ARAH MODEN SDN BHD (being part of the KLCC Group of Companies) ("Arah Moden", "we", "our" "us") are committed to protecting and respecting your privacy.
Reference to "KLCC Group of Companies" herein refers to KLCC (Holdings) Sdn Bhd and its subsidiaries and controlled companies.
This Arah Moden Privacy Statement ("Privacy Statement") explains what personal data we collect about you, when and why we collect it, how we use it, the conditions under which we may disclose it to others, your rights to your personal data and how we keep it secure.
This Privacy Statement covers both our online and offline collection activities, including personal data that we collect through online platforms such as websites, applications, third party social networks or our online and physical events, or through other third parties that we work with.
Please read this Privacy Statement carefully to understand our views and practices regarding your personal data.
Arah Moden is a company registered in Malaysia and a leading retail property asset management company. The registered address of Arah Moden is Level 82, Tower 2, PETRONAS Twin Towers, Kuala Lumpur City Centre, 50088 Kuala Lumpur, Malaysia.
If you are an employee or work for Arah Moden, we shall provide a separate statement to inform you how your personal data is used.
Your personal data may be collected directly from you or from other sources such as our customers tenants, clients, shoppers, their counterparties and representatives, third parties such as regulatory authorities, government agencies, credit reporting agencies, recruitment agencies, providers of pre-engagement screening services, your employer or other referees, social network information, publicly available records, or other third parties that we work with.
We may aggregate personal data from different sources such as online and offline collection points, though in relation to personal data that you have provided, we will only do so for purposes which are consistent with the purposes for which you have provided that personal data. Aggregated data which may be derived from your personal data but is anonymized is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate data related to usage of our website to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data in a way which does directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Statement.
If you are an existing customer tenant or vendor of ours, or a representative of an existing tenant of ours, further details about how we use your personal data are set out in your/ your employer's customer contract with us.
We may provide further notices to you at the point we collect your personal data, which will highlight any further information relating to our use of that personal data, and, where applicable, provide you with the ability to opt in or out of selected uses.
If you are based in the European Economic Area ("EEA") or United Kingdom ("UK") during your interactions with us (other than solely for travel purposes whereby you are not resident in the EEA or UK), the laws in those countries require us to provide you with additional information about our processing activities. We have included this information in Appendix A.
If you are based in a country or territory outside the EEA or UK during your interactions with us (other than solely for travel purposes whereby you are not resident in the EEA or UK), then subject to the applicable data protection laws, by providing us with your personal data, you agree and consent to the collection, use and disclosure of your personal data by us for some or all of the purposes mentioned in this Privacy Statement, where applicable.
We will collect and process all or some of the personal data as follows. We describe certain kind of data (defined below) as Special Category Data.
We may collect current and historical personal data including your name (including any prefix or title), contact information (such as your address, email address, telephone number, nationality, identification number such as national identification number, passport number, birth date, gender, organization, business interest, employment, position held), social media identifiers, Special Category Data (as defined below), billing and financial information (such as billing address, bank account and payment information) and enquiry or complaint details and such other information depending on the nature of business relationship or dealings you have with Arah Moden. "Special Category Data" means sensitive personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic, biometric, health, sexuality or sexual orientation, or relating to criminal convictions or offences. Special Category Data receives a higher level of protection in some jurisdictions such as EEA and UK. Collection and processing of Special Category Data will entail different requirements from jurisdiction to jurisdiction in accordance with applicable local laws.
In any of the above circumstances, we collect your CV or résumé which may include your contact details (such as name, address, email address and telephone number), education information (such as field of study, university and country of study, academic scores and achievements, personal certifications), employment history, racial or ethnic origin, nationality, financial information (such as parents or beneficiaries income, bank account name and number), photographs or profile picture and any other supporting documents or information as submitted by you or on your behalf during the application process.
We carry out pre-screening of applicants to whom we intend to make an offer of employment, scholarship, or internship or to receive grants as beneficiaries (as appropriate). We may also undertake criminal records or financial probity checks or other independent searches to assess your suitability for the position were permitted by, and in accordance with, applicable law. Special Category Data may be processed strictly in accordance with applicable local laws.
If you are or act for or are related to our tenants and shoppers, where you are our counterparty or provide services to our counterparty and where you or the organization you work for is a regulator, government agency, judiciary, legislative or other law enforcement agency, we may collect and process your personal data based on your relationship with us.
The types of personal data include contact information (such as name, address, email address and telephone number); identification information (such a national identification number, passport number, date of birth); business information (such as name of organization, job title, department, business address, organization structure, shareholding or directorship); any recordings captured through our communication platform (such as Microsoft Teams or Zoom, etc.), details in business registration documents, third party due diligence, documents, credit checks, financial details including bank account details and bank account statement; demographic information and interests which will include any information that describe your demographic and behavioral characteristics (such as date of birth, age or age range, geographic location, personal preferences (e.g. food), medical condition (e.g. allergies), hobbies or interests and household or lifestyle information).
