23-26 May, 2018

Putra World Trade Centre 
Kuala Lumpur, Malaysia

Data Protection Policy
  • English
  • Bahasa Malaysia
Notice for consent under the Personal Data Protection 2010
To : Our Valued Customers
With the Personal Data Protection Act 2010 enforced on 15 November 2013, we are taking steps to ensure that we are in compliance with this new Act and that all personal data relating to whoever we are dealing with in the company inclusive of any Supplier, Customer,  their employees, their Directors and Shareholders is processed in accordance with the law.

Trade Link ITE Sdn Bhd (1033543-M) (we”, “our” orus) respects and is committed to the protection of your personal information and your privacy.  This Personal Data Protection Notice (“PDP Notice”), prepared in accordance with the Personal Data Protection Act 2010 (the “Act”), sets out our personal data protection practices that are put in place to protect the personal data of individuals, Customers, Suppliers, and Business Partners whom we deal with.

Trade Link ITE Sdn Bhd (1033543-M) would like to thank you for providing your Personal Data to us through current or earlier dealings. By providing your Personal Information to us, you are consenting to this Personal Data Protection Notice and the collection, use, access, transfer, storage and processing of your personal information as described in this PDP Notice. Your Personal Data will continue to be used and processed by us in accordance with our Personal Data Protection ("PDP") Policy.

Trade Link ITE Sdn Bhd (1033543-M) asks you to read this PDP Notice carefully as it contains important information about how we will use and process the Personal Data provided by you. Please note that this Notice only applies to Personal Data processed in respect of commercial transactions as defined in the PDPA.
For the purpose of this document, unless the context otherwise requires:
‘You / Your’  : means the addressee of this notice.
Affiliates”  : means Trade Link ITE Sdn Bhd (1033543-M) and/or related companies, including their related companies;
‘Personal data : means is about you/your, related to you/your or affecting you/your, as defined herein.
'We / Our / Us'  : means Trade Link ITE Sdn Bhd (1033543-M)
Business Partners : Suppliers, Vendors, Principals and providers of goods and/or services,  dealer(s), authorised service partner(s), their employees, Directors and Shareholders.
Individuals : Any individual dealing on behalf of any company and guest visiting Trade Link ITE Sdn Bhd (1033543-M) offices.
Customers : Any individual or entity that purchases our products or services.
1.1  “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images. 
1.2  We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
2.1  The provision of your personal data is voluntary. But, if you do not provide your Personal Data to us, Trade Link ITE Sdn Bhd (1033543-M) may not be able to provide the products and/or services which you require of us. 
2.2  Trade Link ITE Sdn Bhd (1033543-M) collects personal data during the course of its everyday activities, and will only collect such personal data if it is necessary for one of our functions or activities.
2.3  The Personal Data Protection Act requires us to collect personal data about you, only from you, if it is reasonable and practical to do so. Some examples of the types of information which we may collect about our stakeholders include:
  • contact information such as names, addresses, telephone numbers, and email addresses;
  • unique information such as ID or passport number, photograph, contact preferences, and date of birth; and
  • transaction history;

3.1  Some examples of how personal data can be collected:
  • Register your details on our website, apps or kiosks;
  • When you open new account either cash or credit term with us;
  • When you complete purchase orders, requests or applications for our products or services (by phone, in person, snail mail, or electronically);
  • When you communicate with us directly via our general line, or directly via our co-workers within our organisation in relation to our products and services (in person, by email, telephone, direct mail or any other means);
  • When you use services such as logistic service;
  • When you conduct certain types of transactions such as refunds and/or cancellation;
  • When you enter, and when you interact with us during promotions, competitions, contests, lucky draws, special events, or by using devices within our warehouse;
  • Subscribe to any of our membership programmes, such as customer loyalty programme;
  • Participate in surveys and other types of research.
  • Personal data collected by appointed agent(s).

4.1  The personal data which we collect from you may be collected, used, disclosed and/or  processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including :
  • to communicate with you;
  • to maintain and improve customer relationship;
  • to assess, process and provide products, services and/or facilities to you;
  • to administer and process any payments related to products, services and/or facilities requested by you;
  • to establish your identity and background;
  • to respond to your enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings with us;
  • to provide you with information and/or updates on our products, services, upcoming promotions offered by us and/or events organised by us and selected third parties which may be of interest to you from time to time;
  • for marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels to members of our loyalty programmes, in accordance with their consent;
  • to facilitate your participation in, and our administration of, any events including contests, promotions or campaigns;
  • to award points in a loyalty or rewards programme;
  • to maintain and update internal record keeping;
  • for internal administrative purposes;
  • to send you seasonal greetings messages from time to time;
  • to send you invitation to join our events and promotions and product launch events;
  • to monitor, review and improve our events and promotions, products and/or services;
  • to conduct credit reference checks and establish your credit worthiness, where necessary, in providing you with the products, services and/or facilities;
  • to administer and give effect to your commercial transactions with us (such as tender award, contract for service, tenancy agreement);
  • to process any payments related to your commercial transactions with us;
  • to process and analyse your Personal Data either individually or collectively with other individuals;
  • to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services;
  • to share any of your Personal Data with the auditor for our  audit and reporting purposes;
  • to share any of your Personal Data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
  • to share any of your Personal Data with our business partners to jointly develop products and/or services or launch marketing campaigns;
  • to share any of your Personal Data with financial institutions necessary for the purpose of applying and obtaining credit facility(ies), if necessary;
  • for audit, risk management and security purposes;
  • for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
  • for enabling us to perform our obligations and enforce our rights  under guarantee or any agreements or documents,  that we are a party to;
  • to transfer or assign our rights, interests and obligations under any agreements entered into with us;
  • for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;
  • to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations; and/or
  • for other purposes required to operate, maintain and better manage our business and your relationship with us;
  • for  any other  purposes that are incidental or ancillary or in furtherance to the above purposes which are not specifically mentioned herein.

