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PRIVACY AND PERSONAL DATA PROTECTION POLICY

1. INTRODUCTION

Capital City Property Sdn Bhd (1049977-V) and its group of companies ("CCP 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. CCP Group is bound by the Personal Data Protection Act 2010 ("PDA Act") and all other applicable law 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 PDA Act which means any information in respect of commercial transactions, which:-

1.  is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose;
2.  is recorded with the intention that it should wholly or partly be processed by means of such equipment; or
3.  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 CCP Group, you may be requested to furnish from time to time to CCP 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, financing details for the purchase of the property of CCP Group 's housing development project 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 CCP Group.

3. PURPOSE OF COLLECTION

1.  CCP Group may collect, retain, use and otherwise process your personal data for the following purposes:-
1.  providing you with services under any business of CCP Group; or
2.  processing your application or registration under any program and/or activities organized or conducted by CCP Group or in connection with your employment application; or
3.  notifying you of services or launches of properties 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
4.  sale of the products and/or properties offered by CCP Group, to you which shall include all matters relevant for the completion of the sale and purchase transactions, delivery of vacant possession, defect rectification works and other post vacant possession services; or
5. entering into any transactions, agreements or instruments in the ordinary course of business of CCP Group; or
6. discharging CCP Group 's contractual obligations in the ordinary course of business of CCP Group; or
7. property and/or estate management; or
8. collection of any payments due and payable to CCP Group including late interest charges; or
9. credit assessments and other background verification that may be necessary or appropriate for CCP Group 's business or employment purposes; or
10. human resource management; or
11. sending you services, products or promotional information related to other third parties which CCP Group thinks you may be interested; or
12. discharging CCP Group 's duties and obligations under the Companies Act 1965 (as amended from time to time) and any other applicable law, regulation, direction and guideline applicable to CCP Group;
13. for other legitimate business activities of CCP Group; or
14. in anticipation of, and in the course of an actual or potential sale, reorganization, consolidation, merger, or amalgamation of all or part of CCP Group 's business or operations; or
15. for any other purpose that is incidental or ancillary or in furtherance to the above purposes.
2. To facilitate any of the purposes of Paragraph 3 (a) above, it is obligatory for you to supply CCP Group with sufficient personal data as required by CCP Group. If you fail to supply the personal data as required:-
1. CCP Group will not be able to provide you with the necessary notices, services and/or products requested;
2. CCP Group will not be able to process your application or registration for any of the necessary services, products, programs and/or activities; and/or
3. CCP Group will not be able to enter into the necessary transaction, agreement or dealing with you or in your favour.
3. If you do not want CCP 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 CCP Group in writing at the particulars set out in Paragraph 7(c) below.

4. DISCLOSURE

CCP 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, Bank Negara Malaysia, Official Assignee's Office of the Insolvency Department of Malaysia, any other person, body or government agency under the requirements of any applicable law or order, direction or egulation of any regulatory or appropriate authorities;

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

(c) CCP Group 's business partners and affiliates;

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

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

(f) third party property management companies;

(g) any financial institutions, lawyers and professional advisers appointed by you;

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

(i) any other entities that CCP Group may think fit.

5. SECURITY POLICY

CCP 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:

(a)to the nature of the personal data and the harm that would arise;

(b)to the place or location where the personal data is stored;

(c) to any security measures incorporated into any equipment in which the personal data is stored;

(d) to the measures taken for ensuring the reliability, integrity and competence of personnel having access to the personal data; and

(e) langkah yang diambil bagi memastikan pemindahan selamat data peribadi itu

CCP Group shall ensure that any security policy developed or implemented by CCP Group complies with the security standard required under the PDA 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 CCP 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 CCP 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

CCP 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, CCP Group shall take all reasonable steps to ensure that it is destroyed or permanently deleted.

7. RIGHT OF ACCESS AND CORRECTION

Under the PDA Act, you have the right of access to your personal data held by CCP 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 CCP Group is inaccurate, incomplete, misleading or not up-to- date, you may make a data correction request in writing to CCP Group. You may submit your written request or any inquiries in writing to CCP Group at the following address:

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