INTRODUCTION

This is the privacy policy (“Privacy Policy”) of Careclinics Healthcare Services Sdn Bhd and its affiliates (including but not limited to its subsidiaries, related, associated and affiliated companies, whether such companies are residing, situated, carrying on business, incorporated or constituted within or outside Malaysia) (“Careclinics Healthcare Services Sdn Bhd”).

This Privacy Policy applies to personal information about individuals held by Careclinics Healthcare Services Sdn Bhd. Careclinics Healthcare Services Sdn Bhd will only process your Personal Data in accordance with the Personal Data Protection Act 2010, the applicable regulations, guidelines, orders made under the PDPA and any statutory amendments or re-enactments made of the PDPA from time to time (collectively referred to as the “PDPA”) as well as this Privacy Policy.

Careclinics Healthcare Services Sdn Bhd reserves the right, at its sole discretion, to modify, update and/or amend this Privacy Policy from time to time. Any updates and/or amendments to this Privacy Policy will be posted on Careclinics Healthcare Services Sdn Bhd website (“Site”), and you are advised to check the Privacy Policy from time to time. Any amendments to this Privacy Policy will apply retrospectively to all personal data collected. By continuing to use the services and/or access to the Site, you will be treated as having agreed to and accepted those amendments.

You may obtain a copy of this Privacy Policy on https://www.careclinics.com.my/ (Website name) or by contacting Careclinics Healthcare Services Sdn Bhd at the contact details given below.

If you do not agree to this Privacy Policy or any amendments to this Privacy Policy,Careclinics Healthcare Services Sdn Bhd may not be able to render such necessary services and/or products to you, if at all.

COLLECTION OF PERSONAL DATA

The term “Personal Data” means any information in the possession of Careclinics Healthcare Services Sdn Bhd or control of Careclinics Healthcare Services Sdn Bhd that relates directly or indirectly to an individual to the extent that the individual can be identified or are identifiable from that and other information in the possession of Careclinics Healthcare Services Sdn Bhd such as name, address, telephone number, NRIC, email address, etc. Careclinics Healthcare Services Sdn Bhd may “process” your Personal Data by way of collecting, recording, holding, storing, using or disclosing it.

Your Personal Data may be collected from you during your course of dealings with Careclinics Healthcare Services Sdn Bhd in any way or manner including pursuant to any transactions and/or communications made from/with Careclinics Healthcare Services Sdn Bhd. Careclinics Healthcare Services Sdn Bhd may also collect your Personal Data from a variety of sources, including without limitation, at any events, seminars, road shows, customer satisfaction surveys organised or sponsored by Careclinics Healthcare Services Sdn Bhd and/or from the cookies used on the Site.

In addition, Careclinics Healthcare Services Sdn Bhd may also receive, store and process your Personal Data which are provided or made available by any third parties, credit reference bodies, regulatory and law enforcement authorities, for reasons including delivery of Careclinics Healthcare Services Sdn Bhd products and/or services, performance of conditions of agreements and/or to comply with Careclinics Healthcare Services Sdn Bhd legal and regulatory obligations.

PURPOSE OF ACQUIRING AND PROCESSING YOUR PERSONAL DATA

Your Personal Data may be processed for the following purposes:

(a) to communicate with you;

(b) to provide products and/or services to you;

(c) to respond to your enquiries or complaints;

(d) to process your purchase and/or contest entry;

(e) to provide you with information and/or updates on the present and future property developments, other products, services and/or promotions offered by Careclinics Healthcare Services Sdn Bhd and selected third parties which may be of interest to you from time to time by SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;

(f) to send you seasonal greetings messages from time to time;

(g) to send you invitation to join Careclinics Healthcare Services Sdn Bhd’s membership(optional), events and promotions and property launch events;

(h) to monitor, review and improve Careclinics Healthcare Services Sdn Bhd’s membership, events and promotions, products and/or services;

(i) to process and analyse your Personal Data either individually or collectively with other individuals;

(j) to conduct market research or surveys, client profiling activities, planning and statistical analysis within Careclinics Healthcare Services Sdn Bhd in relation to Careclinics Healthcare Services Sdn Bhd present and future property developments, other products and/or services;

