Personal Data Protection and Privacy Notice
We, GROHE Malaysia Sdn. Bhd. (Company No.: 938845-W) (“GROHE”) respect your right to privacy and we respect all Personal Information you provide to us.
We are committed to protecting all Personal Information kept by us. GROHE is bound by the Personal Data Protection Act 2010 and all other applicable laws in Malaysia in respect of privacy protection which set out a number of principles concerning Personal Information and consumer protection in Malaysia.
For the purpose of this Personal Data Protection and Privacy Notice (“Privacy Policy”):
“Authorised Third Parties” means the group of companies of GROHE, its holding company, LIXIL Group Corporation, associated and related companies, GROHE’s bankers, professional advisors, agents, consultants, contractors, agents or third party suppliers or service providers with whom GROHE enters into an agreement;
“GROHE”, “we”, “us” or “our” means collectively, GROHE Malaysia Sdn. Bhd., a company incorporated in Malaysia and having its registered office at Suite 1005, 10th Floor, Wisma Hamzah-Kwong Hing, No. 1 Leboh Ampang, 50100 Kuala Lumpur, Malaysia, its subsidiaries, associate and related companies;
“Personal Information” means any personal information relating to you that you have provided to GROHE or made available to GROHE;
“Sensitive Personal Information” comprises information as to your physical or mental health or condition, political opinions, religious beliefs or other beliefs of a similar nature, commission or alleged commission of any offence, or any other Personal Information designated as such; and
“Services” comprises any communications, information or other products or services provided by GROHE to you.
1. PERSONAL INFORMATION
1.1 We may obtain your Personal Information from various sources.
1.2 The types of Personal Information we may obtain about you are:
a) contact information;
b) business contact information;
c) username and password to access our Services;
d) financial information;
e) employment information;
f) social media identifier; and
g) other information (such as shopping behaviour and preferences, language preference, age, date of birth, gender and family status).
1.3 We may also obtain your Personal Information from publicly available information systems and reporting agencies in connection with our contract with you.
2. USE OF PERSONAL INFORMATION
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
a) to communicate with you;
b) to provide Services to you;
c) to process your payment transactions;
d) to respond to your requests and inquiries;
e) to administer your participation in contests;
f) to conduct internal activities;
g) technical administration of our website;
h) to conduct market research/surveys and trend/statistical analysis;
i) to provide you with information on products and services of GROHE;
j) for other legitimate business activities of GROHE;
k) for such other purposes in relation to your contract with GROHE;
l) for customer redemption, warranty card program, loyalty, privilege, improvement, appreciation, recognition, benefits, rewards, rebates, discounts and other engagements, marketing and promotional activities and such other strategic alliances;
m) for marketing profiling activities regarding to GROHE latest products or services;
n) to send out invitation for GROHE present and future products launches, events and exhibitions;
o) for processing of relevant documents for our products and services;
p) to send GROHE newsletter, information, updates and corporate information by postage, voice/phone call, fax, email, text messages or social media about our products or services that GROHE think may interest you; and
q) to maintenance and upkeep of customer’s records and data.
(collectively “Purposes”).
3. INFORMATION SHARING
3.1 We do not sell or otherwise use, process, record, hold, store, share and disclose (“process”) your Personal Information we collect about you, except as described in this Privacy Policy or otherwise disclosed to you at the time the Personal Information is collected.
3.2 We may need to share your Personal Information with Authorised Third Parties who perform Services on our behalf for the Purposes. We do not authorise the Authorised Third Parties to use or disclose the information except as necessary to perform certain Services on our behalf for the Purposes or comply with legal requirements. We require the Authorised Third Parties by contract to appropriately safeguard the privacy and security of Personal Information they process on our behalf.
4. PERSONAL INFORMATION PROTECTION PRINCIPLES
4.1 We will process the Personal Information provided to GROHE by you when you register or apply for or express an interest in our Services with your specific consent.
4.2 GROHE will not process Personal Information without your prior written consent, except for the Purposes and where it is required or permitted under Malaysian law.
4.3 We may use your Personal Information for the Purposes.
4.4 If you are below the age of 18, you should ensure that you obtain the prior consent of your parents or legal guardian before using GROHE’s Services.
4.5 Any individual who have provided his/her Personal Information prior to this Privacy Policy, may contact GROHE using the contact details set out below to know what types of Personal Information have been processed and the purpose for the processing.
4.6 You will be given the opportunity to 'opt-out' of having your Personal Information used for purposes not directly related to the Services at the point where GROHE asks for information. If you do not wish to receive our promotional updates you may opt-out of receiving these communications by emailing us at info-malaysia@grohe.com. Please note that should you decide to “opt-out”, we may not be able to provide you with certain Services and your subscription to or application for certain Services may be declined, denied or refused by GROHE.
4.7 GROHE will not sell or rent your Personal Information to third parties. Other than as provided in this Privacy Policy, GROHE will not disclose your Personal Information to any third party without your consent.
