1. INTRODUCTION

Redplanet Solutions (M) Sdn Bhd (1117638-T) and its group of companies (“RP Group”) respect your right to privacy and we respect all personal data you provide to us. We are committed to protecting the personal data supplied by you to us.  RP Group is bound by the Personal Data Protection Act 2010 (“PDP Act”) and all other applicable laws in Malaysia in respect of privacy protection which sets out a number of principles concerning personal data and consumer protection in Malaysia.

For the purpose of this Privacy and Personal Data Protection Policy, “personal data” shall have the meaning as ascribed to it in the PDP Act which means any information in respect of commercial transactions, which:-

(a)        is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose;

(b)       is recorded with the intention that it should wholly or partly be processed by means of such equipment; or

(c)        is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system,

that relates directly or indirectly to a data subject, who is identified or identifiable from that information or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject; but does not include any information that is processed for the purpose of a credit reporting business carried on by a credit reporting agency under the Credit Reporting Agencies Act 2010.

This Privacy and Personal Data Protection Policy is issued in both English Language and Bahasa Malaysia. In the event of any inconsistencies between the English version and the Bahasa Malaysia version, the English version shall prevail.

2. TYPES OF PERSONAL DATA COLLECTED

During the course of your transaction and dealings with RP Group, you may be requested to furnish from time to time to RP Group, directly or through online forms and/or other electronic methods, your personal data, which may include your name, gender, age, marital status, date of birth, race, nationality, identity card number, passport number, visa information, correspondence address, email address, telephone contact number, occupation, income range, credit card or bank account information and/or other information relevant to the purposes listed in Paragraph 3 (a) below.

The types of personal data collected will be depending on the nature of your dealings or transaction with RP Group.

3. PURPOSE OF COLLECTION

(a)        RP Group may collect, retain, use and otherwise process your personal data for the following purposes:-

• providing you with services under any business of RP Group; or
• processing your application or registration under any program and/or activities organized or conducted by RP Group; or
• processing your application by RP Group in connection with your employment application; or
• notifying you of services or products whether present or future, updates and promotions including delivery of notices and sending any advertising and/or marketing material, to you (including notices through social medias); or
• entering into any transactions, agreements or instruments in the ordinary course of business of RP Group; or
• discharging RP Group’s contractual obligations in the ordinary course of business of RP Group; or
• collection of any payments due and payable to RP Group including late interest charges; or
• credit assessments and other background verification that may be necessary or appropriate for RP Group ‘s business or employment purposes; or
• human resource management; or
• sending you services, products or promotional information related to other third parties which RP Group thinks you may be interested; or
• discharging RP Group’s duties and obligations under the Companies Act 2016 (as amended from time to time) and any other applicable law, regulation, direction and guideline applicable to RP Group;
• for other legitimate business activities of RP Group; or
• in anticipation of, and in the course of an actual or potential sale, reorganization, consolidation, merger, or amalgamation of all or part of RP Group’s business or operations; or
• for any other purpose that is incidental or ancillary or in furtherance to the above purposes.

(b)       To facilitate any of the purposes of Paragraph 3 (a) above, it is obligatory for you to supply RP Group with sufficient personal data as required by RP Group. If you fail to supply the personal data as required:-

• RP Group will not be able to provide you with the necessary notices, services and/or products requested;
• RP Group will not be able to process your application or registration for any of the necessary services, products, programs and/or activities; and/or
• RP Group will not be able to enter into the necessary transaction or dealing with you or in your favour.

(c)        If you do not want RP Group to disclose, transfer, use or process otherwise your personal data for any of the purposes listed in Paragraph 3(a) above or if you wish to withdraw your consent in full or in part or limit the processing of your personal data, you may contact RP Group in writing at the particulars set out in Paragraph 7(c) below.

4. DISCLOSURE

RP Group may disclose your personal data to the following categories of third party as may be required for any of the above purposes as stipulated in Paragraph 3(a) or for other legitimate purposes:-

(a)        Companies Commission of Malaysia and any other person, body or government agency under the requirements of any applicable law or order, direction or regulation of any regulatory or appropriate authorities;

(b)       any related companies and subsidiaries within RP Group ;

(c)        RP Group’s business partners and affiliates;

(d)       RP Group’s auditors, consultants, accountants, lawyers or other financial or professional advisers including any relevant financial institutions;

(e)        RP Group’s agents, contractors, sub-contractors, network operations, third party service or product providers;

(f)        third party property management companies;

(g)       any other persons under a duty of confidentiality to RP Group; and/or

(h)       any other entities that RP Group may think fit.

5. SECURITY POLICY

RP Group shall take practical steps to safeguard your personal data against any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction by having regard:

• to the nature of the personal data and the harm that would arise;
• to the place or location where the personal data is stored;
• to any security measures incorporated into any equipment in which the personal data is stored;
• to the measures taken for ensuring the reliability, integrity and competence of personnel having access to the personal data; and
• to the measures taken for ensuring the secure transfer of the personal data.

RP Group shall ensure that any security policy developed or implemented by RP Group complies with the security standard required under the PDP Act and any applicable law that may from time to time be in force.

It may be necessary to transfer your personal data to other entities or service providers located in countries outside Malaysia. This may happen where RP Group’s servers or suppliers and service providers are based outside Malaysia or where you use the services from countries outside Malaysia. In these instances RP Group will take steps to ensure that your privacy rights are respected in accordance with this Privacy and Personal Data Protection Policy.

6. DURATION OF RETENTION

RP Group will retain any personal data supplied by you as long as the purpose it was collected for remains valid or otherwise permitted by any applicable law that may from time to time be in force

If any personal data is no longer required for the purpose for which it was processed, RP Group shall take all reasonable steps to ensure that it is destroyed or permanently deleted.

7. RIGHT OF ACCESS AND CORRECTION

Under the PDP Act, you have the right of access to your personal data held by RP Group upon payment of a prescribed fee as per the Personal Data Protection (Fees) Regulation 2013.

If you know that your personal data held by RP Group is inaccurate, incomplete, misleading or not up-to-date, you may make a data correction request in writing to RP Group. You may submit your written request or any inquiries in writing to RP Group at the following address:

BY PROVIDING YOUR PERSONAL DATA TO RP GROUP, YOU HEREBY AGREE THAT RP GROUP SHALL PROCESS YOUR PERSONAL DATA IN ACCORDANCE WITH ALL OF THE FOREGOING