1.1 SBH Corporate Group Sdn Bhd, its subsidiaries and/ or affiliates (hereinafter collectively referred to as “SBH”, “we”, “us” or “our”) commit to fully meet the requirements of the applicable data privacy law of Malaysia, i.e. the Personal Data Protection Act 2010 in Malaysia. In doing so, we will ensure our staff comply to the strictest standards of security and confidentiality in respect of all personal information and data submitted by you to us via our products, services and website.
1.2 This Privacy Notice (this “Notice”) describes how we collects, uses, maintains, discloses and shares your personal data and information about you and the choices that you can make about the way your information is collected, used, maintained, disclosed and shared.
1.3 This Notice applies to all products, services and website available from SBH. We strongly recommend you to read this Notice before using any product, service and website of SBH. By using our products, services and/or website, you are agreeing to the current terms of this Privacy Notice and consenting to our use of your Personal Data provided by you to us.
2. Information collected
2.1 Personal Data is information and/or data that identifies you as an individual, such as your name, national identification number, date of birth, age, gender, nationality, mailing address, email address, mobile number, photo, income level, credit card account number, bank account number, marital status, occupation, financial information etc. When it is necessary, we may collect such other additional personal information from you to facilitate a transaction and/or to comply with all applicable anti-money laundering and/or counter-terrorist financing laws, other regulations and our internal policies. We may collect your sensitive personal data (including personal data related to your physical or mental health, the commission or alleged commission of offences etc) if it is required by another relevant authority to facilitate a transaction through any products, services and/or use of website provided by SBH to you. We will only use your sensitive personal data to provide the product(s), service(s) you signed up for. For the avoidance of doubt, Personal Data as defined in this Clause 2.1 shall include the sensitive personal data as specified herein.
2.2 The Personal Data we collect from you can be either voluntary or obligatory. Voluntary personal data are those data that are not mandatory in order for us to provide you with our products and/or services and/or for your usage of our website. If you do not provide us with voluntary personal data, you may still sign up for certain part of our products and/or services and/or part usage of our website. On the other hand, obligatory personal data are those data that we require in order to provide our products, services and/or for your usage of our website. If you do not provide us with the obligatory personal data, we would not be able to render you with our products, services and/or for your usage of our website. Voluntary and obligatory personal data may differ for each services and products and will be indicated in the relevant application forms.
2.3 You are not obliged to provide the Personal Data requested if you are not agreeable to this Privacy Notice. However, we may not be able to provide certain products and/or render certain services and/or allow your usage of the website, if you fail to do so and SBH shall not be held liable for any loss, damage, cost or expenses whatsoever in connection to your rejection in providing the required Personal Data for us to continue providing certain products to you and/or rendering certain services for you and/or allowing your usage of the website.
3. How do we collect your Personal Data
3.1 We collect your Personal Data in various ways, including but not limited to:-
(a) when you sign up for or use one of the many products and/or services we provide or when you register an account at our website; and/or
(b) when you contact us through various method such as emails, letters, application forms and telephone calls. We may monitor or record the phone call for quality assurance, training and security purposes; and/or
(c) when we obtained any data and information from third party, i.e. legal representatives, regulatory and enforcement agencies, credit reference agencies etc; and/or
(d) when we obtained your personal data from your participation in our customer surveys or when you sign up for any courses, seminars, competitions or events organised by SBH; and/or
(e) from publicly available sources.
3.2 We may also automatically collect device information when you install, access and use our services and/or browse through our website. This includes information such as mobile carrier, mobile device model, operation system, browser type and version, IP address, device platform (Android/ iOS), browsing platform etc.
3.3 We may also collect service-related, diagnostic, and performance information. This includes information about your activity, log files, diagnostic, crash, website, referral url. and performance logs and reports.
(e) You can adjust settings on your browser so that you will be notified when you receive a cookie. Please refer to your browser documentation to check if cookies have been enabled on your computer or to request not to receive cookies.
