1. Introduction

This Privacy Policy is operated by LACTALIS TRADING MALAYSIA SDN. BHD. (“the Company, “our”, “us”, “we”). In compliance with the Personal Data Protection Act 2010 (“the PDPA”) and its regulations, this Privacy Policy will inform you of your rights with regard to your personal data that has been and/or will be, collected and processed by us.

2. Personal Data

Personal Data means any information, whether recorded from any material information from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual. Such information may be collected and processed by us, which may include but is not limited to the following:

1. your name, gender, race, ethnic origin, designation, company’s and business’ name, and contact particulars including telephone number(s), residential address(es) and email address;
2. age, gender, date of birth, national registration identity card number, passport number;
3. details, information and contact particulars of your family, relatives or related parties;
4. information in connection with any products and services which you may have purchased from us or registered your interest with us for purchase, enquiry, updates, information etc;
5. your image and photo, by way of video surveillance installed in some parts of our premises as part of our security infrastructures (if applicable);
6. your network usage data and other information gathered automatically by our computer systems, including your computer IP address, links visited and other activities conducted online or using our computer system;
7. Personally Identifiable Information (PII) as defined by international privacy laws or standards;
8. sensitive personal data disclosed by you which are necessary for purposes of performing any obligations in relation to employment, for purposes of protecting vital interests of yourself and other person, for law enforcement purposes, for medical purposes or disclosure to health authorities which may include but not limited to biometric data such as finger print, religious belief, health condition, dietary requirement, commission or alleged commission of any offence(s) and other necessary sensitive personal data required by law; and
9. any other personal data required from you for the purposes set out in Section 4 of this Privacy Policy.

3. Collection of personal data

We have collected and will collect your personal data to be processed by us. Your personal data enables us to achieve the “Purposes” (as defined herein) that is in connection with our business in accordance to Section 4 of this Privacy Policy.

4. Purposes for collection of personal data

The Company will use your personal data for the following purposes including, but not limited to:

1. emergency uses;
2. other business-related references;
3. administration and management;
4. in compliance with applicable laws and regulations;
5. to communicate the requested information;
6. to provide products and/or services;
7. to provide on-going information, events, programmes or activities, our products and/or services to people that we believe may be interested in such information, events, programmes or activities, products and/or services;
8. to consider applications for employment;
9. to research, develop and improve our events, programmes, activities, products and services;
10. to comply with legal and regulatory requirements, applicable laws, regulations, directives, orders, guidelines and circulars;
11. for promotional and publicity purposes, including recording or taking photographs of participants at events or functions organised, hosted or participated by the Company;
12. verifying your identity or monitoring your activities, including without limitation via video surveillance observation and/or recording;
13. preventing, detecting and investigating fraud, misconduct, any unlawful action, dispute, and whether or not there is suspicion of the aforesaid;
14. in relation to employment, for staff training, quality assurance, performance evaluation and record-keeping;
15. for purposes of conducting/performing credit reference/reporting checks;
16. for transfer to third party data intermediaries to facilitate any of the aforesaid purposes for any other purpose that is incidental or ancillary or in furtherance to the above purposes; and
17. for any other purpose that is incidental or ancillary or in furtherance to the above purposes

(collectively, known as “Purposes”)

5. Sources of personal data

The Company may obtain your personal data from the following sources including, but not limited to:

1. any documents submitted for job application;
2. any documents given to the Company for any purposes;
3. responding to communication or your correspondences with us;
4. updating of your contact information including your contact number and/ or address;
5. from any subsidiary of the Company;
6. visiting the Company’s premises;
7. attend or participate any activities or events organised by the Company;
8. working with third party sources, including collecting publicly available information from social networking websites;
9. information you have provided us, information from third parties and information from credit reporting agencies such as CTOS or any other public domain.

