Privacy Notice

Personal Data Protection Notice and Choice Principle Notification and Consent
(Customers and Vendors, Suppliers and Third-Parties)
(Pursuant to sections 6 and 7, respectively, of the Personal Data Protection Act 2010)

Last Updated: 2 July 2026

1. Collection and Processing of Personal Data  
‍
We hereby inform you that we, Paramount Corporation Berhad, all our subsidiaries, related corporations (as the term is defined in the Companies Act 2016), affiliates, and associated companies (whether or not controlled by us) ("Company", "we", "our" or "us"), as data controller(s), as the term is defined in the Personal Data Protection Act 2010 (“PDPA”), may or will collect, record, hold, store, use, disclose and/or process (collectively referred to as "Process") any one, or all of the following categories and/or types of personal data about you:

• personal identification: such as name, age, gender, date of birth, citizenship, marital status, nationality, race, ethnic origin, government-issued identification details (e.g. National Registration Identity Card (“NRIC”), passport, driver’s license, visa, work permit, tax file identification number etc.), family composition, signatures;
• contact details: such as home address, mailing address, contact numbers (e.g., home, office or mobile), e-mail address, work address;
• spouse, dependent, and beneficiary information: such as name, age, gender, contact details;
• emergency contact details: such as name and contact details of person to be contacted in case of an emergency;
• background check information: such as background information and credit records;
• employment information (where applicable to customers): such as employment status, job designation, job code;
• audio/visual information: such as recordings from closed-circuit television (“CCTV”) or security systems, photographs, images, voice recordings;
• financial information: such as salary details and allowances, bank account details, insurance details, income tax file numbers, bank statements income details (e.g., income range, bonus, incentives and commission plans), loan details in relation to property purchase, introducer’s name, address and NRIC number;
• technical information such as the information collected when you use our network infrastructure and the technology we make available to you, including, logs of actions in applications you have been granted access to, IP address, device identifiers, computer number, browser type and operating system;
• other information: any such information / personal data you provide to us or collected by us in the course of our business relationship with you.

Website
In addition to the abovementioned types of personal data, when you use our websites, we may or will Process any one or all of the following categories and/or types of personal information about you:

• information obtained from cookies and other technologies: such as information from public databases or data aggregators that may include your demographic information, media consumption, previous purchases, personalisation preferences, shopping habits, search history, loyalty program information or lifestyle preferences; and
• other information: any such information / personal data you provide to us or collected by us in the course of our relationship with you or when you use our website.

We may also Process some or all of the following types of sensitive information about you in connection with your business relationship with us:

(i) religious or similar beliefs;
(ii) political opinions;
(iii) physical or mental health condition;
(iv) the commission of crimes, allegations thereof and / or convictions; and / or
(v) biometric data (fingerprints and/or facial recognition data).

(Collectively, all the above to be referred to as "Personal Data").

If you are a corporate entity / organisation, we may collect any or all of the abovementioned information regarding your employees, officers, or agents.

To the extent that you willfully and voluntarily disclose to us any personal information whether or not coming within the definition of Personal Data above, of any individual, we shall assume, without independent verification, that you have obtained such individual's consent for the disclosure as well as the Processing of the same in accordance with the terms of this notification.

2. Sources of Information

Your Personal Data may be and/or will be collected and obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:

• directly from you before and during the course of ourbusiness / commercial relationship with you, such as written or verbal communications or documents delivered to us (including those prior to and during the course of our contractual or pre-contractual dealings with you, if any), information provided or submitted by you through among others, as applicable the registration form (received via email, facsimile, manual submission or online), sales form or webpage, surveys  or competitions, when you visit or use our premises;
• indirectly, through other sources such as from management corporations, third-party service providers and third-parties connected with you (e.g., your legal representatives, agents, sub-contractors, your employer or employees, etc), and from such other permissible, authorised or publicly accessible sources); and
• as applicable, publicly available or publicly accessible information.

Website
In addition to the above sources, when you use our websites, your Personal Data may be and/or will be obtained:

• when you input or submit your information to our online facilities; and
• from cookies through the use of our website.

As the accuracy of your Personal Data depends largely on the information you provide to us, kindly inform us as soon as practicable if there are any errors in your Personal Data or if there have been any changes to your Personal Data.

