Hunza Properties Berhad : Policy

A. Privacy

The Personal Data Protection Act 2010 (hereinafter referred to as “the Act”) has now come into force. Hunza Properties Berhad along with its related companies (hereinafter Hunza and its related companies shall be referred to as “Hunza Group”) values your privacy and is committed to protecting your Personal Data (as defined in the Act) entrusted to us.

In the course of your dealings with Hunza Group, you will be requested to disclose certain Personal Data to us. This Privacy Notice is formulated in accordance with the requirements of the Act and sets forth how we collect, store and handle your Personal Data.

Use of the Personal Data Collected

Your Personal Data is being collected, used and / or processed by Hunza Group for, amongst others, the following purposes :

To enable you to enter into the necessary agreement and / or contract to purchase the products and / or properties from Hunza Group;
To respond to your inquiries, request for information, complaints and / or feedbacks or take any other action in response to your inquiries, request for information, complaints and / or feedbacks;
To communicate, direct market and to update you about Hunza Group’s products, properties, future projects and developments or other marketing and promotional purposes related to Hunza Group’s products, properties, future or proposed projects and developments;
To communicate, direct market and to update you about brands, products, services, events and promotions offered by the affiliates and business / marketing partners of Hunza Group, or for other marketing and promotional purposes related to brands, products, services, events, promotions offered by the affiliates and business / marketing partners of Hunza Group, unless you have otherwise indicated that you do not wish for us to process your personal data for such purposes;
To create personalized promotions by combining your Personal Data with non-personal information about you (i.e. the type and value of the property purchased by you or to which you have shown interest in);
For internal purposes such as evaluating the effectiveness of Hunza Group’s marketing and promotional activities as well as for market research, profiling and statistical analysis;
To improve Hunza Groups’ products, properties and services and to assist Hunza Group in the development of new products, properties and / or services;
To better serve your housing requirements now and in the future;
To carry out credit assessments, financial and background investigation as and when deemed necessary;
For the delivery of vacant possession of your property to you, handover of the keys to your property, property / estate management, customer care and / or defect rectification works;
To provide post vacant possession services, such as club house services, security and customer loyalty card programs;
To organize and administer promotions and other activities organized by Hunza Group (e.g. roadshows, property launches) and to conduct advertising, publicizing and marketing strictly of the aforementioned promotions and other activities;
For Hunza Group’s internal record keeping;
To take such actions as is necessary to protect, carry out and enforce Hunza Group’s contractual and legal rights and obligations;
For any other purpose that is required or permitted by any legal or regulatory requirements relating to and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by law, guideline, circular, code applicable to Hunza Group;
For the prevention of fraud or any criminal activity and to enable us to comply with any applicable law, regulation, direction, court order, by law, guideline, circular, code or to assist in law enforcement and investigations by relevant authorities;
To enable Hunza Group to furnish and submit your Personal Data to the following Government bodies / agencies / local authorities and institutions:

Housing Loan Department of the Treasury of Malaysia;
Employee’s Provident Fund;
Social Security Organization;
Inland Revenue Board;
Land Office;
Local authorities;
Internal auditors;
High court, lower courts or tribunal;
Insurance companies;
ISO auditors; and
Any such other Government bodies / agencies / local authorities and institutions as and when may be necessary.

To enable Hunza Group to furnish and submit the Customer’s Personal Data to the following Non - Government bodies / associations / agencies / local authorities and private institutions:

Indah Water Konsortium;
Tenaga Nasional Berhad;
Banks and financial institution;
Insurance companies;
External financial auditors;
Law firms; and
Any such other Non - Government bodies / associations / agencies / local authorities and private institutions as and when may be necessary.

For any other purpose as may be consented to by you; and
For all other purposes incidental or associated with any of the above, including disclosure to and processing by any third party outsourced service providers and / or Hunza Group’s marketing partners.

Types of Personal Data Collected

The precise details, type and nature of the Personal Data collected by Hunza Group will vary according to the specific purpose for which it is intended but will amongst others include the following Personal Data from or in relation to you:

Name;
Correspondence Address;
Telephone Number (house and / or mobile);
E-mail Address;
NRIC and / or other identification number;
Age;
Occupation;
Income;
Marital Status;
Gender;
Race;
Nationality;
Date of Birth;
Housing Preference (e.g. location, type, price range); and
Such other information which Hunza Group may deem necessary from time to time depending on the events or promotions held and the products or services offered (e.g. frequency of visits, type of shops visited etc.) .

