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Personal Data Protection Notice (PDPA)

(Pursuant to sections 7 and 6, respectively, of the Personal Data Protection Act 2010)

1. Collection and Processing of Personal Data
We hereby inform you that we, Paramount Property Division Group which includes but not limited to the following companies:
(i) Paramount Property Development Sdn Bhd
(ii) Paramount Property (CJaya) Sdn Bhd
(iii) Paramount Property (Glenmarie) Sdn Bhd
(iv) Paramount Property (Shah Alam) Sdn Bhd
(v) Paramount Property (PG) Sdn Bhd
(vi) Paramount Property (Utara) Sdn Bhd
(vii) Paramount Property (Sepang) Sdn Bhd
(viii) Paramount Property (PW) Sdn Bhd
(ix) Seleksi Megah Sdn Bhd
(x) Berkeley Sdn Bhd
(xi) Kelab Bandar Laguna Merbok Sdn Bhd
(xii) Paramount Coworking Sdn Bhd

being the respective Paramount Corporation Berhad related corporations (as the term is defined in the Companies Act 1965), affiliates, and associated companies (whether or not controlled by us) ("Company", "we", "our" or "us"), as data user[s], as the term is defined in the Personal Data Protection Act 2010, have or will collect, record, hold, store, use, disclose and/or process (collectively referred to as "Process")
one, or all of the following categories and/or types of personal information about you:

(a) master data: name, gender, date of birth, citizenship, marital status, nationality, race, ethnic origin, identification card /passport details, qualifications, occupation, employer, former employer(s), photographs or other images, and voice recordings;
(b) contact details: home address, home phone number and mobile number, email address, work address, work number;
(c) compensation information: such as amount, currency, number of payments per year, bank account details, income tax file numbers, income range; details of applicable bonus, incentives and commission plans, types of loans applied for in relation to a purchase of property,
as well as introducer's name, address and identity card number;
(d) any such information as we deem necessary or appropriate from time to time in connection with your commercial relationship with us. (collectively, "Personal Data").
To the extent that you wilfully 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 has and/or will be obtained from the following sources, where applicable, or such other sources which we may see fit from
time to time:
(a) information provided or submitted by you through among others, as applicable the registration form (received via email, facsimile, manual submission, online), sales form, webpage;
(b) as applicable, publicly available or publicly accessible information; and
(c) such other written or verbal communications or documents delivered to us prior to and during the course of our contractual or precontractual dealings with you.
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 Personal Data
We will Process the Personal Data that you have provided to us for the following purposes, including but not limited to:
(a) the delivery of notices, services or products to you;
(b) in order for you to enter into the necessary agreement and/or contract to purchase the products and/or properties (for real estate customers only) and/or subscribe the services from us;
(c) user or customer relationship management procedures;
(d) those purposes specifically provided for in any particular service or product offered by us;
(e) credit assessments and other background checks of users as we may determine to be necessary or appropriate;
(f) our internal record keeping;
(g) collection of outstanding payments from clients and/or customers;
(h) prevention of crime including but not limited to fraud, money-laundering, bribery);
(i) meeting any legal or regulatory requirements relating to our provision of services and products and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular, code applicable to us or any of our
member companies;
(j) vacant possession, keys handover, property/estate management, customer care and/or defect rectification works;
(k) conducting marketing and client profiling activities in connection with our services and related products;
(l) for research, benchmarking, and statistical analysis purposes;
(m) post vacant possession delivery-related services, such as club house services, security and customer loyalty programmes, and/or
(n) to enable us and/or our selected authorised third parties to send you information by e-mail, telecommunication (telephone calls and text messages) or via social media concerning related and unrelated products and services offered by us and our business partners which may include but is not limited to the abovementioned purposes which we consider will or may interest you.
(collectively, "Purpose")

4. Storage and Security
We store your Personal Data in hard [and/or] soft copy. Soft copy data is stored on, amongst others, the file server, e-mail server, personal computers, notebooks, tapes and compact disc.
There are corporate security policies and procedures in place which among others confines access to your Personal Data to authorised personnel only on a strictly need to know basis to the relevant department such as the [administration, legal, finance, sales and/or customer service] departments of the Company.
We may retain the 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.

5. Disclosure
Personal Data provided to us will, generally, be kept confidential but you hereby consent and authorise us to provide and /or disclose your Personal Data to the following categories of parties:
(a) 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;
(b) pursuant to an order of a court of competent jurisdiction;
(c) any related companies and subsidiaries of Paramount Corporation Berhad, including-those established in the future;
(d) where applicable, third parties who provide related services or products in connection with our business;
(e) government agencies, statutory authorities and industry regulators;
(f) our auditors, consultants, accountants, lawyers or other financial or professional advisers;
(g) our sub-contractors or third party service or product providers or agent as may determine to be necessary or appropriate;
(h) third party property management companies/entities in respect of the management of property that customers have purchased; and/or
(i) our appointed service providers in relation of our loyalty programs, for the purpose of delivery of gift redemption and services. Please rest assured that consistent with the law, we will only disclose the minimum amount of information which we deem necessary for the Purpose and that we will take all appropriate safeguards to ensure the integrity and security of the Personal Data.

6. Safeguards
We shall keep and Process your 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 endeavor 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.

7. Data Transfer &Sharing
In addition, you will appreciate that the nature of our products and services are such that it may be necessary, where we consider it appropriate, for the purposes of data storage or Processing or providing any service or product on our behalf to you, to transfer your Personal Data to our affiliates and / or associated companies and/or third party service or product providers within or outside the country in which we are established, under conditions of confidentiality and similar levels of safeguards.

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 categories of Personal Data which we request from you for the said Purpose. Failure to supply and
consent to the Processing of the Personal Data in relation to the Purpose will:
(a) result in us being unable to provide you (i.e. customers/ prospective customers) with the information, notices, services and/or products requested;
(b) affect the ability of the parties to enter into the necessary Sales and Purchase Agreement and any other agreements in relation to the sale
of property and/or any services agreement or membership agreement in relation to the subscription of services; and /or
(c) result in us becoming unable us and/or our selected authorised third parties 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.

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:
(a) check whether we hold or use your Personal Data and request access to such data;
(b) request that we correct any of your Personal Data that is inaccurate, incomplete or out-of-date;
(c) 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;
(d) request that we specify or explain our policies and procedures in relation to Personal Data and the categories of Personal Data processed by us;
(e) 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.

The department to whom written requests for access to Personal Data or correction and/or deletion of Personal Data or for information regarding policies and procedures and types of Personal Data is:

Department Name: Administration Office
Contact No:  603 8408 1688
Email Address: hello@scalable.com.my
Address: Suite 88, Co-labs Coworking The Starling, Lot 4-401 & 4-402, Level 4, The Starling Mall, No. 6, Jalan SS21/37, Damansara Uptown, 47400 Petaling Jaya, Selangor, Malaysia.