4.8 GROHE may from time to time, contact you on behalf of external business partners about particular products, offers or services that may be of interest to you. In those cases, Personal Information that may identify you will not be transferred to the third party. All communication from GROHE will be sent to you by GROHE.
4.9 GROHE may however, need to work with Authorised Third Parties for the Purposes or to provide part or all of GROHE’s Services and/or other services to you or to perform market research and statistical analysis. In such situations, GROHE will share your Personal Information as is necessary for the Authorised Third Party to perform these services, on a strictly confidential basis. These parties are not allowed to process your Personal Information disclosed to them except for the limited purpose of providing the particular service for GROHE.
4.10 GROHE may use or disclose your Personal Information for accounting or reporting purposes, subject to the terms of this Privacy Policy.
4.11 It may be necessary to transfer your Personal Information to other entities or service providers located in countries outside Malaysia. In these instances GROHE will take steps to ensure that your privacy rights are respected in accordance with this Privacy Policy.
4.12 GROHE has implemented security policies, rules and technical measures to protect your Personal Information from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. Personal Information that GROHE collects will be stored and backed up securely.
4.13 All our employees and data processors, who have access to and are associated with the processing of Personal Information, are obliged to respect the confidentiality of your Personal Information.
4.14 GROHE will store your Personal Information as long as the purpose it was collected for remains valid and thereafter for a period of seven years or any other period of time required and/or permitted by Malaysian law.
4.15 GROHE takes all reasonable precautions to ensure that the Personal Information that we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that Personal Information depends to a large extent on the information that you provide.
4.16 You have the right to access your Personal Information, subject to some exceptions allowed by law. If you would like to do so, please let us know. You may be required to put your request in writing for security reasons. We reserve the right to charge a fee for searching for and providing access to your information.
4.17 GROHE reserves the right to refuse to provide GROHE’s customers with a copy of their Personal Information by providing a written explanation for such refusal.
4.18 You can have access to your Personal Information that GROHE has in its possession or control and may request that your Personal Information be amended for purposes of accuracy and completeness.
4.19 You may at any time remove your Personal Information from our database, or amend or correct your Personal Information. If you remove your Personal Information from our records, we will no longer be able to provide the Services to you.
5. SENSITIVE PERSONAL INFORMATION
5.1 Where required under Malaysian law, GROHE will obtain consent from you before we process your Sensitive Personal Information.
5.2 GROHE will process Personal Information or Sensitive Personal Information without your consent only in those limited circumstances as permitted by Malaysian law.
6 GROHE’S WEBSITE
6.1 GROHE provides products and services via its websites. When you visit GROHE's sites, its web servers generally record anonymous information such as the time, date and URL of the request. This information assists GROHE to improve the structure of its websites and monitor their performance. From time to time GROHE may also use Authorised Third Parties to analyse this anonymous information.
6.2 GROHE’s websites may require standard information such as a Login ID, password, Personal Information for verification purposes, contact details and identification numbers. This information is necessary for GROHE to provide the services an individual applied for. You are required to maintain the secrecy of his/her Login ID and Password enabling him/her to access the GROHE’s website. It is strongly stressed that GROHE will not be able to secure the Personal Data if you reveal your Login ID and Password to anyone.
7. IP ADDRESSES AND COOKIES
7.1 GROHE also collects Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. GROHE collects and manages IP addresses as part of the service of providing internet session management and for security purposes.
7.2 GROHE’s websites may transmit to any customer’s computer a “cookie”. A cookie is a package of data that allows GROHE’s server to identify and interact more effectively with the customer’s computer having to spend time on identifying each customer user, thereby also providing additional login convenience. You may configure and personalize its current browser to refuse, reject or delete such cookies.
8. INTEREST BASED ADVERTISING
Interest Based Advertising is a way of making advertisements more relevant to the customer based on Personal Information provided by the customer. In order to provide the customer with Interest Based Advertising, GROHE may collect information about a customer’s activities and use that information to associate the customer’s with one or more pre-defined interest categories. GROHE may periodically provide you advertisements that are tailored to your interests.
9. CONTACTING GROHE
You may submit your written request, between 9.00 am and 5.00 pm, Monday to Friday, if:
(a) you have any questions in relation to this Privacy Policy; or
(b) for access to, or correction of, your Personal Information or limit the processing of your Personal Information upon payment of a prescribed fee as per Personal Data Protection (Fees) Regulations 2013 to Corporate Data Protection Officer by post or email as set out below:
GROHE Malaysia Sdn Bhd
Suite 1005, 10th Floor,
Wisma Hamzah-Kwong Hing,
No. 1 Leboh Ampang,
50100 Kuala Lumpur,
Malaysia.
Tel : +603-20284600
National Toll free line: 1800 80 6570
Fax : +603-20284601
Email : DataProtection@grohe.com