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PRIVACY POLICY AND PERSONAL DATA NOTICE

POTO Leisure Group Sdn Bhd (“POTO”) recognises the importance of protecting your personal information and is committed to the compliance of the Malaysian Personal Data Protection Act 2010 (“Act”). This Privacy Policy and Personal Data Notice explains how we collect and handle your personal information in accordance with the Act. 

1. Personal information

1.1 Type of personal information

Personal information means any information which relates to you and which was collected or provided to POTO for the purposes stated in Section 2 below.

The personal data includes but is not limited to the following information:

  1. name, job title and company name;
  2. age, gender, date of birth, national registration identity card number, passport number;
  3. race, ethnic origin, nationality;
  4. contact information including address, email address, social media address and phone number;
  5. marital status, details of spouse or children or immediate family, education, occupation, income range, employer name and contact details;
  6. income range and financial and banking account details;
  7. photographs; and
  8. such other relevant information from time to time requested by POTO to enable us to provide you with our services and products, or to enter into business/contractual transactions (including employment, where relevant) with you.

1.2 Source of personal information

  1. Customer or potential customer: POTO collects your personal information directly from you or indirectly via completed enquiry, application and/or registration forms via various means, including online and physical hardcopies at public venues or in any of our premises.  Your personal information may also be collected from cookies through the use of our website or at any of our marketing events.
  2. Vendor, supplier, tenant or service provider: POTO collects your personal information directly from you or indirectly when you send us completed enquiry and/or credit application forms via various means, including online and physical hardcopies.  Your personal information may also be collected from cookies through the use of our website or at any of our marketing events.
  3. Employee: POTO collects your personal information directly from you or indirectly via completed enquiry and/or job application forms via various means, including online and physical hardcopies. Your personal information may also be collected via background checks customarily conducted in respect of employees.

We may also verify or source personal information about you from third party sources (both public and private) such as credit reporting agencies, Companies Commission Malaysia and the Insolvency Department of Malaysia.

1.3 Obligatory personal information

All information requested for in the relevant forms is obligatory to be provided by you unless stated otherwise.

Should you fail to provide the obligatory information, we would be unable to process your request and/or provide you with the relevant services or enter into business/contractual transactions (including employment) with you, as the case may be.

(2) Personal data collected for the following purposes:-

  1. To give effect to your requested provision of services or enter into business/contractual transactions (including employment) with you;
  2. To effect bookings with airlines, and for purposes of making ground arrangements (including accommodation, transfers and tours), to effect purchase of insurances and applications for visas, and for operational requirements (including name tags, luggage tags, etc) and all other purposes directly or indirectly relating to travel arrangements;
  3. To keep you well informed of new services and/or events offered by us through various communication channels, including by way of email or normal post, or postings on social media channels and on our flyers, brochures, buntings and/or other marketing or promotional material);
  4. To facilitate your participation in any contests or in any of our promotional and marketing events, including;
  5. To process any payments related to your requested services/transactions;
  6. To operate our premises in a manner which is physically safe, secure and befitting of health and safety requirements;
  7. For internal investigations, external credit checks, audit or security purposes;
  8. To  conduct  internal  marketing  analysis  and  analysis  of  customer  patterns  and choices and other research and insight purposes;
  9. To  comply with  POTO’s legal  and  regulatory  obligations in the conduct  of  its business;
  10. To  contact  you  regarding  our services,  upcoming  events,  promotions, advertising, marketing and commercial materials which we may feel to be of interest to you;
  11. To ensure that the content from our website is presented in the most effective manner for you and your computer and/or device;
  12. For POTO’s internal records management, customer relations events and activities, and customer loyalty reward program;
  13. To process your credit account application & to assess your credit worthiness,
  14. To enforce our legal rights and/or obtaining legal advice wherever necessary;
  15. To adhere to our human resource policies in respect of employees of POTO;
  16. For any ancillary purposes directly related to the above.

 

(collectively “the Purposes”)

The personal data collected will be retained by us for the duration required / permitted under Malaysian law, which may extend to periods after termination of your contractual relationship with us. In accordance with the Act, it shall be the duty of POTO to take all reasonable steps to ensure that all personal data is destroyed or permanently deleted if it is no longer required for the Purposes stated herein.

(3) Disclosure of personal information

3.1 Entities within POTO

Your personal information provided to us is processed by entities (in or outside of Malaysia) within POTO (including related companies, subsidiaries, holding companies, associated companies and outsourcing partners).

POTO will maintain the security of your personal data as follows:-

  1.  access to your personal information is restricted to relevant staff on a need-to-know basis;
  2. maintain adequate security control systems to safeguard the confidentiality and security of your personal data;
  3. take reasonable steps to ensure that the personal data is accurate, complete, not misleading and kept up-to-date by having regard to the Purposes herein, including any directly related purposes, for which the personal data is collected and processed;
  4. Where we appoint third party service providers, agents or contractors to provide services to us, we ensure that these third parties observe similar security measures as adopted by us.

