This Privacy Policy is formulated to comply with the requirements of the Personal Data Protection Act 2010 (“Act”). For the purpose of this Privacy Policy, “personal data” shall have the meaning as ascribed to it in the Act, the term “we”, “us” and “Villamas Group” shall include Villamas and its subsidiaries, related companies and affiliates and the term “you” refers to yourself including persons represented by you, customers, visitors and users of this website.
This Privacy Policy sets out how Villamas Group uses and protects any personal data that you provide Villamas Group either electronically or otherwise via this Website or directly to Villamas Group. As a data user we wish to assure you that we respect your privacy and are committed to maintaining, observing and safeguarding the confidentiality of your personal data.
This Privacy Policy is not intended to, nor does it create any contractual rights whatsoever or any other legal rights, nor does it create any obligation on Villamas Group in respect of any other party or on behalf of any party.
Villamas Group reserves the right to amend this Privacy Policy from time to time without prior notification to reflect changes in the applicable law, our business or Website. You should therefore review this Privacy Policy periodically to ensure you are familiar with its terms. In the event material changes are made to the Privacy Policy we will notify you by placing a prominent notice on this Website.
1. PERSONAL DATA COLLECTED
1.1 Personal Data which Villamas Group collects includes:-
– any information collected or obtained such as your name, email address, telephone number, home address, date-of-birth, national registration identity card number, passport number, occupation, banking details and such other persona information provided to any member of the Villamas Group;
– any information collected or obtained through whatsoever means including such as when you register online via this Website, which may include personal data such as your name and contact details;
– the content of any forms electronic or otherwise that you may submit via email or through any other means requesting us to provide services or information, or to take any actions;
– information submitted if you participate in our surveys or competitions organized by any member of the Villamas Group via online or otherwise;
– any messages or comments you submit via this Website, which may include personal data such as name, email address and telephone number; and
– personal information collected when you submit your resume or application to us for consideration of employment or when you submit your company profile or credential for the purpose of introduction of services and/or products to us
2. CONSENT AND PURPOSE OF COLLECTION
2.1 By providing any of your personal data to Villamas Group whether online or otherwise, you acknowledge that you have read, understood and agree to our Privacy Policy and you consent to the collection, retention and use of your personal data by us for any of the following purposes:
– fulfilling contractual obligations in delivering our products and /or properties and/or services and/or fulfilling your instructions and providing you with services under any of Villamas Group’s business;
– processing your application to purchase our products and /or properties and / or enter into necessary agreement and /or contract under any of Villamas Group’s property development and/or other businesses;
– marketing of products and/or services and/or properties and/ or customer loyalty program and sending any advertising and/or promotional material to you via any communication method including without limitation telephone calls, short message services, postal service, emails or if you have checked the consent box in the Property Registration & Enquiry Form, Leasing Form and Corporate Information & Career Form on this Website;
– propose to carry out the user or customer relationship management procedures and/or analysis and/or promotional activities;
– conducting research on planning, profiling, product, goods, services, properties, and testing for any Villamas Group;
– notifying you of special offers, promotional packages, current and future products, and/or properties and/or services that we consider might be of interest to you and for similar updates and promotions via our Newsletter and / or any communications platform and/ or social media and / or applications and/or emails by us and/or products and services offered by the appointed third parties;
– performing statistical, benchmarking and analysis of your interest in and use of the various sections of this Website and / or Villamas Group’s businesses;
– purposes connected with the operation, administration, development or enhancement of Villamas Group’s business and/or this Website that not limit to credit assessment/ background checks/ collection of outstanding payment/ internal record keeping/ prevention of crime such as fraud, money-laundering and bribery;
– where required by law, where we consider that such use or disclosure is necessary to respond to any claims or legal process, or where Villamas Group suspects that fraud or unlawful activity has been, is being or may be engaged in;
– making such disclosures as may be required for any of the above purposes or by law;
– where you have provided your resume, considering you for any jobs that may arise in Villamas Group, and if applicable your terms and conditions of employment; and
– carry out studies to monitor Villamas Group’s recruitment initiatives.
2.2 Please note that in the event that sufficient personal data is not supplied, or is not satisfactory to the Villamas Group then your application or request to the Villamas Group for any of the above purposes under clause 2.1 may not be accepted or acted upon.
3. DISCLOSURE
3.1 You further consent that personal data may be disclosed and transferred within the Villamas Group which may include transfer to other parts of the Villamas Group in different jurisdictions. Other than to those individuals and entities listed in clause 3.2, your personal data will not be revealed by Villamas Group to any external party, unless we have your permission, or in some cases, to disclose information to governmental or other regulatory authorities for the prevention or detection of crime, or for the purpose of investigations or for compliance with any other law or an order of court. In such event, we may be precluded from seeking your consent to notify and/or from informing you that notification has been made.
