We, SG EDUCATION GROUP, our subsidiaries and associate companies (collectively, “SEG”) respect your right to privacy and we respect all Personal Information you provide to us. We are committed to protecting all Personal Information kept by us. SEG is bound by the Personal Data Protection Act 2010 (“PDP Act”) and all other applicable law in Malaysia in respect of privacy protection which set out a number of principles concerning Personal Information and consumer protection in Malaysia.
“Authorised Third Parties“ means SEG’s contractors, agents or third party suppliers or service providers with whom SEG enters into an agreement. “SEG”, “we”, “us” or “our” means collectively, SG Education Group, a group of companies incorporated in Malaysia and having its registered address at D-0-3A, Putra Majestik, Jalan Kasipillay, Off Jalan Ipoh,Batu 2 ½ , 51200 Kuala lumpur., its subsidiaries and associate companies. “Personal Information” means any personal information relating to any individual that the individual has provided to SEG or made available to SEG;
“Sensitive Personal Information” comprises information as to the individual’s physical or mental health or condition, political opinions, religious beliefs or other beliefs of a similar nature, commission or alleged commission of any offence, or any other Personal Information designated as such; “Services” comprises any communications, information or other products or services provided by SEG.
1. INFORMATION WE COLLECT
1.1 We may obtain your Personal Information from various sources.
1.2 The types of Personal Information we may obtain about you are:
1.2.1 contact information;
1.2.2 business contact information ;
1.2.3 username and password to access our Services;
1.2.4 financial information;
1.2.5 employment information;
1.2.6 medical records;
1.2.7 social media identifier;
1.2.8 other information (such as shopping behaviour and preferences, language preference, age, date of birth, gender and family status)
1.3. We also may obtain your Personal Information from publicly available information systems and reporting agencies in connection with our contract with you.
2. HOW WE USE THE PERSONAL INFORMATION WE COLLECT
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
2.1 to communicate with you;
2.2 to provide Services to you;
2.3 to process you payment transactions;
2.4 to respond to your inquiries;
2.5 to administer your participation in contests;
2.6 to conduct internal activities;
2.7 to conduct market surveys and trend analysis;
2.8 to provide you with information on products and services of SEG;
2.9 for other legitimate business activities of SEG; and
2.10 for such other purposes in relation to your contract with SEG. (collectively, “Purposes”)
3. INFORMATION WE SHARE
3.2 We may need to share your Personal Information with Authorised Third Parties who perform services on our behalf. We do not authorise the Authorised Third Parties to use or disclose the information except as necessary to perform certain services on our behalf or comply with legal requirements. We require the Authorised Third Parties by contract to appropriately safeguard the privacy and security of Personal Information they process on our behalf.
4. PERSONAL INFORMATION PROTECTION PRINCIPLES WE ADHERE
4.1 General Principle:
4.1.1 We will process Personal Information provided to SEG by you when you register or apply for or express an interest in our Services with your specific consent.
4.1.2 We may use your Personal Information for the Purposes.
4.1.3 If you are below the age of 18, you should ensure that you obtain the prior consent of your parents or legal guardian before using SEG’s Services.
4.2 Notice and Choice Principle:
4.2.1 Any individuals who has provided his/her Personal Information prior to this Policy, may contact SEG using the contact details set out below to know what ypes of Personal Information have been processed and the purpose for the processing.
4.2.2 SEG will not process Personal Information without your prior written consent, except for the Purposes and where it is required or permitted under Malaysian law.
4.2.3 You will be given the opportunity to ‘opt-out’ of having your Personal Information used for purposes not directly related to the Services at the point where SEG asks for information. If you do not wish to receive our promotional updates you may opt-out of receiving these communications by clicking to “Unsubscribe” in the subject line in the email sent or by emailing us at email@example.com. But please note that should you decide to “opt-out”, we may not be able to provide you with certain Services and your subscription to or application for certain Services may be declined, denied or refused by SEG.
4.3 Disclosure Principle:
4.3.1 SEG will not sell or rent your Personal Information to third parties. Other than as provided in this Policy, SEG will not disclose your Personal Information to any third party without your consent.
4.3.2 SEG may from time to time, contact you on behalf of external business partners about particular goods, offers or services that may be of interest to you. In those cases, Personal Information that may identify you will not be transferred to the third party. All communication whether from SEG or SEG’s business partners will be sent to you by SEG.
4.3.3 SEG may however, need to work with Authorised Third Parties for the Purposes or to provide part or all of SEG’s Services and/or other services to you or to perform market research and statistical analysis. In such situations, SEG will share your Personal Information as is necessary for the Authorised Third Party to perform these services, on a strictly confidential basis. These parties are not allowed to process your Personal Information disclosed to them except for the limited purpose of providing the particular service for SEG.