Details of your visits to our website and information collected through cookies and other tracking technologies including, but not limited to, your log-in information, IP address and domain name, your browser version and operating system, information about your device, traffic data, location data, web logs and other communication data, and the resources that you access.
We use the following cookies:
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| Cookie Name | Expiration | Purpose |
|---|---|---|
| _ga | 2 years | This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. We use this cookie to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. |
| _gid | 1 day | This cookie is set by Google Analytics. It stores and updates a unique value for each page visited. We use this to count and track pageviews. |
| _gat_UA-82765211-1 | 1 minute | This is a pattern type cookie set by Google Analytics, where the pattern element on the party name contains the unique identity number of the account or website it relates to. It is a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites. |
| _gat_UA-123749877-1 | 1 minute | This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It is a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites. |
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
If any part of our website links you to external websites, those websites do not operate under this Privacy Statement and we do not accept any responsibility or liability arising from those websites. We recommend that you read the privacy/personal data protection statement/policy posted on those external websites in order to understand their procedures for collecting, processing, using and disclosing personal data and before submitting your personal data to those websites.
We may also collect information you provide in completing online subscriptions, purchases or registration and any online application forms or when you report a problem, raise a query or provide feedback on our online services.
When you visit our offices or malls, we may collect and process your personal data in connection with your visit. Such personal data may include your contact information (such as name, address, email address and telephone number), identification information (such as national identification number, passport identification number or driver's license information); business information such as name of organization, reason for visit, date and time of visit, biometric and facial recognition and access limitations.
Where we have installed CCTV in our offices and malls, your image may be captured and recorded when you visit our premises that are protected by CCTV. Additionally, your image may be captured via photographs or videos taken by us or our representatives when you attend our events.
Our CCTV use is not intended to target or monitor any individuals but to provide a safe and secure workplace environment in the relevant premises.
During a health crisis or disease outbreak we may collect Special Category Data on your health and physical condition, health condition of individuals in your household, results of your health assessment, quarantine, and hospitalization information and any other information required or recommended to be held in connection with control or management of such health crisis or disease outbreak.
We may use personal data that we obtain for any of the following purposes:
Where we collect personal data from you, we will only do so for fulfilment of the purposes set out above. Failure to provide your personal data may mean that we are not able to effectively provide you with our products and/or services or to carry out any of the abovementioned purposes, if at all.
Where we rely on your consent for processing your personal data, you may withdraw your consent to this processing at any time, by contacting us by using the contact details below. Please note, however, that withdrawing your consent will not affect the lawfulness of processing based on your previously given consent (prior to withdrawal).
Where we process your personal data for direct marketing purposes, we will log any objection you make, and stop processing your data for direct marketing purposes.
There may be instances where we process your personal data for our legitimate interests or on the basis of other lawful grounds (i.e., because we have established a relationship with you and need to process your personal data in order to provide you with the information and/or services you have requested), without having obtained your consent - this applies where our processing activities are governed by the applicable laws of certain jurisdictions in which we operate that do not require consent to have been obtained where there are legitimate and/or other lawful grounds to process the relevant personal data.
We do not seek your consent in such cases largely so that we can provide you with services in an efficient way (or where in some cases it might not be possible for us to seek your consent because we must process personal data, for example, for the detection of fraud). Before processing your personal data, we will consider your rights and freedoms and will only commence such processing where we do not think your rights will be infringed.
The collection of your personal data by us may be mandatory or voluntary in nature depending on the purposes for which your personal data is collected. Where it is mandatory for you to provide us with your personal data, and you fail or choose not to provide us with such data, or do not consent to the above or this Privacy Statement, we will not be able to provide our products and/or services or otherwise deal with you and/or to assess and process your application.
To the extent that you have provided (or will provide) personal data about your family members, spouse, other dependents and/or other individuals, you confirm that you have explained to them that their personal data will be provided to, and processed by, us and where required by law, you represent and warrant that you have obtained their consent to the processing (including disclosure and transfer) of their personal data in accordance with this Privacy Statement.
If you are providing personal data on behalf of minors or individuals not legally competent to give consent, you confirm that you are legally authorized to act on their behalf and to consent to the processing (including disclosure and transfer) of their personal data in accordance with this Privacy Statement.
We may share the personal data that you provide to us to other entities in the KLCC Group of Companies for the purposes described above. Such affiliates may be located in a jurisdiction that may not provide a level of protection equivalent to that provided by the laws of your home country. Where such transfers occur, Arah Moden will reasonably protect personal data and address data privacy and other privacy requirements in accordance with applicable laws.
