BUKIT UTAMA COUNTY SDN BHD (BUC) (Company No. 355991-A) respect the privacy of individuals with regards to Personal Data. This privacy policy is prepared and formulated in accordance with the Personal Data Protection Act 2010 (“the Act”). For the purpose of this privacy policy, “Personal Data” shall have the meaning as ascribed to in the Act. BUC is committed to processing your personal data within the ambit of the Act.

Scope of the Act

The Act primarily aims to regulate the collection, holding, processing and use of Personal Data in commercial transactions and also to prevent malicious use of personal information. This Act plays a crucial role in safeguarding the interest of individuals and makes it illegal for anyone, be it corporate entities or individuals, to sell personal information or allow such use of the data by third parties.

The Act only applies to the processing of personal data in respect of “commercial transactions”. A commercial transaction is widely defined as any transaction of a commercial nature, whether contractual or not which includes any matters relating to the supply or exchange of goods or services, agency, investments, financing, banking and insurance. There must be a commercial element in the processing of the personal data to attract the application of the said Act.

What Personal Data Do We Collect?

BUC will collect certain Personal Data when you sign up with BUC as a Club Member and any additional information required from time to time in connection with the provision of services, obtaining of feedback or conducting of surveys related to the Club Membership.

The Personal Data which BUC may collect are as follows:

(1) Name

(2) NRIC number

(3) Gender

(4) Date of birth

(5) Address

(6) Telephone number

(7) E-mail address

(8) Marital status

(9) Nationality

(10) Race

(11) Photograph

(12) Particulars of family members

What is the Purpose of the Collection of Personal data?

By providing your Personal Data to BUC herewith, you hereby agree that BUC shall collect, retain and use the Personal Data for the purposes stated below and where required by law, where BUC consider that such use or disclosure in necessary to respond to any claims or legal process, or where BUC suspects any form of fraud or unlawful activity.

(1) Notification of critical alerts, special offers, new services and products, updates and promotions of Tenants in 1 Utama Shopping Centre, Centrepoint Bandar Utama, The Club /or other related corporations of BUC.

(2) Conducting surveys and research of spending pattern of consumers to develop new products and services and/or other related surveys/researches.

(3) Communication of any information pertaining to products and services under the related corporations of BUC.

Do We Share and Disclose Your Personal Data?

BUC does not sell, rent, lease or otherwise disclose your Personal Data to third parties unless otherwise stated organisational security measures when processing the Personal Data collected.

Selected Personal Data may be shared with entities participating in and/or providing services for the Club (including tenants, consultants, agents, data processors and vendors) for use in connection with notification of special offers, new services, updates and promotions by The Club and tenants at our Club House and by other related corporations of BUC; and conducting of customer satisfaction survey of our members and guests to gather feedback to improve the quality of our  offerings and services.

What Happens If You Decide Not To Provide Personal Data?

Should you decide not to provide the personal data required, BUC is unable to proceed with the application for Club Membership and reserves the right to cease the processing of the application and issuance of the Club Membership Cards.

What Steps Are Taken to Safeguard the Security and Safety of Your Personal Data?

BUC is required under the Act to protect and safeguard your Personal Data by taking practical steps to implement security measures thereto, i.e. to protect your Personal Data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction.

BUC have assigned specific responsibilities to address privacy and security related manners and do enforce our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, training and assessments. BUC takes appropriate steps to address online security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected. Further, BUC takes steps to limit access to our data bases containing Personal Data to authorized persons having the justified need to access such information.

How Long Do We Retain Your Personal Data?

The Personal Data shall not be kept for longer than is necessary. Whilst the Act does not stipulate the time frame allowed for storage of your Personal Data, BUC shall destroy and/or permanently delete your Personal Data once it is no longer required for the purpose for which it was processed.

Your Rights

The Act accords five (5) rights to individuals to safeguard their Personal Data as listed below:

(1) The Right of Access Personal Data

Subject to the provisions of the Act, you have the right to access your Personal Data and/or to correct your Personal Data with BUC should you believe that the Personal Data provided is incorrect, outdated, inaccurate or incomplete. You may access to your Personal Data at the contact particulars provided below.

(2) The Right to Correct Personal Data

You may request for the Personal Data provided to be deleted and/or corrected if the data is inaccurate, incomplete, misleading or not up-to-date at the contact particulars provided below.

The integrity of the Personal Data which is collected is a crucial element in the Act. BUC shall take reasonable steps to ensure that the Personal Data is accurate, complete, not misleading and kept up-to-date.

(3) The Right to Withdraw Consent

The consent which you have granted in respect of the processing of your Personal Data may not necessarily endure forever, as you may by notice in writing to the contact particulars provided below withdraw the

consent granted. BUC shall cease processing of your Personal Data upon receipt of your notice.

You are entitled to withdraw your consent at any time.

BUC shall be required to obtain your explicit consent in the event that “Sensitive Personal Data” is being processed by BUC and “Sensitive Personal Data” shall include medical history, political opinions, religious beliefs and commission or alleged commission of any offence.

(4) The Right to Prevent Processing for the Purposes of Direct Marketing

BUC shall process your Personal Data in strict adherence to the consent which you have granted in respect of the processing of your Personal Data. As such, BUC shall never process data for purposes of direct marketing where such purpose has not been identified and consent has not been obtained from you.

Should you receive marketing materials from BUC via short messaging service (SMS), e-mails, telephone and/or by post and you wish to discontinue such receipt of marketing information, you may provide BUC with a “opt out” notice to remove/delete your Personal Data from BUC’s database. Once an “opt out” notice has been received from you, BUC shall within a reasonable time remove/delete your Personal Data from our database.

(5) The Right to Prevent Processing which is likely to cause Damage or Distress

We reiterate that BUC shall process your Personal Data only where you have granted your consent for the processing of your Personal data for the abovestated purposes only.

You have the absolute right to prevent the processing of your Personal Data where your consent has not been obtained for such specific purposes and such processing of your Personal Data will cause or is likely to cause substantial unwarranted damage or distress to you or another person.

Change/Amendments to this Privacy Policy

BUC may from time to time change this Privacy Policy. However, if the changes made are material, BUC will post a notice advising of such change at the beginning of this Privacy Policy and use reasonable means to communicate to you such change within twenty one (21) days from such change.

You may at any time hereafter make written enquiries about this Privacy Policy and/or to enforce any of the abovestated five (5) rights by contacting BUC via post, telephone, fax or e-mail at:

Bukit Utama County Sdn Bhd

1, Club Drive, Bukit Utama,

Bandar Utama, 47800,

Petaling Jaya

Selangor Darul Ehsan

Malaysia

Tel (03) 77255199

Fax (03) 77265199

E-mail: info@theclub.com.my