The Source of Your Personal Data

We may obtain your Personal Data from the following sources:

Directly from you; and
Legitimately from third parties or other service providers, to which, you have consented to the disclosure of your Personal Data.

Disclosure of Your Personal Data

Hunza Group will keep your Personal Data confidential but from time to time we may disclose your Personal Data to the following parties:

Other entities within Hunza Group including those incorporated in the future;
Hunza Group’s authorized agents and service providers with whom Hunza Group has contractual agreements for some of Hunza Group’s functions, services and activities;
Hunza Group’s merchants, vendors, suppliers, contractors and strategic partners;
Hunza Group’s auditors, consultants, lawyers, accountants or other professional advisers appointed in connection with Hunza Group’s business and other related matters;
Parties authorized by you;
In the event of a merger, acquisition, reorganization, reconstructions, investment, financing or sale of assets or any other situation involving the transfer of some or all of Hunza Group’s business assets, Hunza Group may disclose the Personal Data to those involved in the arrangement, negotiation or transfer; and
Enforcement, regulatory and / or governmental agencies as permitted or required by law, authorized by any order of court or to meet obligations to any such enforcement, regulatory and / or governmental agencies.

Period of Retention of Your Personal Data

Hunza Group will retain your Personal Data for such period of time as is necessary to enable us to fulfill the purposes as set out in Item A above.

Your Responsibility

You are responsible for ensuring that the Personal Data provided to us is true, accurate and complete, and for updating the Personal Data in the event of any changes or as and when it becomes inaccurate, outdated or incomplete.

Security of Your Personal Data

Hunza Group will use its best endeavors to keep and process your Personal Data in a secure manner. We will implement the appropriate and necessary security safeguards and procedures to prevent the unauthorized and accidental access, use, modification, processing, loss, destruction of or damage to your Personal Data.

Links to Third Party Websites

This Privacy Notice does not apply to third party websites that you may access from Hunza Group ’s websites. These third party websites may have their own privacy policy in place.

Consent

In order for Hunza Group to collect, use, transfer, store and / or otherwise process your Personal Data, we are required to obtain your consent. If you are below the age of 18, kindly bring this notice to the attention of your parent or legal guardian.

By providing your Personal Data to us, you are consenting and agreeing to the collection, use, transfer, storage and processing of your Personal Data by us in accordance with this Privacy Notice.

Should you no longer wish to allow us to collect, use, transfer, store or process your Personal Data, kindly inform us accordingly and we shall ensure the removal, destruction and / or deletion of your Personal Data from our records.

In the event that you have provided the Personal Data of a third party to Hunza Group, we may request your kind assistance in obtaining the consent and agreement of the aforementioned third party to the use of their Personal Data and you hereby agree to use your best endeavors to do so. You are to indemnify Hunza Group in the event that we suffer any loss or damage as a result of your failure to comply with the same.

Personal Data Protection Officer

Should you wish to have access to your Personal Data or to update or make any corrections thereto or should you wish to withdraw your consent to any use of your Personal Data or should you have any questions, queries or complaints relating to the use of your Personal Data, you may contact Hunza Group at the following:

Designation of Contact Person:
Personal Data Protection Officer
E-mail Address: hunzapdpa@hunzagroup.com
Contact Number: +604-2290 888
Fax Number:+604-2273 988

Changes and Updates to this Privacy Notice

You are advised to regularly check Hunza Group’s website regularly for any changes and / or updates to this Privacy Notice.

Inconsistency

In the event of any inconsistency between the English version and the Bahasa Malaysia version of this Privacy Notice, the English version shall prevail.

B. Code of Conduct for Supplier’s Declaration

The following basic principles and fundamental ethical standard to promote the Supplier Code of Conduct (hereinafter referred to as "the Code") with integrity, honesty and compliance with applicable laws and regulations.

