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Data privacy policy



POLICY STATEMENT

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. it also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain personal information about you. when we do so we are subject to the Personal Data Protection Act, which applies in legislation of Malaysia, and we are responsible as “controller” of that personal information for the purposes of those laws.

 

KEY TERMS

It would be helpful to start by explaining some key terms used in this policy:

We, us, our: Lyreco Office Supplies (M) Sdn Bhd

Personal information: Any information relating to an identified or identifiable individual

Special category personal information: Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership. Genetic and biometric data. Data concerning health, sex life or sexual orientation.

 

PERSONAL INFORMATION WE COLLECT ABOUT YOU

Personal information we collect about you

We may collect and use the following personal information about you:

•            your name and contact information, including email address and telephone number and company details

•            information to enable us to undertake credit or other financial.

checks on you

•            Information about how you use our website, IT, communication, and other systems

•            your responses to surveys, competitions, and promotions

This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.

 

 

 

 

HOW YOUR PERSONAL INFORMATION IS COLLECTED

 

We collect most of this personal information directly from you—in person, by telephone, text, or email and/or via our website. However, we may also collect information:

•            directly from a third party, e.g.:

–            your employer

–            credit reference agencies.

•            from cookies on our website

—for more information on our use of cookies, please see our cookies policy

•            via our systems, e.g.:

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

•            to comply with our legal and regulatory obligations.

•            for the performance of our contract with you or to take steps at your request before entering a contract.

•            for our legitimate interests or those of a third party; or

•            where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

 

 

WHAT WE USE YOUR PERSONAL INFORMATION FOR

 

What we use your personal information for:  To provide products and/or services to you

Our reasons: For the performance of our contract with you or to take steps at your request before entering a contract

 

What we use your personal information for:  To provide products and/or services to your employer

Our reasons: For our legitimate interests or those of a third party, i.e., for the performance of our contract with your employer

 

What we use your personal information for:  Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies

Our reasons: To comply with our legal and regulatory obligations

 

What we use your personal information for:  Ensuring business policies are adhered to, e.g., policies covering security and internet use

Our reasons: For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you.

 

What we use your personal information for:  Operational reasons, such as improving efficiency,

training and quality control

Our reasons: For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you or your employer at the best price

 

What we use your personal information for:  Ensuring the confidentiality of commercially sensitive information

Our reasons: For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations

 

What we use your personal information for:  Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures

Our reasons: For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price

 

What we use your personal information for:  Preventing unauthorized access and modifications

to systems

Our reasons: For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you. 

 

 

What we use your personal information for:  Updating and enhancing customer records

Our reasons: To comply with our legal and regulatory obligations

 

What we use your personal information for:  Statutory returns

Our reasons: For the performance of our contract with you or to take steps at your request before entering a contract

 

What we use your personal information for:  Ensuring safe working practices, staff administration and assessments

Our reasons: To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products

 

What we use your personal information for:  Marketing our services and those of selected third parties to:

—existing and former customers.

—third parties who have previously expressed an interest in our services.

—third parties with whom we have had no previous dealings.

Our reasons: To comply with our act regulatory obligations

For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

 

What we use your personal information for:  Credit reference checks via external credit reference agencies

Our reasons: For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services

 

What we use your personal information for:  External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts

Our reasons: For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations                           

 

The above table does not apply to special category personal information, which we will only process with your explicit consent.

 

 

PROMOTIONAL COMMUNICATIONS

We may use your personal information to send you updates (by email, text message, telephone, or post) about our products and/or services, including exclusive offers, promotions, or new products and/or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside the Lyreco group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

•            contacting us at privacy.sima@lyreco.com.

•            using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

 

WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We routinely share personal information with:

•            companies within the Lyreco group.

•            third parties we use to help deliver our products and/or services to you, e.g., delivery companies.

•            other third parties we use to help us run our business, e.g., marketing agencies or website hosts.

We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO or Investors in People accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all our business or during a re-structuring. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

 

WHERE YOUR PERSONAL INFORMATION IS HELD

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

 

HOW LONG YOUR PERSONAL INFORMATION IS KEPT

We will keep your personal information while you have an account with us, or we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

•            to respond to any questions, complaints or claims made by you or on your behalf.

•            to show that we treated you fairly.

•            to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. We will hold your information for as long as the account to which your personal data relates is active. Should you wish to close your account with Lyreco then your personal information will be held for a period of 3 months after the account is closed provided there is no legitimate reason for Lyreco to continue to process the personal data.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

 

TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE EEA

We do not share any personal information about you to any organization outside of the EEA.

 

 

 

 

 

 

 

You have the following rights, which you can exercise free of charge:

Access: The right to be provided with a copy of your personal information (the right of access)

Rectification: The right to require us to correct any mistakes in your personal information

To be forgotten: The right to require us to delete your personal information—in certain situations

Restriction of processing: The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data.

Data portability: The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations.

The right to object:

—at any time to your personal information being

processed for direct marketing (including profiling).

—in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.

 

Not to be subject to automated individual decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

 

For further information on each of those rights, including the circumstances in which they apply, please contact us, or see the Laws of Malaysia, ACT 709 – Personal Data Protection Act 2010.

If you would like to exercise any of those rights, please:

•            email, call or write to us—see below: ‘How to contact us’; and

•            let us have enough information to identify you (e.g., your full name, address, and customer reference number).

•            let us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill); and

•            let us know what right you want to exercise and the information to which your request relates.

 

We have appropriate security measures to prevent personal information from accidently lost, accessed unlawfully.

We limit access to your personal information and to those who have a genuine business need to access it.

Those authorise manner and are subject to a duty of processing your information will do so only in a confidentiality.

We continually test our systems and conduct regular penetration testing by independent third parties. We also have

procedures in place to deal with any suspects data security breach. We will notify you and any applicable regulator.

of a suspected data so security breach where we are legally required to do.

 

HOW TO COMPLAIN

We hope that we can resolve any query or concern you may raise about our use of your information.

The Personal Data Protection Act 2012 also gives you right to lodge a complaint with a supervisory authority,

in the country where you work, normally live or where any alleged infringement of data protection laws occurred.

The supervisory authority in Singapore in the information Commissioner who may be contacted at

Email: mashitah@pdp.gov.my or Telephone: +603 8911 7901       

 

CHANGES TO THIS PRIVACY POLICY

This privacy notice was published on 18 Sept 2023

We may change this privacy notice from time to time—when we do, we will inform you via our website or other means of contact such as email.

 

HOW TO CONTACT US

Please contact us and/or our Data Protection Office by post, email, or telephone if you have any questions about this privacy policy or the information, we hold about you

 

Our contact detail:         

 

No.68, Jalan i-Park SAC 8,

Taman Perindustrian i-Park SAC,

81400 Senai Johor, Malaysia

Alex.ang@lyreco.com 

+60127100311

 

 

              

 

               

 

 

              

              

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