(k) to share any of your Personal Data with the auditor for Careclinics Healthcare Services Sdn Bhd internal audit purposes;

(l) to share any of your Personal Data with a third party for purposes of assisting you pursuant to your financial application, where necessary;

(m) to share any of your Personal Data pursuant to any agreement or document which you have duly entered with Careclinics Healthcare Services Sdn Bhd for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;

(n) to share any of your Personal Data with a third party necessary for the preparation of legal documents or contract to be entered by you with Careclinics Healthcare Services Sdn Bhd;

(o) to share any of your Personal Data with a third party necessary for the purpose of applying and obtaining insurance policy(ies), where necessary;

(p) to maintain and improve customer relationship;

(q) to maintain and update internal record keeping;

(r) for internal administrative purposes;

(s) for audit and risk management purposes;

(t) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;

(u) for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels;

(v) for enabling Careclinics Healthcare Services Sdn Bhd to perform its obligations under the agreement or document which you have duly entered into with Careclinics Healthcare Services Sdn Bhd including but not limited to attending to the registration with the relevant authorities on your behalf, delivery of vacant possession, defect rectification works and perfecting the transfer of the separate individual/strata title in your favour;

(w) for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to Careclinics Healthcare Services Sdn Bhd;

(x) to enforce or defend Careclinics Healthcare Services Sdn Bhd rights and your rights under, and to comply with, Careclinics Healthcare Services Sdn Bhd obligations under the applicable laws, legislation and regulations; and/or

(y) for other purposes required to operate and maintain Careclinics Healthcare Services Sdn Bhd business,

(collectively referred to as the “Purposes”), and you agree and consent to Careclinics Healthcare Services Sdn Bhd using and processing your Personal Data for the Purposes in the manner as identified in this Privacy Policy. If you do not consent to Careclinics Healthcare Services Sdn Bhd processing your Personal Data for one or more of the Purposes, please notify Careclinics Healthcare Services Sdn Bhd at the contact details below. (collectively referred to as the “Purposes”), and you agree and consent to Careclinics Healthcare Services Sdn Bhd using and processing your Personal Data for the Purposes in the manner as identified in this Privacy Policy. If you do not consent to Careclinics Healthcare Services Sdn Bhd processing your Personal Data for one or more of the Purposes, please notify Careclinics Healthcare Services Sdn Bhd at the contact details below.

CONSEQUENCES OF NOT CONSENTING TO THIS PRIVACY POLICY

It is obligatory for Careclinics Healthcare Services Sdn Bhd to collect and to retain your Personal Data unless stated otherwise. If you do not supply Careclinics Healthcare Services Sdn Bhd with your Personal Data, or do not consent to the above or this Privacy Policy, Careclinics Healthcare Services Sdn Bhd (Company name)will not be able to:

(a) to process your purchase of any of Careclinics Healthcare Services Sdn Bhd products and/or services;

(b) communicate with you;

(c) provide you with Careclinics Healthcare Services Sdn Bhd products and/or services requested;

(d) accept and process your entry to any contest;

(e) update you on Careclinics Healthcare Services Sdn Bhd latest products, services and/or promotions; and/or

(f) allow you to access certain sections of the Site where log in is required,

and you may be required to terminate your agreement or discontinue your business relationship with Careclinics Healthcare Services Sdn Bhd.

DISCLOSURE OF YOUR PERSONAL DATA

Careclinics Healthcare Services Sdn Bhd will not disclose any of your Personal Data to any third party without your consent except to the following third parties, for one or more of the above Purposes:

(a) companies within Careclinics Healthcare Services Sdn Bhd and their respective employees;

(b) your immediate family members and/or emergency contact person as may be notified to Careclinics Healthcare Services Sdn Bhd from time to time;

(c) successors in title to the companies within Careclinics Healthcare Services Sdn Bhd;

(d) any party who is involved in connection with corporate exercises, such as a potential or actual sale/disposal of any business or interest of any companies within Careclinics Healthcare Services Sdn Bhd, merger, consolidation, re-organisation or funding exercise relating to any companies within Careclinics Healthcare Services Sdn Bhd, or asset sale, or in the event of winding-up of any companies within Careclinics Healthcare Services Sdn Bhd;

