Personal Data Protection Act

The PDPA took effect to regulate the processing of personal data in commercial transactions. We, KIMBERLUX GROUP OF COMPANIES recognize the importance of privacy and the sensitivity of personal data and information about yourself (“Personal Data”) and are committed to the protection of your Personal Data in line with the PDPA.

KIMBERLUX GROUP OF COMPANIES is sharing this Privacy and Personal Data Protection Policy to highlight your rights under the PDPA and we suggest that you read it thoroughly.

Nature of Personal Data

Personal Data means information that identifies you and shall include but not be limited to the following information:

a.	name, job title and company name;
b.	age, gender, date of birth, identity card number, passport number, photograph;
c.	race, ethnic origin, nationality, physical and mental health;
d.	contact information including address, email address and phone number;
e.	type of loans applied for in relation to purchase of property;
f.	financial and credit card details, bank name and other pertinent banking information, tax file identification number, EPF number, SOCSO number, criminal history; and
g.	such other relevant information and data to enable us to provide you with our services.

Purpose of Collection of Personal Data

Your Personal Data may be collected, stored and/or used (whether directly or indirectly) and in whatever form including audio visual recordings and photographs, amongst others, for the following purposes:

a.	your name and picture may be displayed on KIMBERLUX GROUP OF COMPANIES’s website, publications, newsletters, documents, alerts, notifications, and any other material of similar nature;
b.	to operate our website and information technology software (including the collection of internet protocol address and cookies) including all internet related activities;
c.	credit assessments, financial and background investigations as and when deemed necessary;
d.	for any other purpose that is incidental or ancillary or in furtherance to the above purposes.

Source of Personal Data

We collect information only by lawful and fair means, and not in an unreasonably intrusive way.Wherever possible we collect your Personal Data directly from you, both at the start of a retainer and in the course of our representation.

Sometimes we may obtain information about you from other sources. The Personal Data which may be collected, processed and used by KIMBERLUX GROUP OF COMPANIES are sourced from sources such as:

a.	official registration forms (either electronic or printed) for seminars or in-house talks, newsletter subscription or any other promotional events;
b.	any queries, emails or any correspondences that we have received from you requesting for information or making enquiries;
c.	any ‘contact us’ forms that you have submitted through our website;
d.	from a government agency or registry, any referrals that we may have obtained from existing clients whom we have verifiable personal contact details;

Rights of Access and Correction

You have the right to request access to your Personal Data and if required, correction of your Personal Data in our records. You may at any time:

a.	request access to your Personal Data in our records to check and verify your Personal Data;
b.	request that we correct and update any of your Personal Data in our records if it is inaccurate, incomplete, misleading or becomes out-of-date;
c.	request to limit or cease the processing of your Personal Data all together;
d.	raise any concerns, enquiries or complaints in respect of the processing of your Personal Data;
e.	request for explanation on the policies and procedures in respect of your Personal Data provided to us;

Disclosure of Personal Data

Personal Data provided to KIMBERLUX GROUP OF COMPANIES will generally be kept confidential but you hereby consent and authorise KIMBERLUX GROUP OF COMPANIES to provide or disclose your Personal Data to the following categories of parties:

a.	our and/or our client’s auditors, consultants, accountants or any relevant financial institutions or professional advisers;
b.	our and/or our client’s suppliers, contractors, sub-contractors or third party service providers as may be deemed to be necessary or appropriate;
c.	third party property management and real estate agency companies / entitled in respect of property which is the subject matter of our engagement;
d.	counterparties or counterparties’ advisers, agents and representatives in any legal and/or commercial transaction, financial institutions for loan documentation processing, relevant state authority and the Inland Revenue Board.

Consequences of Refusal

When Personal Data provided is wholly voluntary in nature, you are not under any obligation or under any duress to do so. However, in some circumstances, when it is obligatory to provide us your Personal Data, the failure to do so may result in the following consequences in which KIMBERLUX GROUP OF COMPANIES shall not be held liable:

a.	inability to maintain your clientele with us;
b.	inability of parties to finalize any contract and / or agreement;
c.	inability to keep you apprised of any information requested or business development activities;
d.	inability to complete commercial transactions.

Safeguards and Protection

KIMBERLUX GROUP OF COMPANIES shall keep and process your Personal Data in a secure manner and prevent any unauthorized and/or unlawful processing, any accidental loss, destruction or damage to your Personal Data. We endeavour to implement the appropriate administrative and security safeguards and procedures in accordance with the PDPA to protect and safeguard the integrity of your Personal Data. Compliance with these provisions will be required of all third parties who may access your Personal Data (as set out in paragraph 6).