FUJIFILM (MALAYSIA) SDN. BHD. EXTERNAL DATA PROTECTION POLICY

1.  We value the privacy and confidentiality of the personal data belonging to our customers, partners,vendors, suppliers, visitors, and others we engage with during our business activities. This Policy outlines how we handle and process your Personal Data, as well as your rights and obligations regarding your Personal Data collected while delivering our products and services.

2.  As used in this Policy, “personal data” means information that relates to an individual who is identifiable from that information, including any sensitive personal data of that person. “Sensitive personal data” means any personal data consisting of information as to the physical or mental health or condition of an individual, his political opinions, religious beliefs or other beliefs of a similar nature, the commission or alleged commission by him of any offence and biometric data.

“Biometric data” means any personal data resulting from technical processing relating to the physical, physiological or behavioral characteristics of a person. For avoidance of doubt, “personal data” under this Policy includes sensitive personal data.

3.  Personal data which we may collect includes, without limitation, your:

(a) Name or alias, gender, NRIC or passport number, date of birth, nationality;
(b) Mailing address, telephone numbers, email address and other contact details;
(c) Details of your next-of-kin, spouse and other family members, or emergency contact(s);
(d) Financial information, such as Credit/Debit Card details, Bank Account details;
(e) Transactional data, such as credit transactions, purchase details and history;
(f) Photographs and other audio-visual information; and
(g) For a job applicant, additional information which we collect such as marital status, religion, resume, employment history including last drawn salary, educational qualifications, professional qualifications and certifications, employment references, training history, achievements, medical history including physical or mental health or medical condition(s) or disabilities, commission or alleged commission of any offence or proceedings for any offence committed or alleged to have been committed including past misconduct.

4. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

5.  We generally collect personal data that (a) you knowingly and voluntarily provide in the course of business related transaction with us, after (i) you have been notified of the purposes for which the data is collected, and (ii) you have provided written consent to the collection and usage of your personal data for those purposes or you are deemed given the consent, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law). 

6. Your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:

(a) performing obligations under or in connection with the provision of our goods or services to you;
(b) performing obligations under or in connection with the provision of goods or services from you, including payment of fee(s) and tax;
(c) audit(s) or investigation(s) performed on FMAL;
(d) investigate complaints, claims and disputes;
(e) when you participate in our events, workshops, surveys or contests;
(f) conduct credit check(s) for credit-worthiness;
(g) when you enquire and purchase our products or services;
(h) sign up for our products, services, events or workshops;
(i) leaving your contact information / feedback when visiting our website(s);
(j) provide feedback to us on our products and services or quality of service;
(k) communicate with us via emails or written correspondences;
(l) process job application(s), recruitment, interview and selection;
(m) granting access to our premises;
(n) facilitating our compliance with any laws, customs and regulations which may be applicable to us;
(o) CCTV surveillance for security monitoring within FMAL premises;
(p) photo taking or video recording during FMAL public activities or events which you participate, such as product launching, media engagement etc. and sharing such photos or videos across public publications, our social media platforms, our internal newsletters, within FUJIFILM group companies’ internal platforms etc; and
(q) any other purposes that are incidental or ancillary or in furtherance to the above purposes which are not specifically mentioned herein.

7. We share certain Personal Data that you provide us with the following entities or organizations outside of FMAL to facilitate the abovementioned purpose(s):

(a) IT / technical support vendors and service providers;
(b) Software suppliers;
(c) Recruitment agencies;
(d) Regulatory bodies and other public agencies;
(e) Third party vendors and service providers;
(f) FUJIFILM group companies; and
(g) Payment processors / gateways.

8.  We will disclose Your Personal Data for the above listed cases only to the third parties who have agreed with us: 

(a) to use Your Personal Data only for the purpose agreed upon in advance;
(b) not to sell Your Personal Data to any other third parties; and
(c) not to disclose Your Personal Data to any other third parties except as may be required by law

9.  The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period that allow under the law or other related statutory or regulatory requirements) in order to enforce our rights.

10.  We take reasonable steps to ensure that your personal data provided to us is accurate. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided in Section 22 below, with the following information:

(a) Copies of proper identification of you; and
(b) Specific information regarding your Personal Data that you would like to access, or request for updating, correcting or deleting by completing FUJIFILM (Malaysia) Sdn. Bhd. Personal Data Access / Correction Request Form. Please submit the necessary information in the attached document at the link FUJIFILM (MALAYSIA) SDN. BHD. PERSONAL DATA ACCESS / CORRECTION REQUEST FORM.

11.  Your request made in Section 10 hereof will be subject to the statutory exceptions and prohibitions stipulated by the PDPA and/or any other applicable laws and regulations. 

12.  We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within twenty-one (21) days after receiving your access request, we will inform you in writing within the said twenty-one (21) days and shall respond to your access request not later than fourteen (14) days after the expiration of the initial twenty-one (21) days. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

13.  Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation on the personal data that our organization has on record, if the record of your personal data forms a negligible part of the document.

14.  We have the right to refuse your request to access and/or make any correction to your personal data in certain situations, which include but are not limited to situations when we are unable to confirm your identity or where the information requested for is of a confidential commercial nature or in the event that the expense of providing such access is disproportionate to the risks to your privacy or where the processing of your personal data is being controlled by any other third parties which prohibits us from complying (whether in whole or in part) with your request, or where such access is regulated by another law.

15.  To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced reasonable and appropriate administrative, physical and technical security measures to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorized third party service providers and agents only on a need-to-know basis.

16.  You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

17.  We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided in Section 22 below.

18. We may retain your personal data for as long as it is necessary to fulfill the purposes for which they were collected, or as required or permitted by applicable laws.

19. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.

20.  Please be informed that your personal data may be disclosed, disseminated and/or transferred within our organization or to our affiliates, whether within or outside Malaysia, for any of the abovementioned purposes. To this end, we are committed to ensuring the confidentiality, protection, security and accuracy of your Personal Data made available to us.

21.  In any circumstances where you may have provided personal data relating to other individuals, you represent and warrant that you are authorised to provide their personal data to us and you have obtained their consent for their personal data to be processed by us in the manner as described in this Policy.

22. You may contact our Data Protection Officer if you wish to make any request, inquiries or complaints in respect of your personal data provided to us, in the following manner:

FUJIFILM (Malaysia) Sdn. Bhd.
Address : Level 19, CelcomDigi Tower, 
No. 6, Persiaran Barat, Seksyen 52, 
46200 Petaling Jaya, Selangor Darul Ehsan, Malaysia
Attn : Data Protection Officer
Email : fmal.dpo@fujifilm.com
Tel No. : +603 – 5569 8388

23.  This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

24.  We may revise this Policy from time to time without any prior notice. You may determine if any such 
revision has taken place by referring to the date on which this Notice was last updated.

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