Privacy Notice

General

SD Guthrie and its group of companies, including its subsidiaries and controlled companies ("SD Guthrie” or “we” or “us,” or “our”) are committed to protecting your privacy. This privacy notice ("Privacy Notice”) applies to all our brands globally and set out how we collect, use, maintain, disclose your personal data in accordance with the legal and regulatory requirements. Please ensure that you have read and understood this Privacy Notice before accessing our website or providing your personal data to us.

Information Collection and Categories of Personal Data

Information Collection
Your personal data may be collected from you when you are accessing our website, in our existing guest lists, business cards, guest books and/or any events organised by us or various other sources such as our customers, their counterparties and representatives, regulatory authorities, government agencies, credit reporting agencies, recruitment agencies, providers of pre-engagement screening services, your existing employer, social media sites, publicly available information or any other third parties that we work with.

EEA or UK citizens or residents
If you are a citizen or resident in the European Economic Area ("EEA”) or the United Kingdom, ("UK”) please refer to Purposes and Lawful Basis for Processing of Personal Data Section below where we have set out additional information required by the European Union ("EU”) and UK data protection laws to explain on the “lawful bases” for processing of your personal data.

If you are not a citizen or resident in the EEA or UK, in the case where you provide us with your personal data, you agree and consent to our collection, use and disclosure of your personal data for the purposes set out in this Privacy Notice, where applicable.

Categories of Personal Data
Categories of personal data that we may collect from you, depending on the purpose of our relationship and dealing with you which may include but not limited to your name, identification number (IC), passport number, correspondence address, nationality, telephone number, email address and location. The aforesaid personal data is not exhaustive and may include other personal data depending on the nature of business relationship, dealings or transaction between you and us.

There are instances where we may need to collect certain kind of personal data which is more sensitive and accorded higher level of protection (with stricter requirements) in jurisdictions such as the EEA and UK. Categories of such personal data include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation as well as criminal conviction and offences. Where we require sensitive personal data and criminal records of someone, we will ensure that we satisfy the legal basis for our processing of such data.

Where we collect personal data, we will only do so for purposes of fulfilment of one (1) or more Purposes set out in Purposes and Lawful Basis for Processing of Personal Data Section below. Your refusal to provide us with such personal data may result in us not being able to process and/or disclose your personal data for the Purposes (as defined below).

Purposes and Lawful Basis for Processing of Personal Data

Purposes
The purposes of which your personal data will be collected and processed by us, include but not limited to the following:

to enable you to provide goods or services to us or vice versa;
to process and manage your participation in any contest/programme organised by us;
to assess and handle your job application;
to carry out background check and Know Your Counterparty (KYC) screening activities;
to send you festive messages, promotional message and special offers;
for purposes of entering into a business relationship with you;
to defence claim or suit against us in a legal proceeding or potential legal proceeding;
for internal record keeping;
for security and fraud prevention purposes;
for the purposes of statistical analysis of data;
for profiling your preferences;
for marketing activities;
for the purposes of investor relations matters;
for the investigation of complaints, misconduct and suspected suspicious transactions (including but not limited to carrying out due diligence and/or other screening activities);
for the purposes of inclusion in media engagements and/or any relevant or related events;
for the purposes of us preparing guest invitations, registration and/or sign-ups for our events;
for general administrative and management purposes;
for visit to our offices or premises where your image may be captured and recorded via CCTV to ensure safety within premises;
for sale or transfer of all or any part of our business or assets to third party(ies);
for purposes of health management during health crisis or disease outbreak; and/or
for all other purposes required or permitted by legislative, statutory and regulatory requirements,

(collectively, “the Purposes”).

Anonymised Data
We may create anonymous data records from the personal data that we collect from you which has been anonymised. Anonymised data is not personal data in law as such data will not directly or indirectly identify you. For example, we may use such anonymous data for any calculation of traffic or use of specific website feature and disclose anonymous data to third parties, including but not limited to our research partners. If our use of the anonymous data records will lead to identification of your identity, we will treat the combined data as personal data which will be used in accordance with this Privacy Notice.

Lawful Bases
In our dealings or interaction with you, we rely on various lawful bases for purposes of processing of your personal data. Please refer to the table below.

Direct Marketing Purposes
We may periodically send you newsletters, surveys, offers, and other promotional materials regarding our products and services which we believe that are of interest or useful to you, if you have consented (opted-in) to receive such messages via e-mail or any other electronic channel (where such opt-in is required under your local law).

If you do not wish to receive such communications anymore, you can "opt out" by following the unsubscribe instructions provided in each of our direct marketing e-mails or by contacting us directly (please see Contact Details section below). We will then record any objection you make and stop sending promotional communications to you.

Automated Decision-Making
We do not process your personal data via automated decision-making.

Overview on Cookie
A cookie is a small file which asks permission to be placed on your device. Once you agree, the file is added and the cookie helps to analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

Types of Cookies and the Purposes
We use cookies and other similar technologies to collect information about our visitors. More specifically, we use cookies and other similar technologies for the following purposes:

Necessary Cookies – These cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
Statistics Cookies – These cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
Preference Cookies – These cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
Marketing Cookies – These cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
Unclassified Cookies – These cookies do not belong to any other category or are in the process of categorisation.