(e) Careclinics Healthcare Services Sdn Bhd business partners and affiliates that provide related products and/or services in connection with Careclinics Healthcare Services Sdn Bhd business for joint promotions and/or contests;

(f) any person under a duty of confidentiality to which has undertaken to keep your Personal Data confidential which Careclinics Healthcare Services Sdn Bhd has engaged to discharge Careclinics Healthcare Services Sdn Bhd obligations to you;

(g) any party in relation to legal proceedings or prospective legal proceedings;

(h) Careclinics Healthcare Services Sdn Bhd auditors, consultants, lawyers or other financial or professional advisers on a need to know basis for the purpose of those advisers providing advice to Careclinics Healthcare Services Sdn Bhd;

(i) any party nominated or appointed by Careclinics Healthcare Services Sdn Bhd either solely or jointly with other service providers, for purpose of establishing and maintaining a common database where Careclinics Healthcare Services Sdn Bhd has a legitimate common interest;

(j) data centres and/or servers located within or outside Malaysia for data storage purposes;

(k) payment channels including but not limited to financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to Careclinics Healthcare Services Sdn Bhd in connection with your purchase of Careclinics Healthcare Services Sdn Bhd products and/or services;

(l) government agencies, law enforcement agencies, courts, tribunals, regulatory bodies, ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgement of a court or tribunal or queries from the relevant authorities;

(m) Careclinics Healthcare Services Sdn Bhd contractors or sub-contractors as may be necessary for discharging Careclinics Healthcare Services Sdn Bhd duties and obligations under any document or agreement duly entered by you with Careclinics Healthcare Services Sdn Bhd;

(n) Careclinics Healthcare Services Sdn Bhd appointed product and/or service providers, suppliers or agents, to discharge or perform one or more of the above Purposes;

(o) any persons, authorities or regulators to whom Careclinics Healthcare Services Sdn Bhd is permitted or required to disclose to under the applicable laws; and/or

ACCURACY OF YOUR PERSONAL DATA

Careclinics Healthcare Services Sdn Bhd aims to keep all Personal Data as accurate, complete, not misleading, up-to-date and reliable as possible. Therefore, the accuracy of your Personal Data depends to a large extent on the information you provide. As such, it is a condition of Careclinics Healthcare Services Sdn Bhd providing the products and/or services to you that you:

(a) warrant and declare that all your Personal Data submitted or to be submitted to Careclinics Healthcare Services Sdn Bhd are accurate, not misleading, updated and complete in all respects for purposes of acquiring or using the relevant products and/or services and you have not withheld any Personal Data which may be material in any respect and that Careclinics Healthcare Services Sdn Bhd is authorized to assume the authenticity and accuracy of the Personal Data given by you when processing the Personal Data submitted by you to Careclinics Healthcare Services Sdn Bhd (and Careclinics Healthcare Services Sdn Bhd is not obliged to independently verify any of such Personal Data); and

(b) you understand and agree to the importance of the need to update Careclinics Healthcare Services Sdn Bhd as and when such Personal Data provided earlier to Careclinics Healthcare Services Sdn Bhd becomes inaccurate, incomplete, misleading, outdated or changes in any way whatsoever by contacting Careclinics Healthcare Services Sdn Bhd at the contact details below.

YOUR RIGHTS

Subject to the exceptions provided under the PDPA, you have the right to request for access to, request for a copy of, request to update or correct, your Personal Data held by Careclinics Healthcare Services Sdn Bhd. Careclinics Healthcare Services Sdn Bhd may charge a small fee (such amount as permitted by the PDPA) to cover the administration costs involved in processing your request to access your Personal Data.

In respect of your right to access and/or correct your Personal Data, Careclinics Healthcare Services Sdn Bhd has the right to refuse your request to access and/or correct your Personal Data for the reasons permitted under the law, such as where the expense of providing access to you is disproportionate to the risks to your privacy, or where the rights of others may also be violated, amongst other reasons.

You have the right at any time to request Careclinics Healthcare Services Sdn Bhd to limit the processing and use of your Personal Data (for example, requesting Careclinics Healthcare Services Sdn Bhd to stop sending you any marketing and promotional materials or contacting you for marketing purposes).

