending you any marketing and promotional materials or contacting you for marketing purposes).
   4. In addition, you also have the right to inform the Zeon Properties Sdn Bhd on your withdrawal (in full or in part) of your consent given previously to the Zeon Properties Sdn Bhd subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be effected.

8. RETENTION OF THE PERSONAL DATA

• Your Personal Data shall be stored in the manner as determined by Zeon Properties Sdn Bhd. Any Personal Data supplied by you will be retained by Zeon Properties Sdn Bhd as long as necessary for the fulfilment of the Purposes stated herein or as required to satisfy legal regulatory, accounting requirements or to protect our interests.
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  The Zeon Properties Sdn Bhd’s information technology storage facilities and servers may be located in other jurisdictions outside of Malaysia. Your Personal Data may be transferred to entities outside of Malaysia. This may include, but are not limited to, instances where your Personal Data may be stored on servers located outside of Malaysia. There might be a different level of protection/governance under the law of the foreign entity. You hereby expressly consent to the transferring of your Personal Data outside of Malaysia for such purposes.

9. SECURITY OF THE PERSONAL DATA

9. 1. Zeon Properties Sdn Bhd shall in its endeavours, secure the safety of your Persona Data, to prevent unauthorised access, disclosure or other similar risks, to implement appropriate technical (where practicable) and take precaution and measures in accordance with the relevant laws and regulations to safeguard against and to prevent the unlawful or unauthorised 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.
   2. The Zeon Properties Sdn Bhd will make reasonable updates to its security measures from time to time and ensure the authorised third parties only use your Personal Data for the Purposes set out in this Privacy Policy, and to adequately safeguard your Personal Data.
   3. However no data transmission over the internet can be guaranteed as completely secure and Zeon Properties Sdn Bhd cannot warrant or secure the security of any Personal Data transmitted to Zeon Properties Sdn Bhd and individuals do so at their own risk. Zeon Properties Sdn Bhd will put in place various security procedures with regard to the website and your electronic communications with the Zeon Properties Sdn Bhd.
   4. Please take note 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.
   5. The Zeon Properties Sdn Bhd is not responsible and cannot and does not accept responsibility for any unauthorised access or interception or loss of Personal Data that is beyond the Zeon Properties Sdn Bhd’s reasonable control.

10. PERSONAL DATA FROM MINORS AND OTHER INDIVIDUALS

• To the extent that you have provided (or will provide) Personal Data about your family, spouse and/or other dependents, you represent and warrant that you have obtained their consent to provide their Personal Data to the Zeon Properties Sdn Bhd and they consent to their Personal Data being processed in accordance with this Privacy Policy and, with respect to minors (i.e. individuals under 18 years of age) or any individuals not legally competent to give consent, you consent on their behalf (and you confirm that you have the authority to do so).

11. WEBSITE

• zeon.com.my
• Zeon Properties Sdn Bhd’s Websites may contain links to other websites. Zeon Properties Sdn Bhd are not responsible for the privacy practices or the content of such websites and does not accept any responsibility or liability arising from those websites. It shall be the sole responsibility or the users to read and understand the privacy policy of the other website.

12. CONTACT DETAILS

• If you have any questions about this Privacy Policy or would like to make a complaint or data access or correction request, you may contact the Zeon Properties Sdn Bhd at the contact details below:
• Zeon Properties Group
• Wisma Zeon, 29C-03A-01, Persiaran Karpal Singh 2,
  11600 Jelutong, Penang, Malaysia
• Email: info@zeon.com.my
• Tel: +6012 443 8888