6. Disclosure of personal data

We may disclose your personal data with other entity including, but not limited to

1. our subsidiaries, related, or affiliated companies;
2. our directors, authorised employees or representatives, auditors, advisers, consultants, professional firms or entities;
3. any third parties we hire to perform support service(s);
4. any third parties who partner with us to provide products and services to our customers;
5. any third parties when we have good faith belief that disclosure is necessary:
   1. to comply with a law, regulations, court order, or other legal process;
   2. to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of the company’s Internet Sites, products or services;
   3. to protect the company’s rights or property or yours or other’s health, safety, welfare, rights, or property;
6. any third parties in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of the company or a company’s business unit, or under similar circumstances;
7. relevant regulatory authorities, securities exchange, governmental bodies and law enforcement agencies; and
8. such other persons which the Company may think fit or necessary

These entities shall treat your personal data as confidential, in accordance with this Privacy Policy and with all applicable data protection legislation and will process such personal data only for the Purposes and within the terms set out herein. We are responsible for the personal data under our control, including personal data disclosed by us to a Vendor (often referred to the “data processor“). We take every measure, by contract or otherwise, to provide a comparable level protection for personal data should the information be processed by a Vendor. The Company is committed to ensure compliance with the PDPA, in particular, its policies as well as corresponding guidelines and orders.

7. Security of personal data

The Company uses strict procedures and security features to prevent unauthorised access wherever possible. The level of security of personal data which kept in a non-electronic environment are also treated with strict procedures and means.

We shall keep and process your personal data in a secure manner and in strict confidence. We endeavour, where practicable, to implement the appropriate security measures and procedures in accordance with the PDPA and relevant regulations. We do not on an individual basis disclose your sensitive personal data to third parties, without your explicit consent or unless required under the PDPA or other applicable law.

Although we use security measures to help protect the confidentiality, security and integrity of your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security which are beyond our reasonable control.

8. Use of Cookies

The cookies used by the Website are solely associated to anonymous users and their computers and do not provide personal data on users. Some cookies are used by third parties to provide the Company with data on the effectiveness of its engagements and promotions. The cookies used by the Website not in any way collect personal data that could be used to identify a specific user. In addition, cookies are of a temporary nature, used solely to improve the efficiency of the last transmission, Users may configure their browser to notify them of the reception of cookies and to prevent their installation on their computer.

9. Transfer of Personal Data

Your personal data may be transferred to a place outside Malaysia. We will take reasonable precautions and protection on your personal data should the information be processed or used outside Malaysia by our Vendors or experts and exercise due diligence to ensure that personal data transferred outside of Malaysia receives a standard of protection comparable to the protection received under the PDPA and such transfer shall be subject to this Privacy Policy.

10. Changes to Privacy Policy

We reserve the right to amend this Privacy Policy from time to time without prior notice. We advise that you check with our website for this Privacy Policy on a regular basis, Kindly view our Privacy Policy on the website https://staging.lactel.com.my/privacy-policy/.

11. Retention Period

We will not retain personal information longer than necessary to fulfil the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations for example audit, accounting, statutory retention terms, handling disputes, and for the establishment, exercise or defence of legal claims in the countries where we carry out business.

In the event such information retained by us is no longer required, we will take reasonable steps to ensure that such information is deleted and/ or destroyed.

12. Exclusion of Liability

You acknowledge and agree that the Company shall not in any event be liable for any claim, loss, damage (financial and otherwise), injuries, misfeasance, embarrassments or liability howsoever arising whether in contract, tort, negligence, strict liability or any basis whatsoever (including direct or indirect, special, incidental, consequential or punitive damages or loss of profits or savings) arising from any inaccuracy or loss, deletion or modification of data or for any other reasons whatsoever relating to any information forwarded by the Company to such other party, as the case may be, or in relation to any access or use, or the inability to access or use by such other party or reliance on the information contained therein, whether caused by any technical, hardware or software failure of any kind, the interruption, error, omission, delay, viruses or otherwise howsoever. Further you shall indemnify and keep the Company indemnified from any loss, damage, expense, injuries, embarrassments or liability that may be suffered by the Company arising from your provision of false or inaccurate personal data.

13. Privacy Questions

If you have a question about this Privacy Policy or the Company’s handling of your information, you can contact us at:

Lactalis Trading Malaysia Sdn. Bhd.

25, Jalan Tandang 51/204,

46050 Petaling Jaya,

Selangor, Malaysia

14. Consent

Unless otherwise required under the Act or other applicable law, the Company will not collect, use, disclose or share your personal data (including sensitive information) without your consent. The Company will take reasonable steps to bring to your attention the purposes of the disclosure and the extent to which the disclosure be made to third parties, at the time of collection of personal data.

15. Withdrawal of Consent

Should you wish to withdraw your consent to any use or disclosure of your personal data by the Company as set out in this Privacy Policy, you may notify us in writing at the address stated above.