In addition, you also have the right to inform Careclinics Healthcare Services Sdn Bhd on your withdrawal (in full or in part) of your consent given previously to Careclinics Healthcare Services Sdn Bhd subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be effected.

RETENTION OF YOUR PERSONAL DATA

Any of your Personal Data provided to Careclinics Healthcare Services Sdn Bhd is retained for as long as the purposes for which the Personal Data was collected continues; your Personal Data is then destroyed unless its further retention is required to satisfy a longer retention period to meet the operational, legal, regulatory, tax or accounting requirements of Careclinics Healthcare Services Sdn Bhd.

SECURITY OF YOUR PERSONAL DATA

Careclinics Healthcare Services Sdn Bhd is committed to ensuring that your Personal Data is stored securely. In order to prevent unauthorised access, disclosure or other similar risks, Careclinics Healthcare Services Sdn Bhd endeavours, where practicable, to implement appropriate technical and organisational measures in accordance with the applicable laws and regulations to safeguard against and prevent the unauthorised or unlawful processing of your Personal Data, and the destruction of, or accidental loss, damage to, alteration of, unauthorised disclosure of or access to your Personal Data.

Careclinics Healthcare Services Sdn Bhd will make reasonable updates to its security measures from time to time and ensure the authorised third parties only use your Personal Data for the Purposes set out in this Privacy Policy, and to adequately safeguard your Personal Data.

The Internet is not a secure medium. However, Careclinics Healthcare Services Sdn Bhd will put in place various security procedures with regard to the Site and your electronic communications with Careclinics Healthcare Services Sdn Bhd.

Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may be routed through a number of countries before being delivered – this is the nature of the World Wide Web/Internet.

Careclinics Healthcare Services Sdn Bhd cannot and does not accept responsibility for any unauthorised access or interception or loss of Personal Data that is beyond Careclinics Healthcare Services Sdn Bhd reasonable control.

PERSONAL DATA FROM MINORS AND OTHER INDIVIDUALS

To the extent that you have provided (or will provide) Personal Data about your family, spouse and/or other dependents, you represent and warrant that you have obtained their consent to provide their Personal Data to Careclinics Healthcare Services Sdn Bhd and they consent to their Personal Data being processed in accordance with this Privacy Policy and, with respect to minors (i.e. individuals under 18 years of age) or any individuals not legally competent to give consent, you consent on their behalf (and you confirm that you have the authority to do so).

TRANSFER OF YOUR PERSONAL DATA OUTSIDE OF MALAYSIA

Careclinics Healthcare Services Sdn Bhd information technology storage facilities and servers may be located in other jurisdictions outside of Malaysia. Your Personal Data may be transferred to entities outside of Malaysia. This may include, but not limited to, instances where your Personal Data may be stored on servers located outside of Malaysia. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in Malaysia under the laws of Malaysia. You hereby expressly consent to Careclinics Healthcare Services Sdn Bhd transferring your Personal Data outside of Malaysia for such purposes. Careclinics Healthcare Services Sdn Bhd shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of Malaysia shall not use your Personal Data other than for that part of the Purposes and to adequately protect the confidentiality and privacy of your Personal Data.

WEBSITE

External links

(a) If any part of the Site links you to other websites, those websites do not operate under this Privacy Policy and Careclinics Healthcare Services Sdn Bhd does not accept any responsibility or liability arising from those websites.

(b) Likewise, if you subscribe to an application, content or a product from a strategic partner of Careclinics Healthcare Services Sdn Bhd and you subsequently provide your Personal Data directly to that third party, that Personal Data will be subject to that third party’s privacy policy (if they have such a policy) and not to this Privacy Policy.

(c) Careclinics Healthcare Services Sdn Bhd recommends you to read and understand the privacy statement/policy posted on those other websites in order to understand their procedures for collecting, processing, using and disclosing personal data and before submitting your Personal Data to those websites.

CONTACT DETAILS

If you have any questions about this Privacy Policy or would like to make a complaint or data access or correction request, you may contact Careclinics Healthcare Services Sdn Bhd at the contact details below:

(Contact details)

+603 2732 8934 / 8932

Careclinics Healthcare Services Headquarters

No. 23A-6, Oval Damansara, 685, Jalan Damansara,

Taman Tun Dr. Ismail, 60000 Kuala Lumpur