KASUMIGASEKI CAPITAL(MALAYSIA) SDN. BHD.

Privacy Policy

KASUMIGASEKI CAPITAL (MALAYSIA) SDN. BHD. 

PERSONAL DATA PROTECTION NOTICE

Effective date: [ August 1, 2025 ]

  1. Introduction
    • KASUMIGASEKI CAPITAL (MALAYSIA) SDN. BHD. and its group of companies (“KCMY” or “we” or “us”) are committed in protecting your personal data and complying with the Personal Data Protection Act 2010 (“PDPA”). 
    • This personal data protection notice (“PDP Notice”) describes how KCMY processes your personal data in accordance with the PDPA, and any regulations and guidelines relating to the PDPA, when you interact with us as, amongst others, the following:
      • our customers or potential customers relating to our products or services;  
      • our business partners or potential business partners engaging in any discussions or negotiations with us;
      • existing employees during your employment with us, or any potential employees and job applicants interested in working with us; and
      • any other person who has any dealings with us and provides personal data to us for any reason. 
    • This PDP Notice is adopted and applied by KCMY and all subsidiaries and affiliate companies of KCMY to the extent that the provisions of the PDPA will be applicable to the processing of your personal data by us. 
    • We may amend this PDP Notice from time to time by posting a revised version of this PDP Notice on our website, and we may also inform you of such updates through other forms of communication. We encourage you to check this PDP Notice from time to time to stay updated on any changes made to this PDP Notice. 
  2. Types of personal data processed
    • The term “personal data” in this PDP Notice has the meaning ascribed to it by the PDPA, and it generally includes any information which relates directly or indirectly to you, including:
      • your name, National Registration Identity Card number, passport number, age, race, date of birth, gender, nationality, address and photograph; 
      • your contact details (including e-mail address and phone number), financial or banking account details and emergency contact details;
      • your communications, opinions, requests, inquiries and feedback; 
      • your previous and current employment records, educational history and qualifications, references and background check information, disciplinary and grievance records, resume/CV and criminal records (if any);
      • information that we may automatically collect from our website, via cookies or otherwise, which include:
        • network and connection information, such as the Internet Protocol (IP) address used to connect your mobile phone or other device to the Internet;
        • mobile phone and device information, such as device, browser type or version, browser plug-in type, or time zone setting;
        • the location of your device;
        • authentication and security credential information; and
        • identifiers and information contained in cookies; 
      • sensitive personal data, including any information on your physical or mental health or condition, political opinions, religious beliefs or other beliefs of a similar nature and the commission or alleged commission of any offence and biometric data (such as information relating to the physical, physiological or behavioural characteristics of an individual); and
      • any other information which may relate directly or indirectly identify you, provided to us in any manner.
  3. Source of personal data
    • We collect your personal data through your direct dealings/interactions with us, including:
      • when you submit or complete any inquiries or contact forms to us;
      • when you visit or use our website through cookies or otherwise, or open any e-mails or click on any hyperlinks from us;
      • when you enter into any business engagements or business negotiations with us;
      • through the information you directly provide to us, including any resume and cover letter sent to us for your application, or when you apply for any positions with us (through any form of recruitment websites or social media platforms), or participate in any recruitment activities by us; or
      • when you interact with us, including through any requests for customer support, feedback, or complaints.
    • We may also collect personal data from third parties, such as from:
      • your authorised representatives or agents;
      • recruitment agencies;
      • your past, current, future or potential employers;
      • business partners and suppliers;
      • publicly available information; or 
      • the government, governmental agencies, law enforcement agencies or regulatory bodies. 
  4. Purposes of collecting and processing your personal data
    • We collect and process your personal data for, amongst others, the following purposes (as applicable):
      • to respond to your inquiries and to provide you with information on our products or services;
      • to evaluate potential business partnerships;
      • to carry out any background checks and to manage any recruitment processes, including screening, interviewing, assessing qualifications and selecting candidates;
      • to administer and manage employment matters, including payroll, benefits, performance evaluation, disciplinary actions and health and safety requirements;
      • to carry out internal analytics to improve our website and your user experience;
      • to maintain internal administration processes and record-keeping;
      • to facilitate business operations and contractual obligations;