POTO may disclose your personal data to:-

  1. Our directors and officers for purposes relating to your use of our services or pertaining to our business/contractual relationship;
  2. Regulatory bodies such as the Companies Commission of Malaysia and other relevant authorities which have oversight over our activities;
  3. Our auditors, lawyers, consultants and other advisors;
  4. Any party to whom POTO’s rights are legally assigned/novated and/or transferred;
  5. Third party service providers, agents or contractors that the POTO engages for the Purposes set out in Section 2;
  6. Any other party to whom such disclosure is required by law or regulatory requirement; and
  7. Any other persons under a duty of confidentiality to POTO,

Notwithstanding that any such persons may be outside Malaysia, for any of the above Purposes or any other purpose for which your personal data was to be disclosed at the time of its collection or any other purpose directly related to any of the above Purposes.

(4) Websites

4.1 Links to other sites

We are not responsible for the content on the linked sites or any use of the site that was provided for your convenience and information.  However, these sites may have their own privacy statement in place, which we recommend you to review if you were to visit any such linked websites.

4.2 Location enabled products or applications

Location enabled features are opt-in and you have control over your participation and can turn these services off at any time or uninstall them.

4.3 Cookies

A cookie may be used in the processing of your information. A cookie is a text file placed into the memory of your computer and/or device by our computers. A copy of this text file is sent by your computer and/or device whenever it communicates with our server. We use cookies to identify you. We may also collect the following information during your visit to our website and/or the fully qualified domain name from which you accessed our site, or alternatively, your IP address:

  1. the date and time you accessed each page on our web site;
  2. the URL of any webpage from which you accessed our site (the referrer); and
  3. the web browser that you are using and the pages you accessed.

Some web pages may require you to provide a limited amount of personal information in order to enjoy certain services on our websites (system login credentials, email address and contact, etc). These personal information will only be used for its intended purposes only, i.e. to respond to your message or deliver the requested services.

(5) Right to access and correct personal information

In accordance with the provisions of the Act, you may:

  • check whether POTO holds data about you and of access to such data;
  • request POTO to correct any data relating to you which is inaccurate, incomplete, misleading or not updated;
  • request clarification on POTO’s policies and practices in relation to any personal data held by POTO,except where compliance with a request to such access or correction is refused under the Act.

In accordance with the Act, POTO has the right to charge a fee for the processing of any data access request.

You may request for access to or correction of data or for information regarding policies and practices and kinds of data held, by mail to the address stated in Section 6 below.

(6) Amendments and Contact details

POTO reserves the right to amend this Privacy Policy and Personal Data Notice at any time and will place notice of such amendments on its website at www.pototravel.com.my or notify you via email or any other suitable mode of communication.

Complaints or enquiries relating to any matter concerning your personal data can be made to the following personnel:-

Norita Muhamad
POTO Leisure Group Sdn. Bhd.
68-4-3, Aras 4, Dataran Shamelin
No. 68, Jalan 4/91
Taman Shamelin Perkasa
Jalan Cheras
56100 Kuala Lumpur

(7) Miscellaneous 

  1. Where you are a partnership or other unincorporated body of persons, the giving of this Privacy Policy and Personal Data Notice addressed to the partnership or other unincorporated body of persons shall be deemed as a notice given to all your partners or office-bearers (as the case may be) whose data are collected and/or process by POTO for the Purposes stated herein. In this regard, you warrant that you have obtained the consent of all such individuals to the provision of their data to POTO for the foregoing Purposes and for disclosure to such parties as stipulated above and you undertake to extend a copy of this Privacy Policy and Personal Data Notice to all such individuals, which expression shall include all your existing and new partners or office-bearers (as the case may be) from time to time.
  2. This Privacy Policy and Personal Data Notice shall also apply (as the context shall require) in relation to the usage, processing and disclosure of the data of any other individual who is not a customer, potential customer, vendor, supplier, tenant or service provider as set out in Section 1.2 but whose data is required to be collected by POTO by reason of, or incidental to the provision of the services requested to be provided to you. In this regard, you confirm and warrant that you have obtained the consent of such individuals to the provision of such data to POTO for the foregoing Purposes and for disclosure to such parties as stipulated above.
  3. Nothing in this Privacy Policy and Personal Data Notice shall limit your rights under the Act.
  4. Your continued usage of the services and/or facilities of POTO and/or continuous business/contractual relationship with POTO shall be deemed consent for POTO to collect, process and store the data in accordance with the above. Failure to consent to the above may result in POTO being unable to provide the services and/or facilities to you or to continue with the business/contractual relationship with you.
 
     
 
 
 
 
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