4.3.5 It may be necessary to transfer your Personal Information to other entities or service providers located in countries outside Malaysia. This may happen where SEG’s servers or suppliers and service providers are based outside Malaysia or where you use the Services from countries outside Malaysia. In these instances SEG will take steps to ensure that your privacy rights are respected in accordance with this Policy.
4.4 Security Principle:
4.4.1 SEG has implemented security policies, rules and technical measures to protect your Personal Information from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. All our employees and data processors, who have access to and are associated with the processing of Personal Information, are obliged to respect the confidentiality of your Personal Information.
4.4.2 Personal Information that SEG collects from you will be stored and backed up securely in a location which is accessible by SEG’s authorised personnel. 4.4.3 In discharging its responsibilities with respect to the confidentiality of Personal Information, SEG will employ a number of safeguards, appropriate to the sensitivity of the information, to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures and technological measures, for example locked filing cabinets, restricted access to offices, security clearances and limiting access on a “need to know” basis and use of passwords and encryption. Procedures for implementing these measures will be communicated to SEG employees and third parties to ensure compliance with this principle.
4.5 Retention Principle:
SEG will store your Personal Information as long as the purpose it was collected for remains valid and thereafter for a period of seven years or any other period of time required and/or permitted by Malaysian law.
4.6 Data Integrity Principle:
4.6.1 SEG takes all reasonable precautions to ensure that the Personal Information that we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that information depends to a large extent on the information that you provide.
4.6.2 You have the right to access your Personal Information, subject to some exceptions allowed by law. If you would like to do so, please let us know. You may be required to put your request in writing for security reasons. We reserve the right to charge a fee for searching for and providing access to your information.
4.6.3 SEG reserves the right to refuse to provide SEG’s visitors with a copy of their Personal Information by providing a written explanation for such refusal.
4.7 Access Principle:
4.7.1 Any individuals dealing with SEG can have access to his/her Personal Information that SEG has in its possession or control and may request that his/her Personal Information be amended for purposes of accuracy and completeness.
4.7.2 You may at any time remove your personal details from our database, or amend or correct your Personal Information. If you remove your Personal Information from our records, we will no longer be able to provide the Services to you.
5. SENSITIVE PERSONAL INFORMATION
5.1 Where required under Malaysian law, SEG will obtain consent from you before we process your Sensitive Personal Information.
5.2 SEG will process Personal Information or Sensitive Personal Information without your consent only in those limited circumstances as permitted by Malaysian law.
6. SEG’S WEBSITE
6.1 SEG provides products and services via its various websites. When an individual visits SEG’s sites, its web servers generally record anonymous information such as the time, date and URL of the request. This information assists SEG to improve the structure of its websites and monitor their performance. From time to time SEG may also use Authorised Third Parties to analyse this anonymous information.
6.2 As mandatory in the usage of the SEG’s websites SEG may require standard information such as a Login ID, password, Personal Information for verification purposes, contact details and identification numbers. This information is necessary for SEG to provide the services an individual applied for. You are required to maintain the secrecy of his/her Login ID and Password enabling him/her to access the SEG’s website. It is strongly stressed that SEG will not be able to secure the Personal Data if you reveal your Login ID and Password to anyone.
7. IP ADDRESSES AND COOKIES
7.1 SEG also collects Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. SEG collects and manages IP addresses as part of the service of providing internet session management and for security purposes.
7.2 SEG’s websites may transmit to any customer’s computer a “cookie”. A cookie is a package of data that allows SEG’s server to identify and interact more effectively with the customer’s computer having to spend time on identifying each customer user, thereby also providing additional login convenience. You may configure and personalize its current browser to refuse, reject or delete such cookies.
8. INTEREST BASED ADVERTISING
Interest Based Advertising is a way of making advertisements more relevant to the customer based on Personal Information provided by the customer. In order to provide the customer with Interest Based Advertising, SEG may collect information about a customer’s activities and use that information to associate the customer’s with one or more pre-defined interest categories. SEG may periodically provide you advertisements that are tailored to your interests.
9. CONTACTING SEG
You may submit your written request, between 9.00AM and 5.00PM, Monday to Friday,if:
(b) for access to, or correction of, your Personal Information or limit the processing of your Personal Information upon payment of a prescribed fee;
to SEG’s Personal Data Protection Officer by post or email as set out below:
Postal Address: Personal Data Protection Officer
D-0-3A, Putra Majestik,
Off Jalan Ipoh,Batu 2 ½ ,
51200 Kuala lumpur.
Email Address: firstname.lastname@example.org