Information may also be shared with our service providers or third parties, in each case to the extent necessary for the purposes described above. Such third-party who we reasonably believe need to have access to your information to provide you with the information or services you request from us may include:
We will not otherwise use, share, disseminate, publish or disclose your personal data except as may be required in response to litigation, investigations or other legally required disclosures or or to protect our rights, property or safety or of our customers, or others.
As part of the services offered to you either through the website or otherwise, the information which you provide to us may in some instances be transferred to countries outside of the EEA and UK. The data protection laws in such countries may not provide the same level of protection for your personal data as provided for under European and UK data protection laws. However, when we transfer your information outside of the EEA or UK in this way, we take steps to ensure that appropriate safeguards, required by law, are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Statement. You can obtain further details about the transfer safeguards we use by contacting us at the contact details set out below.
If we transfer your personal data, we will always do so under strict conditions of confidentiality and similar levels of security safeguards.
All information you provide to us is stored on our secure servers or on the servers of third party IT service providers. We maintain appropriate administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the personal data you provide to us in accordance with applicable laws.
We may transfer your personal data to, or store it in, a destination outside of the jurisdiction of the entity to which you provided it as we use third party service providers based in a number of locations worldwide. Where we have to transfer your personal data to third countries, we will use appropriate approved safeguards in accordance with applicable laws.
We will store your personal data for no longer than is necessary for the purposes for which it was collected or provided to us (unless a legal or insurance obligation requires us to keep it for longer period such as operational, legal, regulatory, tax or accounting requirements).
Please note that you have the following rights:
We have security measures in place to help protect against the loss, misuse and alteration of the information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we ensure that our systems adhere to market security standard so as to help safeguard against such occurrences.
Any changes we make to our Privacy Statement in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Statement.
In accordance with the requirement of Malaysian data protection and privacy law, this Privacy Statement is issued in both English and Bahasa Malaysia. In the event of any inconsistencies or discrepancies between the English version and the Bahasa Malaysia version, the English version shall prevail.
If you have any questions, comments or request regarding this Privacy Statement or your personal data, or if you wish to contact a data protection officer, you may reach out to:
Designation: Data Protection Officer
Address: Level 33 & 34, Menara Dayabumi, Jalan Sultan Hushamuddin, 50050 Kuala Lumpur, W.P. Kuala Lumpur
E-mail Address: klccgroupdpo@klcc.com.my
We may collect your personal data which you voluntarily provide to us such as your name, salutation, date of birth, gender, your business contact information such as your designation, organization, address, email address, telephone number, and such other information depending on the nature of business relationship you have with Arah Moden.
We may also collect your personal data from third party sources where your personal data has been made publicly available by yourself or by third parties (e.g. information published on your personal or official website, business card, online publications such as news reporting, corporate profiles, autobiographies, annual reports, social media postings) and from such other sources where you have given your consent for the disclosure of personal data relating to yourself (e.g. formal and informal engagements such as meetings, conferences, events organised by Arah Moden or third parties), or where otherwise lawfully permitted.
From the aforesaid sources, we may derive further information such as your personal and professional profile, interests, preferences, persons related to yourself (e.g. family members, relatives, connected persons), publicly known political affiliations, insights or opinions, etc., all of which will be processed by us strictly for internal use by KLCC Group of Companies for the purpose of managing our relationship with you only.
We may use personal data that we obtain for any of the following purposes (including but not limited to):
Where we collect personal data from you for stakeholder relation purpose, we will only do so strictly needed for fulfilment of one of the purposes set out above. In the event we do not receive your personal data, this may mean that we are not able to effectively address your requirements, interests and concerns or to carry out any of the abovementioned purposes, if at all.
This Appendix applies if you are based in the EEA or UK during your interactions with us (other than solely for travel purposes). It sets out the additional information that we are required to provide to you under UK and European Union ("EU") data protection law.
Under EU and UK law, we are required to inform you of the "lawful bases" on which we rely to process your personal data. Below, we set out the "lawful bases" that we use as the basis for our use of your personal data for each of the purposes mentioned in the main Privacy Statement.
You can find an explanation of each of the grounds relied on below:
| Processing activity | Lawful bases |
|---|---|
| Purpose for which we collect and use personal data | |
| To communicate effectively with you and conduct our business, including providing service and notifying you of changes to services |
|
| To decide whether to enter into a contract with you |
|
| To assess your application for a role at Arah Moden |
|
| To provide you with marketing materials or to personalize our website and services |
|
| For research and development purposes |
|
| To carry out due diligence or KYC screening activities |
|
| To monitor certain activities and to ensure service quality, compliance with procedures and to combat fraud, and to process any payments related to your commercial transaction with us |
|
| To administer or re-organise Arah Moden and protect Arah Moden and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
| To ensure the physical security and safety of visitors to our offices |
|
| In connection with legal or regulatory obligations |
|
Under EU and UK data protection laws, Special Category Data has greater protections. Typically for UK/EEA-resident individuals, we will use your Special Category Data in the following ways: