Privacy Policy

Introduction

FPG Solution & Consultancy Sdn Bhd (“FPGSC”) respects and protects the privacy of all users of our website. This privacy policy (“Privacy Policy”) explains how we may collect, use, disclose or otherwise process the data, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access (“Personal Data”) in accordance with the Personal Data Protection Act of Malaysia, as may be amended from time to time (“PDPA”). This Privacy Policy applies to all users of our website located at www.first-cert.com(“FirstCert”).

FPGSC reserves the right to change this Privacy Policy and related business practices at any time for any reason. Please review this Privacy Policy periodically for changes. Such changes shall be effective immediately upon posting. Your continued use of our Website constitutes your acknowledgment and acceptance of such changes.

Please note that capitalised words and expressions shall, unless otherwise specified or the context otherwise requires, have the corresponding meaning assigned to them in the Terms and Conditions of the use of our Website at.

Collection of personal data

It may be necessary for us to collect and use certain Personal Data when you interact with our Website. The following broad categories of Personal Data which are collected by us and/or our affiliates include:

It may be necessary for us to collect and use certain Personal Data when you interact with our Website. The following broad categories of Personal Data which are collected by us and/or our affiliates include:

• Identification data – full name, country of residence, job title, age, marital status and/or gender
• Contact data – residential address, e-mail address and/or telephone number
• Usage data – information about how you use our Website (including the time you visit our Website, the duration of your visit, the types of products and/or services you are searching for and/or how you are searching for such products and/or services)
• Marketing, behavioural and communications date – your interests, feedback, survey responses, preferences in receiving marketing materials from us and your communication preferences, as well as your preferences for particular products or services
• Technical data – your Internet Protocol (IP) address, the internet device identity or media access control address of your device, information regarding the manufacturer, model or operating system of the device that you use and/or information about the web browser that you use to access our Website
• Any other data and/or information you provide

How personal data is collected

Apart from your interaction with our Website, we may collect your Personal Data:

• Directly from you – when you use our Website, create an account on our Website, enter into a contract with us, apply for or enquire about our Website or products, participate in a promotion, survey, event or other marketing campaign organised by us, subscribe to our newsletters or alerts, request marketing materials to be sent to you or contact us
• From your authorised representatives – these include persons whom you have authorised and persons who have been validly identified as acting on your behalf pursuant to our security procedures
• Third parties – these include technical data from analytics providers, advertising networks and social media platforms
• Publicly available sources.

Purposes for processing your personal data

We may collect and use your Personal Data for any or all of the following purposes:

• To register you as a new customer
• To verify your identity
• To process your order(s)
• To manage your account
• To manage our relationship with you
• To administer, operate, provide, maintain and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorised users do not access the information on our Website)
• To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve you
• To make suggestions and recommendations to you about products or services that may be of interest to you
• To send you relevant information about our events, news announcements or promotions
• To enable you to complete a survey or participate in a promotion, survey, event or other marketing campaign organised by us
• To contact you in relation to all of the above
• To comply 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
• Any other purposes for which you have provided the information
• Any other incidental business purposes related to or in connection with the above

The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

If you supply us with your Contact Data, you may receive periodic mailings, calls, emails, or messages from us with information about new products and services or upcoming events. We will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your Personal Data to any third party for such marketing.

If you no longer wish to receive our newsletter, you may withdraw your consent by contacting us at [email protected].

We will only process your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If there is any change in the purposes for which we collect your Personal Data, we will inform you of such change by way of email. If we need to use your Personal Data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so as well as obtain your consent to the use of your Personal Data for such purpose where we are required to do so by law.

Disclosure of personal data

In connection with one or more of the purposes outlined above, we may disclose your Personal Data to:

• Other members of the First Pavilion Global Berhad Group
• Professional advisors, third parties, agents or independent contractors that provide services to any member of the First Pavilion Global Berhad Group (such as IT systems providers, platform providers, financial advisors, brokers and consultants including solicitors and accountants)
• Goods and services providers (such as providers of marketing services where we are permitted to disclose your Personal Data to them), intermediaries, brokers, and other individuals and entities that partner with us
• Competent authorities (including any national and/or international regulatory or enforcement body, agency, court or other form of tribunal or tax authority) or their agents where FPGSC is required or allowed to do so under applicable law or regulation
• A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of FPGSC’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it
• Credit reference agencies or other organisations that help us to conduct anti-money laundering and anti-terrorist financing checks and to detect fraud and other potential criminal activity
• If any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties
• Any person to whom disclosure is allowed or required by local or foreign law, regulation, or any other applicable instrument

We do not disclose your Personal Data to unaffiliated third parties for their independent use unless we have obtained your express consent to do so and pursuant to executing confidentiality agreements with such unaffiliated third parties. We also require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.

Retention of personal data

We only retain your Personal Data for as long as is necessary for us to process your Personal Data as described above. However, we may retain some of your Personal Data after you cease to use our services, for instance if the data is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

International transfers of information

We may transfer your Personal Data to countries outside of Malaysia and if we do so, 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. For example, we will always ensure that there is a proper legal agreement that covers the data transfer.

Security

We take commercially reasonable precautions and appropriate measures to keep all information obtained from our online users secure against unauthorised access (such as data breach), collection, use, disclosure, copying, modification, or disposal, or similar risks, and we periodically review our security measures. Although no data transmission over the Internet is secure and there is no way that any website can absolutely guarantee the security of your Personal Data, FPGSC is committed to employing reasonable security measures, regularly reviewing our security practices (such as security risk assessments and/or audits), and providing regular awareness training.

You are responsible for keeping your login information and passwords confidential. FPGSC uses for its Website security certificates.

Please be aware that these protection tools do not protect information that is not collected through our Website, such as information provided to us by email.

Collection of personal data from children

We do not knowingly collect personal data from children under the age of 13. If you are under the age of 13, please do not provide Personal Data of any kind whatsoever.

If a child under the age of 13 provides us with personal data, a parent or guardian of that child may have this information deleted from our records by contacting us at [email protected].

Cookies

We use cookies to provide users with a personalised experience on our Website. Cookies are pieces of information that a website transfers to the memory or hard drive of a user’s computer for record-keeping purposes. We use cookies to make improvements and to better tailor our website to our users’ needs. We also use this information to verify that users meet the criteria required to process their requests.

Most browsers used by users have options that allow the user to control whether the browser will accept cookies, reject cookies, or notify the user each time a cookie is sent. However, if you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. In addition, you can delete your FPGSC cookies from your browser program at any time.

Links to other websites

Our website may contain links to other websites. These websites are not covered by this Privacy Policy, and we are not responsible for the privacy practices or the content of these websites.

Your choices

You may request access to, correction of, or deletion of your Personal Data by contacting us at [email protected].

Contact us

If you have questions or concerns about our Privacy Policy, please contact us at [email protected].