This Personal Data Protection Notice (“Notice”) sets out Volkswagen Club of Selangor and KL (Register of Societies No: PPM-033-14-17012017) referred to in this Notice as “Volkswagen Club Malaysia” or “VWCM”) personal data protection practices that will be followed to respect the personal data of individuals who deal with VWCM. This notice is provided in accordance with the Personal Data Protection Act 2010 (“the Act”) and the personal data protection principles which are set out in the Act.
Collection of information
The type of data collected by VWCM regarding individuals generally includes the following:
- Full name as per IC/Passport including any aliases
- Addresses (including email addresses)
- Telephone and mobile numbers
- Date of birth
- Make/Model of vehicle
- Road Tax and Vehicle Insurance expiration date
- Details about next of kin including spouse and children’s names
- Other information deemed necessary for the purposes of VWCM activities, which may be amended from time to time.
Such data, where it relates directly or indirectly to a specific individual may fall within the definition of personal data under the Act and as such, all acts of processing such personal data will be carried out in compliance with the Act. Under the Act, “processing” includes the acts of collecting, recording, holding or storing personal data.
VWCM will collect personal data where it is required for carrying out one or more of its functions or activities. VWCM will collect the personal data only by lawful and fair means and not in an unreasonably intrusive way.
If it is reasonable and practical to do so, VWCM will collect personal data about an individual directly from the individual concerned. VWCM may also collect personal data from a variety of other sources, including without limitation at any events, conferences, seminars or talks organised or sponsored by VWCM and/or from the cookies used on the social media initiatives of VWCM.
The purposes for which VWCM processes personal data
Among the purposes for which VWCM processes personal data include the following (non-exhaustive):
- For safety purposes of events organized by VWCM
- For safety purposes of events participated in by VWCM
- For marketing and sales initiatives such as VWCM publications, events and business programs
- Direct marketing purposes
- For VWCM to comply with its obligations under law
Use and disclosure
As a general rule, VWCM will not use or disclose personal data about an individual other than for its primary purpose of collection, unless:
- The individual has consented to the use or disclosure
- The use or disclosure is required or authorized by or under law
- The use or disclosure is reasonably necessary for a specified purpose by or on behalf of a regulatory or enforcement body
With regards to VWCM’s direct marketing activities:
- VWCM will not charge the individual for giving effect to a request not to receive direct marketing communications
- Any individual who receives direct marketing communication from VWCM may contact or email VWCM’s Personal Data Protection Compliance Officer at the contact details below to “unsubscribe” or not receive any further direct marketing communications
Personal data integrity
VWCM will take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete, not misleading and up-to-date
Personal data security
VWCM will take reasonable steps to protect the personal data it holds from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction.
VWCM will not keep personal data for longer than is necessary and will take reasonable steps to destroy or permanently de-identify personal data.
Access and correction
In accordance with the Act, VWCM may on request by an individual, provide them with access to their personal data and consider a request for correction of that data.
VWCM’s decision to provide such access or consider any request for correction of the personal data as it appears in VWCM’s records is subject always to any exceptions under applicable laws and/or the Act.
VWCM may decide to impose a charge upon the individual to cover the cost of verifying a request for information and locating, retrieving, reviewing and copying any material requested.
In accordance with the Act, an individual may forward a written request to VWCM’s Personal Data Protection Compliance Officer to stop processing personal data.
Disclosure to third parties
VWCM may disclose personal data to certain third parties to perform functions on VWCM’s behalf, and consequently may provide access or disclose personal data to the third parties such as those listed below (not exhaustive):
(a) Information technology (IT) service providers
(b) Data entry service providers
(c) Storage facility service providers
(d) Banks and financial institutions
(e) Insurance providers
(f) Any professional advisers and external auditors
(g) Regulatory and governmental authorities in order to comply with statutory and government requirements.
How can an individual contact VWCM with any inquiry/ complaint regarding personal data protection?
He/ She may email VWCM at the following address: