- As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means any information in respect of commercial transactions which:-
(a) Is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose;
(b) Is recorded with the intention that it should wholly or partly be processed by means of such equipment; or
(c) Is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system,
that relates directly or indirectly to a data subject, who is identified or identifiable from
that information or from that and other information in the possession of a data user,
including any sensitive personal data and expression of opinion about the data subject;
but does not include any information that is processed for the purpose of a credit
reporting business carried on by a credit reporting agency under the Credit Reporting
Agencies Act 2010.
- Depending on the nature of your interaction with us, some examples of personal data which we may collect from you includes name, identification numbers such as NRIC, work permit and birth certificate, residential address, email address, telephone number, nationality, gender, date of birth, marital status and employment information.
- Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- For customers who use our website will be able to use most of the services in the website without providing any personal data (please note that in some services we may request that the customer provide personal data). We carefully respect and protect the personal data of the customer who uses our website.
- We declaim any responsibility for the collecting, managing and the security of customer’s personal data used on non-affiliated third parties’ websites that are linked to our website. With regards to personal data protection of non-affiliated third parties’ website, please refer to the personal data protection policy of such parties respectively.
- We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(g) any other purposes for which you have provided the information;
(h) for purposes of sales of product – providing with products and services that Topcon and its subsidiaries and partners offer (“Products“) and managing contractual relationship related to providing Products and other business activities;
(i) for purposes of use of product – Planning, development, manufacturing, installation, support, training and maintenance of machines and equipment, providing and distributing information such as information on Products, contact you about warranty, service and sales issues;
(j) for purposes of marketing and communication – to send you free publications like product news and insights, press releases and company news, as well as invitations for events, training and webinars (you may unsubscribe from these communications at any time);
(k) to send you other e-mail-marketing related to direct marketing, we reserve the right to send you information on goods and services similar to those you have purchased from us by e-mail. You can object to receiving such information by email at any time. Each email contains information on how to unsubscribe from future emails;
(l) for purposes of improvement of our Website – personalizing your experience at our websites; selectively sending you information that may be of interest to you; contests and sweepstakes; market research and online surveys; automatic monitoring of statistical information to determine how Topcon’s websites are being used;
(m) for purposes of improvement of our Products – Conducting surveys on Products and analysis of the results. The processing of personal data is carried out because Topcon has a predominant legitimate interest to enhance your experience and to develop and improve our products;
(n) for purposes of application process – We collect personal data relating to job applicants in connection with our employment application/recruiting process. In instances where personal data is collected in connection with a specific open position, we will store the subject personal data for no more than 30 days following the date on which the subject opening is no longer available. In instances where personal data is collected that is not specifically associated to an open position, we will store the subject personal data for no more than 180 days. Should we wish to keep your personal information on file longer for consideration for future suitable employment opportunities with us we will ask for your consent, which, if given, can be withdrawn at any time;
(o) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Malaysia or abroad, for the aforementioned purposes; and
(p) any other incidental business purposes related to or in connection with the above.
- We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes.
WITHDRAWING YOUR CONSENT
- The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
- Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) business days of receiving it.
- Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 7 above.
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
- Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
- We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (14) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
- To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, use of privacy filters, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
- We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
- We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
- We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- We generally do not transfer your personal data to countries outside of Malaysia. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
- As we have networks, databases, servers, systems, support, and help desks located throughout our offices around the world. We collaborate with third parties such as cloud hosting services, suppliers, and technology support located around the world to serve the needs of our business, workforce, and customers. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within Topcon or to third parties in areas outside of your home country. The areas in which these recipients are located will vary from time to time, but may include the United States, Japan, Europe and other countries where Topcon has a presence or uses contractors.
DATA PROTECTION OFFICER
- You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Name of DPO : Jeremy Lim
Contact No. : +65-68720606
Email Address : firstname.lastname@example.org
EFFECT OF NOTICE AND CHANGES TO NOTICE
- This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
- We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : 24/06/2021
Last updated : 24/06/2021