      • to comply with all applicable reporting, legal and regulatory obligations under applicable laws and regulations;
      • to evaluate or conduct any potential, proposed or actual sale, disposal, merger, acquisition, consolidation, re-organisation, restructuring or funding exercise of our businesses, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding; and
      • to carry out any other purposes necessary or incidental to the purposes stated above.
    • The provision of your personal data may be mandatory or voluntary in nature, depending on the purposes for which your personal data is collected. If we are not provided with your personal data where it is required, we may not be able to perform the purposes stated in this PDP Notice. 
  5. Disclosure of personal data
    • We may transfer or disclose your personal data in accordance with this PDP Notice and to the extent permissible under the PDPA and any other applicable laws. In particular, for the purposes set out in this PDP Notice, we may disclose your personal data to the following third parties whether within or outside of Malaysia:
      • our group of companies either in Malaysia or outside of Malaysia;
      • authorised service providers or data processors, including any vendors, payroll service providers, insurance service providers, recruitment agencies, background check providers, IT service providers and cloud-based software or platform providers;
      • professional advisors, such as our lawyers, auditors, consultants and accountants, appointed in connection to our business on a strictly confidential basis;
      • government agencies, law enforcement agencies, courts of law and regulatory bodies, where required under applicable laws and regulations;
      • your immediate family members and/or emergency contact person, as may be notified to us from time to time;
      • our successors-in-title;
      • financial institutions;
      • data centres and/or servers located within or outside of Malaysia for data storage purposes; and
      • related parties in connection with any potential, proposed or actual sale, disposal, merger, acquisition, consolidation, re-organisation, restructuring or funding exercise of our businesses, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
  6. Accuracy, retention, and security of your personal data
    • The accuracy of your personal data depends largely on the information you provide to us. In order for us to ensure that your personal data is accurate, reliable, complete and updated at all times, you must promptly update us as and when your personal data provided to us becomes inaccurate, incomplete, misleading or not up-to-date.
    • Your personal data provided to us will be retained as long as it is necessary for the purposes for which such personal data was obtained. In the event your personal data is no longer required for the purposes it was obtained, we will destroy and permanently delete such personal data from our records and systems in line with our retention policy, in accordance with any applicable retention period required by applicable laws and regulations. For business partners and job applicants, we may retain your personal data for as long as you have provided consent to us to do so for further opportunities or engagements.
    • We will ensure that your personal data is processed and stored securely. To mitigate the risk of unauthorised access and disclosure of personal data, we will, in our best reasonable endeavour, implement appropriate technical, physical, electronic, and procedural security measures to ensure that the personal data collected will be safe and secured.
  7. Other individuals 
    • You confirm that you have explained to your family, spouse and/or other dependents that you have provided or will provide their personal data for us to process. You also represent and warrant that they consent to the processing, transfer, or disclosure of their personal data in accordance with this PDP Notice.
  8. Your rights
    • You have the right to limit our processing and use of your personal data at any time, and you may inform us of your withdrawal (in full or in part) of your consent to process personal data. Your withdrawal of consent is, however, subject to any applicable legal restrictions, contractual conditions, and reasonable duration of time for withdrawal.
    • In addition to the above, under the PDPA, you have the following rights:
      • to request access, request a copy of, your personal data;
      • to request an update or correction of your personal data;
      • to request the porting of your personal data to another entity or organisation; and
      • to withdraw your consent to our use of your personal data for marketing activities.
    • You can exercise each of your rights described in sections 8.1 and 8.2 above by providing a notice to us in writing using the contact details set out in clause 9 below.
    • To the extent permitted by the applicable laws and regulations, we reserve our right to refuse your request to access, correct or port your personal data. 
  9. Contact details
    • If you have any questions about this PDP Notice, or if you would like to make a complaint or a data access, correction or withdrawal request, you may contact us using the contact details below: 

      Contact person : TOSHIHIRO OHKUMA
      Telephone number : +60-12-650-1674
      E-mail address : privacy_contactus@kasumigaseki.com.my
  10. Conflict
    • In the event there is any conflict between this PDP Notice in the English language with any other versions of the PDP Notice in a different language, this PDP Notice in the English language will prevail.