3. Purpose of Processing Your Personal Data

We may Process your Personal Data for the following purposes and for such other purposes as required or permitted by law:

Customers or Potential Customers

• responding to your inquiries and managing customer relationships;
• processing your requested products and/or services including preparing the necessary agreements;
• processing your application/participation in connection with any of our loyalty programmes, surveys, promotions, marketing campaigns, contests or events;
• purposes specifically provided for in any particular service or product offered by us;
• facilitating any transactions with us which may include opening of utility accounts, registering ownership and property management (for property purchase);
• facilitating business transactions which may include mergers, acquisitions or asset sales;
• performing marketing, customer profiling and communication of updates, promotions, new products, advertising, commercial materials (via emails, short message services or other means) and/or to be used in, to provide and/or improve our products and services, creating and delivering personalised products and services to enhance customer experience;
• conducting credit assessments and background checks with any registered credit reporting agency for the purpose of processing a transaction with us or for any due and outstanding payments with us;
• our internal record keeping;
• processing invoices, claims, payments (including card payments), collection of outstanding payments;
• purposes connected with the administration, management and/or enforcement of the commercial transaction and for communication with you and/or such other persons or companies as represented by you;
• purposes connected with the operation, development, support or enhancement of our businesses;
• or research, benchmarking, and statistical analysis purposes;
• where a third party acquires or wishes to acquire, or makes inquiries in relation to acquiring, an interest within the Company;
• where a third party requires in order for such third party to perform functions or services as required by us;
• where a third party requires in order for purposes of preparation and submission of any claim or payment to any party or for any audit/checks by any party for whatever purposes related to our businesses;
• purposes connected with the enforcement of our rights pursuant to any letters, agreements and/or documents including seeking legal and/or financial advice, taking any preliminary steps or commencing any legal action;
• conducting internal investigations, audits and security purposes;
• implementing and maintaining our information technology systems, including storing and processing data in computer databases and servers located within and/or outside Malaysia;
• purposes connected with the prevention of crime including but not limited to fraud, money-laundering, bribery; and
• complying with legal or regulatory requirements including disclosure requirements under applicable laws, regulations, directions, court orders, and/or guidelines.

Visitors
When you visit our premises (including offices, showrooms, coworking spaces or restaurants), your Personal Data may be processed for the following purposes:

• verifying your identity for security purposes;
• assisting and directing you to the correct location during your visit to our premises;
• contacting you after your departure from our premises if necessary (such as for lost of personal belongings);
• ensuring your safety and security while at our premises; and
• other related security purposes.

Vendors, Suppliers, Tenants and Service Providers
If you act as our vendor, supplier tenant or service provider, your Personal Data may be collected and Processed for the following purposes:

• building and developing a working relationship with you, including conducting pre-contractual checks, negotiating agreements or contracts, onboarding and registration of you and your employees to our internal IT network or systems;
• assessing and evaluating your performance and compliance with our internal policies, procedures, rules and regulations, handbooks, guidelines and/or codes of conduct;
• administering and giving effect to commercial transactions (tender awards, contracts for services, tenancy agreements);
• managing operational and administrative matters, including responding to your queries or complaints and processing invoices, payments and insurance-related matters;
• ensuring business continuity in the event of agreement / contract termination;
• conducting internal investigations, audits and security purposes;
• maintaining internal records and supporting business development; and
• complying with legal and regulatory requirements including disclosure requirements under applicable laws, regulations, directions, court orders and/or guidelines.
  
  (Collectively, “Purposes”).

4. Storage and Security 

‍We store your Personal Data in hard and/or soft copy. Soft copy data isstored on, amongst others, the file server, e-mail server, personal computers,notebooks, tapes and compact disc.

There are corporate security policies, safeguards and procedures inplace which, among others, restrict access to your Personal Data to authorisedpersonnel only on a strictly need-to-know basis. 

We may retain your Personal Data and that of other individuals that you provide to us for a reasonable period in accordance with commercial requirements and at all times subject to prevailing legal requirements. We will take reasonable steps to ensure the Personal Data is destroyed or permanently deleted if it is no longer required for the purposes stated under Paragraph 3.