Legal Compliance

In addition to the legal standards mentioned in the Code, Suppliers will comply with all other applicable laws on anti-bribery, fraud and corruption in the provision of products and services to Hunza Group. Hunza Group expects Suppliers to implement systems and controls to promote compliance with applicable laws and the principles set forth in the Code. Suppliers should also apply these or similar principles to their subcontractors who are providing goods and services directly or indirectly to Hunza Group.

Bribery and Corruption

Suppliers will comply with all the anti-corruption principles:

Committing to promote values of integrity, transparency, accountability and good corporate governance;
Strengthening internal systems that support corruption prevention;
Fighting any form of corrupt practice; and
supporting corruption prevention initiatives by the Government and the local authorities;

to the best of our knowledge (collectively referred to as “The Requirements”).

A ‘zero tolerance’ policy towards any form of bribery, corruption, extortion and embezzlement. In particular, Suppliers shall not pay bribes or make any other inducement, including kickbacks, facilitation payments, excessive gifts and hospitality, grants or donations in relation to their business dealing with customers and public officials. Suppliers are expected to perform all business dealings transparently and these dealings shall be recorded accurately. Suppliers shall ensure the subsidiaries, affiliates and all other parties appointed by the Suppliers to conduct work for Hunza Group also comply with The Requirements.

Suppliers have not been convicted nor are the subject of any investigation, inquiry or enforcement proceedings by the relevant authorities of any actual or suspected breach to The Requirements and will report any actual or suspected breach to The Requirements as soon as reasonably practicable and to the extent permitted by law, to Hunza Group.

Human Rights

Suppliers will conduct business in a way that respects the human rights of all people and treat them fairly, in accordance with all applicable laws. Hunza Group do not tolerate the occurrence of involuntary labor, child labor, prison labor, bonded labor or human trafficking in our operations or supply chain. Suppliers must conduct the activities with reasonable steps to identify, prevent and manage human rights impacts in the operations and controlled entities. Any incidents must be reported.

No Discrimination

Suppliers are committed to equal employment opportunity and not to discriminate on the ground of race, color, gender, national origin, sex orientation, religion, age, disability status or any other personal characteristic unrelated to job performance and will comply with all applicable employment discrimination laws. This also applies to the treatment of other counterparties.

Harassment

Suppliers are prohibited from any form of harassment, including sexual harassment and bullying of any employee on the basis of any status protected by law. It can be in the form of physical, verbal, visual or any conduct toward a person that is unwelcomed by that person and has the purpose or effect of creating an intimidating, hostile or offensive work environment. This include the conduct of anyone in the workplace, such as employees of Hunza Group and non-employees.

Security

Suppliers shall ensure that all necessary security arrangements are in place to protect their employees. Suppliers are expected to have a management policy in place to be able to respond to emergencies timely and efficiently.

Conflicts of Interest

Suppliers are required to avoid any activity or association that creates or appears to create conflicts that may arise in the performance of work and in any related business decisions. It can be involved both financial and non-financial interests.

Environment

Suppliers will comply with sustainability and all applicable environmental laws including efficient use of resources and respect for the environment.

Health and Safety

Substance Abuse - Suppliers must be free from the influence of alcohol or any other substance in order to perform the jobs safely and effectively.
Workplace Violence - Suppliers must ensure workers do not act or threats of violence in the workplace. Weapons are not permitted in Suppliers' premises or while conducting business on behalf of the Suppliers.
Protect Health and Safety - Suppliers will comply with all applicable workplace health and safety laws including appropriate controls, training, work procedures and personal protective equipment.

AGREES THAT:

In the event that we are in breach of any of the above sections, Hunza Group may immediately revoke the contract award or terminate the contract for the business transactions without any liability whatsoever on the part of Hunza Group to the Suppliers. This is without prejudice to any other rights or remedies that Hunza Group may have or any other appropriate action which Hunza Group may seek under the terms of the applicable tender/ contract or applicable laws and regulations.
Should any person attempt to solicit any bribe or advantage (whether financial or otherwise) from the Suppliers or any other person connected to the Suppliers either as an inducement or incentive to be selected or as a reward, gift or bonus for being selected in the business transactions, or where the Suppliers has reasonable grounds to suspect any breach of the obligations in the Code, the Suppliers will report such act to Hunza Group as soon as reasonably practicable.