16. Changes to this Privacy Policy

We reserve the right to amend, update or change any terms in this Privacy Policy from time to time to ensure it is consistent with future developments or business purposes or to accommodate future changes to applicable laws and regulatory requirements. All updates will be published on our website: https://staging.lactel.com.my. By continuing your relationship with the Company after any amendments have been introduced and published on our website, you shall be deemed to have accepted this Privacy Policy as amended.

This policy is effective as of 21 March 2022.

1. Terms

By accessing the website at https://staging.lactel.com.my, you are agreeing to be bound by these terms of service, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws in full and without reservation. If you do not agree with any of these Terms of Service, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law.

2. License

1. Subject to the terms and conditions set forth, we grant you a non-exclusive, non-transferrable, limited right to access, use and display this site and the materials thereon (“License”). You further agree not to interrupt or attempt to interrupt the operation of this site in any way.
2. Permission is granted to temporarily download one copy of the materials (information or software) on our website for personal, non-commercial transitory viewing only. This is the grant of a License to use our site, not a transfer of title, and under this License you may not:
   1. modify, republish or copy the materials;
   2. exploit the materials for any commercial purpose, or for any public display (commercial or non-commercial);
   3. sell, rent, or sub-license the materials from our website;
   4. attempt to decompile or reverse engineer any software contained on our website;
   5. remove any copyright or other proprietary notations from the materials; or
   6. transfer the materials to another person or “mirror” the materials on any other server.
3. This License shall automatically terminate if you violate any of these restrictions and may be terminated by us at any time. Upon terminating your viewing of these materials or upon the termination of this License, you must destroy any downloaded materials in your possession whether in electronic or printed format.

3. Disclaimer

1. The materials on our website are provided on an ‘as is’ basis. We make no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights.
2. Further, we do not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or otherwise relating to such materials or on any sites linked to this site.

4. User Warranties

1. You hereby represent and warrant that you will use this site in compliance with this Terms of Service, including the laws and provisions under this Terms of Service, and to comply with all existing and future policy and rules of the site.
2. You agree that you will not use this site to:
   1. Transit spam or unsolicited communication;
   2. Pretend to be the Company or someone else;
   3. Forge headers or otherwise manipulate identities in order to disguise the origin of any content transmitted through the site;
   4. Misrepresent your affiliation with a person or entity;
   5. Act in a manner that negatively affects other users’ ability to use the Site;
   6. Engage in activities that would violate any applicable law;
   7. Post or transmit any material which violates or infringes in any way upon the rights of others or which is unlawful, abusive, defamatory, vulgar or otherwise objectionable or which contains any advertising or solicitation with respect to product or services;
   8. Collect or store personal data about other users unless specifically authorized by the Company; or
   9. Not adhere to withdrawal of such authorization as described in (h) above.
3. Should you not comply to any one of Paragraph 4(2) above, you may not use the site, and the Company shall reserve all our legal rights in relation to such non-compliance by you.

5. Limitations

In no event shall we or our suppliers be liable for any damages (including, without limitation, damages for loss of data, revenue, business, contract, revenue, information or business interruption) arising out of or in connection with the use or inability to use the materials on our site, even if we or our authorized representative have been notified orally or expressly in writing of the possibility of such damage. In addition to the terms set forth herein, in no event shall we be liable for any errors, inaccuracies, omissions or other defects or unauthenticity of any information contained in this site.

6. Accuracy of materials

Although care has been taken to ensure the accuracy of the information available on this site, the materials appearing on this site could include technical, typographical, or photographic errors. We do not warrant that any of the materials on this site are accurate, complete or current. We may make changes to the materials contained on this site at any time without notice. However, we do not make any commitment to update the materials.

7. Linked Sites

We do not undertake to monitor and review all of the sites linked to our website and we are not responsible for the contents of any such linked site. The inclusion of any link does not imply our endorsement, sponsorship, affiliation or association with the linked site. The use of any such linked site is at your own risk, and it is your responsibility to take all protective measures to guard against any potential viruses or any other destructive elements.

8. Modifications

We reserve the right, at our sole discretion, to change, modify, add, remove or revise this Terms of Service, in whole or in part, for our site at any time without notice. By using this site, you are agreeing to be bound by the current version of this Terms of Service, and your continued use of this site after any changes to this Terms of Service posted will be considered acceptance to those changes.

9. Governing Law

This Terms of Service is governed by and construed in accordance with the laws of Malaysia and you irrevocably submit to the exclusive jurisdiction of the courts in that State or location.