5. Disclosure

Your Personal Data will generally be kept confidential, we will not disclose any of your Personal Data to any third party without your consent, except to the following categories of persons (whether located within or outside Malaysia) and only to the extent permitted or required by law:

Customers or Potential Customers and Visitors

• pursuant to an order of a court of competent jurisdiction;
• any person to whom we are compelled or required to do so under law or in response to a legitimate instruction from a competent or government agency;
• where applicable, third-parties who provide related services or products in connection with our business;
• associated companies, any relevant authority, embassies, statutory bodies, regulatory bodies, organisations or any relevant financial institution;
• government agencies, statutory authorities and industry regulators;
• any other person under a duty of confidentiality to us or any company within us;
• actual or proposed assignees or transferees or buyers of any right / businesses / assets of the companies within us;
• our sub-contractors or third-party service or product providers (including those who assist us in providing our website) as we may determine to be necessary or appropriate, such as our legal advisors and/or representatives, partners, joint venture partners, advertisers, purchasers, network operators.

Vendors, Suppliers, Tenants and Service Providers

• other third-party vendors, service or product providers (including those who assistus in providing our website), consultants, sub-contractors, agents, auditors, solicitors, legal advisors and/or representatives, lawyers or other financial or professional advisers, partners, joint venture partners, advertisers, purchasers, network operators engaged by us that require such information as is reasonably necessary for the primary purpose for which it was collected;
• third-party property management companies/entities in respect of the management of property that customers have purchased;
• our appointed service providers in relation to our loyalty programs, for the purpose of delivery of gift redemption and services;
• governmental, legal and/or regulatory authorities in order to comply with legal or regulatory requirements;
• any of our related companies and subsidiaries, including those established in the future, or operational and administrative purposes; and
• such other classes of third-parties whom you have given their consent for the disclosure within the registration form or other such forms.

Additionally, please note that when you use our website, we may use and disclose aggregated non-personally identifying information collected by us as part of our process of constantly improving our website and/or business. 

Please rest assured that, consistent with the law, we will only disclose the minimum amount of Personal Data necessary for the Purpose and that we will take all appropriate safeguards to ensure the integrity and security of your Personal Data.

6. Safeguards  

We shall keep and Process your Personal Data in a secure manner. We will take all reasonable steps to ensure that such information is kept confidential. We will not sell, rent or trade your Personal Data. We endeavour where practicable, to implement the legally mandated and/or appropriate administrative and security safeguards and procedures in accordance with the applicable laws and regulations in order to prevent the unauthorised or unlawful processing of your Personal Data and the accidental loss or destruction of, or damage to, your Personal Data.

Website 
Unfortunately, we cannot ensure or warrant the security of any Personal Data transmitted to us, and individuals doso at their own risk. Once any Personal Data comes into our possession, we will take reasonable steps to protect such information from misuse and lose and from unauthorised access, modification or disclosure. However, given the nature of the internet, no data transmission over the internet can be guaranteed as completely or absolutely secured. 

A username and password may be essential for you to use some sections of our websites. For your own protection, we require you to keep these confidential and to change your password regularly (if required).

Visitors 
When you visit our premises, our CCTV use is not intended to target or monitor to you, but your image may be captured as part of our security functions. Where we collect personal data from you, we will only do so as strictly needed for the fulfilment of any of the purposes set out under Paragraph 3, or as permitted by law. Failure to provide your Personal Data may mean that we are not able to facilitate your presence at our premises.

7. Data Transfer & Sharing

You acknowledge and agree that, given the nature of our products and services, it may be necessary, appropriate, for the purposes of data storage or processing or providing any services or products on our behalf to you, to transfer your Personal Data to our affiliates and/or associated companies and/or thirdparty service or product providers, whether located within or outside the country in which we are established. Any such transfer shall be effected under conditions of confidentiality and similar levels of safeguards that are consistent with the PDPA. You hereby consent to the transfer of your Personal Data outside Malaysia to the classes of third-parties listed under Paragraph 5 and for the purposes listed under Paragraph 3

8. Impact Resulting from Failure to Supply and Consent to the Processing of Personal Data  

It is obligatory for you to provide all of the Personal Data which we request from you for the said Purposes. Failure to provide and consent to the Processing of the Personal Data in relation to the Purpose may result in the following consequences:

Customers or Potential Customers

• we may be unable to provide you with the information, notices, services and/or products requested;
• it may affect the ability of the parties to enter into the necessary Sales and Purchase Agreement in relation to the sale of property; and/or
• it may result in us and/or our selected authorised third-parties becoming unable to send you information by e-mail, telecommunication means (telephone calls and text messages) or via social media concerning related and unrelated products and services offered by us and our affiliated business partners which we consider will or may interest you.