(hereinafter referred to as “Purposes”)
Notwithstanding the above, we may process your Personal Data without your consent if it is permitted under the PDPA or any other relevant legislation.
4.2  In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our Customers, Business Partners, and/or our affiliates or related corporations, and/or other third parties whether sited in Malaysia or outside of Malaysia, for one or more of the above-stated Purposes. Such Customers, Business Partners and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.  


5.1  We respect the confidentiality of the personal data you have provided to us. Trade Link ITE Sdn Bhd (1033543-M) does not share, sell, rent or release any personal data collected to any individuals, companies or groups. Any information we collect is used for Trade Link ITE Sdn Bhd (1033543-M) own purposes as described in this PDP policy.
5.2  So that we can provide a wide range of products and services to you, third party service providers offering services are engaged through Trade Link ITE Sdn Bhd (1033543-M), including the following:

  • Data entry service providers
  • Professional advisors, consultants and/or auditors
  • Contractors. storage facility & logistic providers
  • Business partners
  • Financial institution
  • Local authorities
  • Third party service providers who provide operational services such as venue providers, telecommunications, information technology, printing, postal service, marketing promotions, and relevant government regulators to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority.

5.3 The third parties whom we conduct business are only authorized to use your information to perform the service for which they were hired. As part of our agreement with them, they are required to follow the PDPA laws and policies that we provide, and to take reasonable measures to ensure your personal data is secure.
5.4  In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:

  • cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
  • cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
  • cases in which the purpose of such disclosure is required for business transaction with you;
  • cases where disclosure is needed to enable our Business Partners to vet and evaluate information provided and collection of overdue invoices;
  • cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
  • cases in which the disclosure is necessary for any investigation or proceedings;
  • cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency;
  • cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
  • where such disclosure without your consent is permitted by the PDPA or by law. 

5.5 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.  


6.1 You may request to access and/or correct the personal data currently in our possession by submitting your written request to the following address:  
Personal Data Protection Officer
Trade Link ITE Sdn Bhd (1033543-M)
A-11-02A, Empire Tower Office,
Empire Subang, Jalan SS16/1,
47500, Selangor, Malaysia
Email address: [email protected]

6.2 For a request to access personal data, we will provide you with the relevant personal data within twenty-one (21) days from such a request being made.
6.3 Where a request cannot be complied with within the above time frame, we will inform you of the reasonably time in which we will respond. 
6.4 Depending on the scope and nature of the work required to process your access request, we may be required to impose a fee to recover our administrative costs. This will be assessed on a case-by-case basis by our Personal Data Protection Officer. Where such a fee is to be imposed, we will provide you with a written estimate of the fee for your consideration. Please note that we will only process your request once you have agreed to the payment of the fee. In certain cases, we may also require a deposit from you before we process the access request. You will be notified if a deposit is required in the written estimate of the fee, if any.  


7.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your written request to the Personal Data Protection Officer at the above address.
7.2 We will process your request within 21 days from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
7.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.

7.4 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 obligatory 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 Policy, we will not be able to provide products and/or services or otherwise deal with you.


8.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by Trade Link ITE Sdn Bhd (1033543-M) to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
8.2  We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control. 
8.3  We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.


9.1  If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to submit your written complaint or grievance to Personal Data Protection Officer (see 6.1).
9.2  Where it is an email or a letter through which you are submitting a complaint, your indication
at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
9.3  We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.  


10.1  As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time. 

10.2  We reserve the right to amend the terms of the Personal Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website.

10.3  You are encouraged to visit our website at here (http://www.automex.com.my/Data-Protection-Policy.aspx)  from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

NB : If there is any conflict between the English and Bahasa Malaysia version of this Notice, the English version shall prevail.
If we do not receive any response from you within fourteen (14) days of this Notice, we shall presume that you have approved of our continued use of your personal data in accordance with this Notice.  However, please rest assured that you will be able to terminate this approval at any time.
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