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Clark Asia Group Limited
Privacy Policy Statement

Clark Asia Group Limited (“CAGL”) is committed to protecting the Personal Data of the individuals (“you” “your”) we encounter in conducting our business. This Privacy Policy explains how and why CAGL (“we” “us” “our”) handles, collects and uses, to whom such data is disclosed and to whom data access requests can be addressed. Our policies and procedures have been designed to ensure that your Personal Data is protected.

* PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS PRIVACY POLICY MAY BE MODIFIED FROM TIME TO TIME.

The very nature of CAGL’s business is such that the collection, use and disclosure of personal information, is fundamental to the products and services we provide. We work hard to respect and uphold personal privacy accordance to this policy and the Personal Data Protection Act 2010 (“PDPA”) when collecting, holding, processing or using Personal Data in Malaysia. We are equally committed in ensuring that all our directors, officers, employees and partners uphold these obligations. Under the PDPA, CAGL is bound to the following obligations with respect to your Personal Data:

1. Consent
2. Purpose Limitation
3. Notification
4. Access and Correction
5. Accuracy
6. Protection
7. Retention
8. Transfer Limitation
9. Your Rights
10. Use of Data in Direct Marketing
11. Updates of Personal Data
12. Acknowledgement

Purpose of Personal Data Collected
The PDPA prohibits CAGL from collecting, using or disclosing an individual’s Personal Data unless the individual gives or is deemed to give consent for the collection, use or disclosure of the Personal Data. By providing the Personal Data requested by us, you consent to us in using and disclosing your Personal Data as set forth in this Privacy Policy Statement.

This consent remains valid until you alter or revoke it by providing written notice to CAGL. Please note that by doing so, depending on the nature of the request, we may not be in a position to continue the services or the contractual relationship in place.

Purpose Limitation
The PDPA limits the purposes for which and the extent to which an organization may collect, use or disclose personal data. CAGL collects your Personal Data when you, register with our website, submit any electronic forms available in this website, or send an email through this website which includes personal data. We collect your personal data to assess your application, through customer due diligence and anti-money laundering screening, provide you with information and services requested, and administrate them. If you do not provide us with your personal data, then we may not be able to assist you with your inquiry.

CAGL will only collect Personal Date that is reasonably necessary and related to our provision of products and services, including but not limited to processing your application arranging contracts and managing your account, and other purposes of our collection of Personal Data as set out in our Privacy Policy Statement.

Notification
When we collect Personal Data directly from you, we will inform you of the purpose by reference to this Privacy Policy. We will only collect Personal Data by lawful and fair means. Personal Data is collected by the means laid out above.

Some Information is collected automatically when you visit our website because your IP address needs to be recognized by the server. We may use the IP address information to monitor and analyze how our website are used.

We may use cookies for a number of purposes as set out in our website terms of use. Our cookies will track only your activity relating to your online activity on our website and will not track your other internet activity. Our cookies do not gather personally identifiable information. Please refer to our website terms of use for our policy on the use of cookies.

Accuracy
We will take practical steps to ensure that the Personal Data we collect, use or disclose is accurate, complete and up to date, having regard to the purpose (including any directly related purpose) for which the Personal Data is or is to be used. Please refer to Obligation 4 for details on how you can obtain and correct any Personal Data relating to you that we may hold.

Protection
We take all practical steps to ensure that Personal Data we hold is protected against unauthorized or accidental access, processing, erasure or other use. We provide a highly secure online infrastructure for activities conducted via our website, including SSL (Secure Socket Layer) encryption, IDS (Intrusion Detection System) and the use of firewalls and anti-virus software. We also adopt the use of stringent security procedures with the use of user ID and passwords, time stamping and audit trails for all transactions, together with a dedicated internal transaction security policy. Our online infrastructure is closely monitored and maintained, with data backup and data recovery procedures and mechanisms. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secured. If you have reason to believe that your interaction with us is no longer secured (for example, if you feel that the security of any Personal Data you may have with us has been compromised), please immediately notify us.

Retention
We will retain your Personal Data for only as long as necessary to serve the purposes set out in this Privacy Policy and in compliance with all statutory and regulatory requirements in Malaysia concerning the retention of Personal Data. We will take reasonable steps to destroy or permanently anonymize the Personal Data if it is no longer needed for such purposes.

Transfer Limitation
Due to the international nature of our business, for the purposes set out in this Privacy Policy, we may transfer the Personal Data to parties located in other countries that may have a different data protection regime than is found in Malaysia. The Personal Data collected in Malaysia by CAGL may be transferred to parties which may be located in Malaysia or overseas, such as to other CAGL subsidiaries, affiliates, lawyers, auditors, government or regulatory authorities, providers of risk intelligence for the purpose of customer due diligence or anti-money laundering screening or directly related purposes, for which the Personal Data was collected. Where such a transfer is performed, CAGL will take appropriate steps to ensure that the overseas recipient of the Personal Data is bound by legally enforceable obligations to provide a standard of protection to that Personal Data that is comparable to that of the PDPA.

Your Rights
Under the PDPA, you have the right (subject to certain exemptions) to request:

1. Access to some or all of your Personal Data in our possession; and
2. Information about the ways the Personal Data has been or may have been used or disclosed by us within a year before the date of your request.

Subject to certain exemptions under the PDPA, we will grant access to and correct Personal Data as requested by you. If we hold Personal Data about you and you are able to establish that the Personal Data is not accurate, complete and up to date, we will take responsible steps to correct your Personal Data so that it is accurate, complete and up to date. We will provide reasons for any denial of access or a refusal to correct the Personal Data.

Your request to access or correct Your Personal Data will be processed as soon as reasonably possible from the time the access request is received. If we are unable to respond within ten (10) working days, we will inform you in writing of the time in which we will be able to respond to your request. We have clearly expressed the policies and practices on our management of Personal Data. These policies are set out in this Privacy Policy. If you would like to access a copy of your personal data, or have a complaint or want to have more information about how CAGL manages your personal data, please contact CAGL Privacy/Compliance Officer at legal@clarkasia.com.

Use of Data in Direct Marketing
CAGL aims to comply with the requirements of the PDPA and respect your choices.

If you have consented for us to send you any promotional and/or marketing messages via your telephone number, we will continue to do so until you withdraw your consent.

CAGL will not divulge your Personal Data to any third-party direct marketers.

At any time, you may opt out of receiving marketing communications from us by contacting us or by using any opt-out facilities provided in our marketing communications and we will ensure that your name is removed from our mailing list.

Updates of Personal Data
You are obligated under this Personal Privacy Policy to update any personal data to the Company when relevant, and ensure the accuracy of the information provided.

Acknowledgement
By visiting this website, you are deemed to have read, understood and are bound by this Personal Privacy Policy.