Website

• your application or request to us for any of the above purposes as setout under Paragraph 3 above may not be accepted or acted upon;
• your request to browse some information on our website may be denied; or
• we will not be able to provide the full range of benefits and/or services and/or perform its obligations under any potential or existing contract with you.

Vendors, Suppliers, Tenants and Service Providers 

It may be difficult for us to maintain our business relationship with you and carry out business with you.

9. Your Rights of Access and Correction

You have the right to, subject to payment of the prescribed fees where applicable, request access to and/or correct your Personal Data and/or limit the Processing thereof. In this respect, you may:  

• check whether we hold or use your Personal Data and request access to such data;
• request that we correct any of your Personal Data that is inaccurate, incomplete or out-of-date;
• request that your Personal Data is retained by us only as long as necessary for the fulfilment of the purposes for which it was collected;  
• request that we specify or explain our policies and procedures in relation to Personal Data and the categories of Personal Data processed by us;
• withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period;
• request that your Personal Data be transmitted directly to any data controller subject to technical feasibility or compatibility of format.

If you wish to exercise any of the above rights, please submit your request in writing to the contact details below:
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For Scalable:

• Department: Administration Office
• Email Address: hello@scalable.com.my
• Address: Level 12, Tower B, Pusat Perdagangan DataranAtwater, Jalan Profesor Diraja Ungku Aziz, 46200 Petaling Jaya, Selangor Darul Ehsan.

Please note that notwithstanding the withdrawal of your consent, we may still Process your Personal Data in circumstances recognised and permitted by law and as required under the contractual conditions.

10. Website Specific Terms

When you use or access any of our websites, these sections will also apply to you:

• Email and “Contact Us” Messages
  
  We may preserve the content of any email or “Contact Us” or other electronic message that we receive. Any Personal Data contained in those messages will only be used or disclosed in ways set out in this Privacy Notice. The message content may be monitored by our service providers or employees for purposes including compliance, auditing and maintenance or where email abuse is suspected.
• Communications or Utilisation Data
  
  Through your use of telecommunications services to access our websites, your communications data (e.g. Internal protocol address) or utilisation data (e.g. information on the beginning, end and extent of each access, andinformation on the telecommunications services you accessed) are technically generated and could conceivably relate to Personal Data. To the extent that there is a compelling necessity, the collection, processing and use of your communications or utilisation data will occur and will be performed in accordance with the PDPA.
• Non-Personal Data Collected Automatically
  
  When you access our websites, we may automatically (e.g. not by registration) collect non-personal data (e.g. type of Internet browser and operating system used, domain name of the website from which you came, number of visits, average time spent on the site, pages viewed) and etc. We may use this data and share it with our holding, related and associate companies to monitor the attractiveness of our website and improve their performance or content.
• Cookies
  
  When you view our websites, we may store some data on your computer in the form of a “cookie” to automatically recognise your personal computer next time you visit. Cookies can help us in many ways, for example, by allowing us to tailor a website to better match your interests or to store your password to save you having to re-enter it each time.
  
  If you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer’s hard drive, block all cookies or to receive a warning before a cookie is stored.
• Links 
  
  ‍Our website may contain links to other websites and pages. By activating a link, such as for example by clicking on the banner of an advertiser, you will be directed out of our website and we do not exercise control over any Personal Data or any other information that you give to any other entity after leaving our website. We are not responsible for the content on such websites and pages.
• Confidentiality 
  
  Any questions, comments, suggestions, or information other than Personal Data submitted to us in whatever manner (including those sent or posted in our website) will be deemed voluntarily provided to us on non-confidential and non-proprietary basis.

11. Amendments to this Privacy Notice 

We reserve the right to update and amend this Privacy Notice from time to time. If we amend this Privacy Notice, the amendment will only apply to Personal Data collected after we have posted the revised Privacy Notice.

12. Language 

This Privacy Notice is issued in both English and Bahasa Malaysia pursuant to the requirements prescribed by Section 7(3) of the PDPA. In the event of any inconsistencies or discrepancies between the English version and the Bahasa Malaysia version, the English version shall prevail.