4. Purpose for which we may process your personal data
4.1 To enable us to provide the products and/or render the services and/or for your usage of the website, we may need to process your Personal Data for purposes including the following:-
(a) Processing your application for products and/or services, effecting transactions, payments and completing instructions or requests;
(b) Communicating with you including but not limiting to your enquiries;
(c) Providing products and/or services to you;
(d) Managing and maintaining your account with SBH;
(e) Operational purposes;
(f) Conducting customer due diligence checks as required by law and regulations, if any;
(g) Marketing and promotional purposes provided by us and/or our merchants;
(h) Statistical purposes;
(i) Establishment, continuation and management of your account with us
(j) Handling and investigating complaints and/or resolving disputes.
4.2 For some purposes in connection with the products you purchased/subscribed and/or service you have requested, we have a legal or regulatory obligation to process your personal data. These purposes include but are not limited to:-
(a) The prevention, detection, investigation and/or prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
(b) Identity verification, government sanctions screening and due diligence checks;
(c) To comply with the law, regulations, reporting requirements under financial transactions legislation, if any and demands of any authority or regulator.
5. To whom we may disclose personal data
5.1 Any member of SBH, including our employees, agents and advisers, may disclose your Personal Data to any of the following parties for any of the purposes specified below:
(a) Professional advisers (including auditors), third party service providers, agents or independent contractors providing services to support our business, website, products;
(b) Our business alliance partners who may provide services to you;
(c) A payment gateway service provider where the disclosure is in connection with the use of a card;
(d) Any court, tribunal, regulator, enforcement agency or any other authority or their agents;
(e) Any authority to conduct anti-money laundering related checks, for fraud prevention and detection of crime purposes;
(f) Anyone we consider necessary in order to provide and improve the services that we provide you;
(g) Anyone reasonably in relation to the products and/or services that we may provide to you.
5.2 Personal data collected may be transferred, stored and processed in any country in which SBH operates. You are deemed to have agreed to, consented to and authorized us to disclose and/or transfer your Personal Data under the circumstances stated above, without further notification to you.
6. Correction of your information
6.1 We are committed to ensure that Personal Data we hold about you is accurate, complete, not misleading and up-to-date. If there are any changes to your personal data or if you believe that the personal data we have about you is inaccurate, incomplete, misleading, or not up-to-date, you may correct factual errors in your personal information that we have collected by sending us a request that credibly shows the error.
6.2 To protect your privacy and security, we will take reasonable steps to verify your identity before making corrections. We reserve the right to charge you a reasonable fee if you request access to your data.
6.3 Your Personal Data will be stored by us until it is no longer necessary to provide our products and/or services or your account is deleted, whichever is the later. This is a case-by-case determination depending on the nature of the Personal Data and/or the necessary legal compliance by SBH in accordance with the relevant law applicable to the country of service.
7.1 Personal data may be transferred to, or stored at, a location outside of your country of residence, which may not have data protection law. The security of your personal data is important to us. We have technical and organisational security measures in place to safeguard your personal data. When using external service providers, we require that they adhere to security standards mandated by SBH. We may do this through contractual provisions. Regardless of where personal data is transferred, we shall take all steps reasonably necessary to ensure that your personal data is kept securely.
7.2 However, you should be aware that methods of transmission over the Internet or methods of electronic storage is not 100% secure. Therefore, while we strive to protect your personal data against all possible unauthorized access, we are unable to guarantee its absolute security.
7.3 You should safeguard your unique password, if any, by keeping it secret and confidential and never share these details with anyone.
7.4 We may use third party payment gateway service providers to facilitate electronic transactions, if necessary. You shall take note of the privacy notice prepared by the third party payment gateway service provider before completing your transaction. In view that the web browser and third-party payment gateway are not within the control of SBH, SBH will not be held liable for any loss, damage, cost and expenses arising from your use of the web browser and/or third-party payment gateway.
8. Contact us
8.1 All requests regarding correction of your personal information should be made in writing to:
The Information Security Officer
SBH Corporate Group Sdn Bhd
8.2 If you have questions regarding this Notice, please email us at firstname.lastname@example.org.
9. Changes to this Policy
9.1 We reserve the right to update, revise, vary, modify, delete and/or amend this Notice at any time as we deem necessary. We shall notify you if we make any changes to the Privacy Notice and give you the opportunity to review the revised Privacy Notice before you choose to continue using our products, services and/or website. A copy of the latest revised Privacy Notice will be posted on our website at https://www.consultancy.sbhgroup.com.my and/or other places we deem appropriate.Last updated: November 2020