A cookie in no way gives us access to your device or any information about you, other than the data you choose to share with us.

Modify Cookies Preferences
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

You can also change your cookie preferences (except for strictly necessary cookies) at any time by clicking on the black icon at the bottom left of our site.

Personal Data of Minors and Other Individuals

Where you have shared or provided us with personal data of any of your family members, spouse, dependent and/or other individuals, you confirm that you have obtained consent from the relevant person for the processing of their personal data in accordance with this Privacy Notice.

In the case where you share or provide us with personal data of minors, you confirm that you have the right to act and consent on their behalf for processing of their personal data in accordance with this Privacy Notice.

Sharing of Your Personal Data

Sharing of Your Personal Data
Please be informed that your personal data may be disclosed, disseminated and/or transferred to other companies within our group (including the holding company, subsidiaries, associated, related and affiliated companies as well as their subsidiaries, associated and affiliated companies, both local and international), whether present or future, or to any third party organisations or persons for the purpose of fulfilling our obligations to you in respect of the Purposes and all such other purposes that are related to the Purposes and also in providing integrated services, maintaining and storing records.

Third parties which we believe would need to have access to your information to provide you with the information or services you request from us such as:

service providers, suppliers, business partners providing administrative, IT or other services appointed by SD Guthrie or any of group of companies of SD Guthrie;
auditors, consultants, lawyers and accountants or any other professional advisers appointed by us on a strictly confidential basis;
advertisers and advertising networks which require certain data to offer relevant adverts to you and/or other selected partners to help them provide better-customised offers, promotions, and/or personalised messages to you or others;
third parties in connection with the sale or transfer of all or any part of our business or assets;
any party in a legal proceeding or potential legal proceeding; or
enforcement agencies, government agencies, courts, tribunals, professional bodies, regulators, ministries (whether at municipal, state or federal level howsoever named in other jurisdictions), if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities.

Transfer out of the EEA and UK
There may be instances where the personal data or information you share with us will be transferred to other countries outside of the EEA and/or the UK. The data protection laws in such countries may not provide the same level of protection for your personal data under the EU and UK data protection laws. In such instances, we are committed to take the relevant steps to ensure that the appropriate safeguards required by law are implemented and your personal data is protected.

Your Rights

Rights
Your rights to your personal data are as follows:

right to access - to request access to the personal data we hold about you;
right to restrict – to ask us to restrict the way we use your personal data;
right to rectification – to ask us to update or correct the personal data we hold about you;
right to erasure – to ask us to delete personal data that we hold about you;
right to withdraw – to withdraw consent for processing of your personal data (if consent is used as the basis for processing);
right to object – to object our processing of your personal data (including for direct marketing purposes); and
right to portability – to request for transfer of your personal data to you or another entity.

Consent and Withdrawal
Where we rely on consent for processing of your personal data, you may withdraw your consent for such processing by reaching out to us using the contact details at Section K below. However, your withdrawal of consent will not affect our right to process your personal data prior to the withdrawal.

Storage of Personal Data

Storage
Information that you share with us is either stored on our secured servers or servers of IT service providers appointed by us. We are committed to maintain appropriate safeguards to prevent loss, misuse, unauthorised access, alteration or destruction of your personal data in accordance with the requirements of applicable laws.

In the event that we transfer your personal data outside of the jurisdiction where you provide us with the personal data, we will put in place the appropriate safeguards to meet the requirements of the applicable laws.

Retention Period
Any personal data retained by us will be destroyed and/or deleted from our records and system in the event such data is no longer required for any of the purposes of which it is collected unless we are required to keep it longer pursuant to any legal or regulatory requirements.

Below are two (2) examples:

tax records will be retained for seven (7) in line with tax retention obligation; and
records of customer complaints received will be retained for six (6) years.

Security of Your Personal Data

We have put in place a variety of technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing.

Complaint

Where you believe that infringement or misuse of your personal data has occurred, you have the right to lodge a complaint with the relevant data protection authority in your country. However, we would encourage you to contact us before making such complaint to the relevant data protection authority so that we are first given the opportunity to understand and resolve your concerns.

Contact Details

If you have any questions, comments or request regarding this Privacy Notice or our processing of your personal data, you can contact us by sending an email to communications@sdguthrie.com or write to us at:

Group Communications
SD Guthrie Berhad,
Level 2, Block A,
Golden Hope Leadership Centre,
No. 2, Jalan PJU 1A/7,
Ara Damansara,
47301 Petaling Jaya,
Selangor Darul Ehsan, Malaysia

Changes or Update to Privacy Notice

We may update, revise, vary, amend and/or modify this Privacy Notice from time to time. Please check back frequently to see the latest changes or update to our Privacy Notice.

Language

In the event of any inconsistencies between the English version and the Bahasa Malaysia version of this Privacy Notice, the English version shall prevail.

Version of this Privacy Notice is as at 2 November 2023.

Privacy Policy