3.2 The personal data provided by you may be disclosed by Villamas Group to:
– Any one or more of the members of the Villamas Group.
– Villamas Group’s Agents and Contractors acting on our behalf.
– Any relevant financial institutions.
– Any referee whose details are provided by you, to verify or obtain additional information including education institutions, current/previous employers.
– Credit Reference Agencies.
– Third Party Service Providers (including management of this Website), for Villamas Group’s operational, administration and development requirements.
– Auditors, lawyers, professional advisory, debt collectors, bankers, advertising companies, recruitment agencies, researchers, utility and security services to use, disclose, hold, process, retain or transfer such personal data for the purposes of (2.1) above for and on behalf of Villamas Group
– Any related affiliated, holding, subsidiaries and successors in title of Villamas Group including those established in the future.
– Related business partners and affiliates of Villamas Group.
– Auditors, consultants, accountants, solicitors, professional advisers, contractors, sub-contractors, appointed third party service or product providers as may determine to be necessary or appropriate.
– Any related third party property or estate management companies / entities in respect of the management of property that customers have purchased and any appointed service providers of Villamas in relation of the loyalty program.
– Companies who provide utilities services.
3.3 Each of the above parties, other than Regulators and your referees, are similarly bound by a duty of confidentiality to Villamas Group in respect of all information disclosed to them.
3.4 Villamas Group uses and discloses aggregated non-personally identifying information collected through this Website as part of Villamas Group’s process of constantly improving this Website and/or Villamas Group’s business.
4. SECURITY
4.1 We have put in place appropriate physical, electronic, and administrative procedures to safeguard and help prevent unauthorized access, disclosure, loss, misuse and to maintain data integrity.
4.2 All reasonable precautions are taken to secure your personal data but we cannot guarantee that your information will never be disclosed in a manner inconsistent with this Privacy Policy due to unauthorized or illegal acts of third parties in violation of existing laws or the policies of Villamas Group.
5. STORAGE AND RETENTION OF THE PERSONAL DATA
5.1 Your personal data shall be stored either in hard copies in Villamas Group’s offices or stored in servers located in Malaysia and operated by Villamas Group or its service providers.
5.2 Any personal data supplied by you will be retained by Villamas Group as long as necessary for the fulfillment of the purposes stated in clause 2.1 above or is required to satisfy legal regulatory, accounting requirements or to protect Villamas Group’s interests. As a general rule the maximum retention period is 7 years.
5.3 Villamas Group does not offer any online facilities for you to delete your personal data held by Villamas Group.
5.4 Villamas Group will take reasonable steps to protect your personal data from misuse and loss and from unauthorized access, modification or disclosure.
6. COMMUNICATION OR UTILIZATION DATA
6.1 Through your use of telecommunications services to access this Website, your communications data (e.g. Internet protocol address) or utilization data (e.g. information on the beginning, end and extent of each access, and information on the telecommunications services you accessed) are technically generated and could conceivably relate to personal data.
6.2 To the extent that there is a compelling necessity, the collection, processing and use of your communications or utilization data will occur and will be performed in accordance with the applicable data privacy protection legal framework.
7. CONFIDENTIALITY
7.1 Personal Data held by the Villamas Group will be kept confidential in accordance with this Privacy Policy pursuant to the Act.
7.2 Any questions, comments, suggestions or information other than personal data sent or posted to this Website, or any part of the this Website by visitors will be deemed voluntarily provided to the VILLAMAS Group on a non-confidential and non-proprietary basis.
7.3 The Villamas Group reserves the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely as set out in clause 3.2 above.
8. RIGHT OF ACCESS TO PERSONAL DATA
8.1 Under the Act, you have the right of access to your personal data held by the Villamas Group on payment of a prescribed fee and to request correction of the personal data that is inaccurate, incomplete, misleading or not up-to-date.
8.2 If you have any questions regarding this Privacy Policy or if you wish to request access to or correct your personal data or if you wish to withdraw your consent to the Villamas Group for the processing of your personal data for the purposes as set out in clause 2.1 above or for the transfer of your personal data to the parties stated in clause 3.2 above, you may send your request in writing to the following address:
The Personal Data Protection Officer
Villamas Group
B-2-6, Plaza TTDI, Jalan Wan
Kadir 3, Taman Tun Dr Ismail,
60000 Kuala Lumpur, Malaysia.
Email: info@villamas.lead3.my
Tel: 03-8957 8883 / Fax: 03-8958 6222
8.3 Villamas Group reserves the right to charge you a reasonable fee for the processing of any data access request.