Last Updated 25 May 2022
Rakan Tutor (“Rakan Tutor,” “we,” “us,” “our” or the “Organisation“) and its group entities (collectively, the “Group“) are committed to protecting the privacy and security of your personal information.
It is important that you read the Policy (please ensure you are looking at the most recent version) and any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.
- Who can you contact for privacy questions or concerns?
If you have questions or comments about this Privacy Notice or how we handle personal data, please direct your correspondence to: Rakan Tutor, Unit 79-1, Biz Avenue II @ Neocyber, Lingkaran Cyber Point Barat, 63000 Cyberjaya, Selangor or email firstname.lastname@example.org. We aim to respond within 30 days from the date we receive privacy-related communications.
- How do we collect personal data?
- Directly. We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who correspond with us in any way and form, complete our online forms, subscribe to our newsletter, register for webinars, attend meetings or events we host, visit our offices for recruitment purposes or performance of services in relation to our activities. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.
- Indirectly. We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our partners. We may attach personal data to our management records to better understand the services in connection with our offerings, to satisfy a legal obligation, or to pursue our legitimate interests.
- Public sources. Personal data may be obtained from public registers, news articles, sanctions lists, and Internet searches (including social media).
Social and professional networking sites. If you register or login to our websites using social media or email address to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share or engage with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
- What categories of personal data do we collect?
We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through engagements, from applicants, our partners and through other situations including those described in this Privacy Notice.
- Personal data. Here is a list of personal data we commonly collect to conduct our voluntary services.
- Personal details (e.g., name, gender, Organisation name, job title, work and mobile telephone numbers, work and personal email, current location and postal address).
- Professional details (e.g., job and career history, educational background and professional memberships, published articles).
- Financial information (e.g., taxes, payroll, investment interests, assets, bank details, insolvency records).
- Sensitive personal data. Examples of sensitive personal data we may obtain, or otherwise hold, include:
- Personal identification details that may reveal race, religion or ethnic origin, possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
- Adverse information that may reveal criminal convictions or offences information.
- Information provided to us by our clients in the course of a professional engagement.
- Diversity and equal opportunity information volunteered by participants in certain professional empowerment programmes and onboarding processes.
- Child data. Although we do not intentionally collect information from individuals under 13 years of age, we may occasionally receive details about children attending performances and other events we host with their family or guardians.
Location-based data. We may process geographical locations you enter when arranging or providing services to you.
- What lawful reasons do we have for processing personal data?
We may rely on the following lawful reasons when we collect and use personal data to operate our activity and provide our products and services:
- Contract. We may process personal data in order to efficiently and safely perform our contractual obligations owed to (or to enter into a contract with) the relevant individuals.
- Consent. We may rely on your freely given consent at the time you provided your personal data to us.
- Legitimate interests. We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These may include:
- To deliver the services.
- To deliver timely market insights and speciality knowledge.
- Legal obligations. We may process personal data in order to meet our legal and regulatory obligations or mandates.
- Why do we need personal data?
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
- Performing internal arrangements in connection with the provision of our services.
- Providing services in line with our vision.
- Promoting our services and capabilities to existing and prospective individuals and businesses.
- Personalising online landing pages and communications we think would be of interest.
- Administering, maintaining and ensuring the security of our information systems, applications and websites.
- Authenticating registered volunteers, including background checks for criminal records.
- Processing online requests and queries, including responding to communications from individuals or requests for information.
- Contacting journalists or influencers regarding Organisation press releases, invitations to press parties, highlighting messages that may be of interest on specific topics.
- Helping to support the running of development programs for education and learning purposes.
- Complying with legal and regulatory obligations relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime.
- Compiling health and safety data (directly or indirectly) following an incident or accident. Indirect data can take many forms including an incident report, first aider report, and witness statements.
- Do we share personal data with third parties?
We may occasionally share personal data with trusted third parties to help us deliver efficient, safe and quality services. These recipients are contractually bound to safeguard the data we entrust to them.
- Do we transfer your personal data outside of Malaysia?
We may. Each organisation in receipt of the data is required to safeguard personal data in accordance with our contractual obligations and data protection legislation.
- What are your data protection rights?
- You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
- You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
- You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
- You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
- In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another organisation if it is technically feasible.
- You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
- You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
- You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
If you would like to exercise your Data Subject Rights, you can email email@example.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
- What about personal data security?
We have put appropriate technical and organisational security procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk.
- How long do we retain personal data?
We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of campaign needs or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these purposes, we retain such personal data for seven years.
11. Do we link to other websites?
Our websites may contain links to other sites, including sites maintained by other organisations that are not governed by this Privacy Notice. Please review the destination websites’ privacy notices before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.
12. Do we change this Privacy Notice?
We regularly review this Privacy Notice and will post the updated version on the webpage. This Privacy Notice was last updated on 03 June 2022.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.