Glenvex Privacy Policy

Glenvex (“we,” “our,” or “us”) is committed to safeguarding your personal data, and will handle your personal data in accordance with this Privacy Policy and in compliance with Malaysia’s Personal Data Protection Act 2010 (“PDPA”) and other applicable laws. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you engage with us, including through our services, website, and other interactions. Please read this Privacy Policy carefully to familiarize yourself with the categories of personal data that are subject to collection and processing, how we use this personal data, and with whom we are likely to share it. This policy also describes your rights and how you can get in touch with us to exercise these rights or to ask us any questions you might have concerning the protection of your personal data. This policy may be amended, supplemented, or updated, in particular to comply with any legal, regulatory or technical developments that may arise. However, your personal data will always be processed in accordance with the policy in force at the time of the data collection, unless a compulsory legal requirement otherwise applies and is enforced retroactively. 1. What Constitutes Personal Data? Personal data refers to any information that identifies or can identify an individual, such as your name, contact details, and identification numbers, or such other details as permitted under the PDPA. 2. What Data We Collect and Why We collect personal data concerning our employees, potential employees (i.e. job candidates, job applicants), employees, customers and prospective customers, suppliers, customers’ and suppliers’ representatives, other stakeholders and users of our websites. We may collect your personal data in the following ways below: • Directly from you, such as when you complete forms on our sites or when we provide services directly to you; • Indirectly during your navigation of the site or via our service providers and/or technologies; • On a mandatory basis where this is required by applicable local laws or where this is necessary for the performance of the services. Examples of data we collect include: • Contact information (e.g., name, phone number, email address); • Transactional data (e.g., payment information, service usage); • Technical data (e.g., IP addresses, browser types); • Recruitment data (e.g., curriculum vitae, diplomas, information provided with your application); • Other data determined at time of collection and described in specific privacy policy. We collect, process, disclose and/or otherwise use your data for certain purposes detailed below (by no means exhaustive): • Provide services, provide you with access to the site, respond to inquiries and manage accounts; • Improve user/ customer experiences and improve website functionality, monitoring use of systems and websites; • Communication, including on updates and promotional offers (subject to consent); • Procurement of services and products; • For recruitment, administration, talent management, carrying out necessary background and/or reference checks; • Ensuring the safety of goods and people on our premises; • Ensuring regulatory compliance or where necessary to comply with legal obligations; • Any other purpose that may be specified at time of collection and described in specific privacy policy. If we are unable to collect certain personal data items, please note that this may limit our ability to assist you or fulfil your requests and we will not be able to manage your access to the site or to provide you our services. 3. How We Collect Your Data We collect personal data directly from you through interactions such as inquiries, service requests, and website usage. In some instances, data may be obtained from third parties with your consent. If we receive unsolicited data unrelated to our business purposes, we will delete or anonymize it unless required by law to retain it. 4. Use of Cookies Our website uses cookies to improve functionality and user experience. These small files track usage patterns and preferences but do not directly identify you. You can manage cookie preferences in your browser settings. 5. Disclosure of Personal Data The security and confidentiality of your Personal data is of great importance to us. This is why we restrict access to your personal data only within Glenvex and/or the Glenvex group of companies and to members of our staff only, to the extent it is strictly necessary to process your personal data or to provide the services necessary for the site. We may share or disclose personal data to third parties under the following circumstances: • To service providers supporting our operations including technical service providers; • To government agencies including law enforcement, regulatory and dispute resolution bodies (or any other body to whom disclosure is required by law or court/ tribunal order); • To contractors assisting with our operations; • To any other person or entity to whom disclosure is authorised by you. When we disclose your personal data to a third party who is processing personal data on our behalf, we take all reasonable steps to ensure that such third parties will implement appropriate safeguards and process your data only as required for their role. The potential disclosure of your personal data is conducted in compliance with legal requirements. Furthermore, we may share your Personal data (i) if the law or a legal procedure requires us to do so, (ii) in response to a request by public authorities or other officials, or (iii) if we are of the opinion that transferring this data is necessary or appropriate to prevent any physical harm or financial loss, or in respect of an investigation concerning a suspected or proven unlawful activity. 6. Data Security We take reasonable precautions to protect your data, including encryption, access controls, and secure storage systems. However, no method of transmission over the internet is entirely secure. 7. Retention of Data We retain personal data only for as long as necessary to fulfil its purpose or comply with legal obligations. This period may be extended, if applicable, for any amount of time prescribed by any legal or regulatory provisions that may apply. For example: • Customer data or where part of financial records: Retained for seven years post-transaction; • Recruitment data: If you are employed by us, your personal data will be retained for the duration of employment and up to 7 years after cessation of your employment; if you are not employed by us, we keep your data for up to 1 year after the last contact with you; • Specific data: Retained for the period specified in the specific privacy policy. After the retention period, we securely delete or anonymize your data in such a way that you can no longer be identified and may continue to use it for statistical purposes. 8. Your Rights It is important that the Personal data we hold about you is accurate and up to date. Where applicable, please keep us informed of your Personal data changes by updating your account on the site. Under the PDPA, you have the right to protect your privacy rights including without limitation the following: • Access and correct your personal data; • Withdraw consent for data processing, or request us to restrict our processing; • Object to data processing for marketing purposes. Requests can be submitted via the contact details below. Please note that some requests may limit our ability to provide certain services. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 9. Links to Other Sites/ Platforms Occasionally, we provide links to other platforms for practical and informative purposes. These platforms operate independently from our sites and are not under our control. These platforms have their own privacy policies or terms of use, please refer accordingly. We do not accept any liability with regards to the content on these platforms, for the products and services that may be offered there, or for any other use thereof. While we implement technical and organizational security measures to ensure security and confidentiality in processing your Personal data, you also have a responsibility to ensure the security and confidentiality of your Personal data so we invite you to remain vigilant, especially when using an open system such as the Internet. 10. Contact Us If you have any questions about this Privacy Policy or if you wish to exercise your data protection rights, please contact us in writing at: • Email: admin@glenvex.com • Address: Glenvex Data Protection Officer, Ground Floor, Sheraton Imperial Kuala Lumpur Hotel, 50250 Kuala Lumpur, Malaysia 11. Updates to This Policy We may review and amend this Privacy Policy from time to time to reflect changes in laws or business practices. Any revised terms will take effect from the date of posting on our website www.glenvex.com, please consult this page to be informed of any changes. By continuing to engage with Glenvex, you acknowledge and agree to the terms of this Privacy Policy as may be updated from time to time.