PRIVACY NOTICE OF TURNING POINT INTEGRATED WELLNESS SDN BHD

Introduction
Personal Data Protection Act 2010 (“PDPA/Act”) has been introduced by the Government of Malaysia to monitor the processing of personal data in commercial transactions. The Act, which applies to all companies and firms incorporated in Malaysia, makes it mandatory for us to notify you, among others, regarding your rights as our customer/potential customer (“you”) in relation to your personal data that we have collected, will be collecting, processing and/or will be processed and the purpose of processing the said personal data. This privacy notice (“Notice”) is issued by Turning Point Integrated Wellness Sdn Bhd (Company No. 200701015469) and on behalf of its holding and related companies and its subsidiaries (“Turning Point/we/us/our”). This Notice is applied to the processing of your personal data by Turning Point (including without limitation to holding and related companies and the subsidiaries of Turning Point), associates, partners, related corporations, service providers, strategic partners, contractors, related third parties and/or consultants (as further described below) for the Meanings (as hereinafter defined) in this Notice. This Notice describes how we collect, process, use, store and allow access to your personal data in accordance with the PDPA. For the purposes of this Notice, the terms “personal data” and “processing” have the same meaning as prescribed in the PDPA.

This Notice is to inform you that your personal data is being processed by us or on our behalf. Please read this Notice to understand how we use personal data that we may collect from you. By providing us with your personal data, you agree and consent to this Notice and the collection, processing, use, storage and accessibility of your personal data in accordance with and as described in this Notice.

Collection of Personal Data and Personal Data Source
Your personal data is or will be collected from various sources or in a variety of ways, including without limitation:

(a) from any information submitted or provided by you to us for any purpose;
(b) by telephone, facsimile, mail, coupon, advertisement, website, email, registration forms, and/or by means of a simple text message system (“sms”);
(c) when you contact us through various means such as telephone calls, emails, and/or mails;
(d) from authorized third parties such as marketing companies; and
(e) from all other communications between you and us and from any other information that you may provide to us from time to time.

Description Of Personal Data That Will Be Collected
We may collect and process a variety of your personal data (including sensitive personal data such as physical or mental health or medical condition, religious beliefs or other beliefs of a similar nature, or any other sensitive personal data as prescribed by the law from time to time) which includes but is not limited to:

(a) introduction details such as your name, identification number, passport number, supporting identity documents such as identification card, gender, ethnic, race, nationality, date of birth, age, chosen language and marital status;
(b) your contact details such as your personal address, address stipulated in your identification card, house/ residential address, office/ business address, delivery address for marketing materials, phone number, email address and other contact details that you provide to us from time to time;
(c) if you are an individual, your occupation details such as your employer’s name, your designation in the company, job description, the company address, the company phone number, your salary range and professional qualification or qualification;
(d) if you are an enterprise, partnership or a corporation, the address of the enterprise, partnership or the corporation, details of the enterprise, partnership or corporation including but not limited to the details of the ownership of the enterprise, the details of the partner(s) or directorship/ shareholders details of the corporation;
(e) your payment details such as bank account number(s) and credit card or debit card details;
(f) your interest and personal preference to help us to standardize our marketing promotion and/or services that is most suitable for you;
(g) information that is related to the transaction, including personal individual data provided by a corporate entity related with a transaction or contract;
(h) telephone conversations;
(i) sms;
(j) if you are an individual, the details of your spouse, dependency or any other third party; and
(k) any other personal data transmitted or provided by you to us and all other personal data collected from you at any time.

Purposes
The personal data provided, has been given and will be given to Turning Point, is currently in use or will be used and will be processed by us for the following meaning and purposes:

(a) to carry our pre-contractual and contractual obligations with you;
(b) to verify your identity and background, and to minimize the risks of unauthorized access to your personal data when you are dealing with us;
(c) to consider and to process your queries on our services;
(d) for the purpose of marketing and advertising of our services, to the extend approved by the laws;
(e) for the delivery of marketing materials, sms, notices, documentations and forms;
(f) advertising and offering our services and to provide you with our services;
(g) providing you details about our promotions, services and business update of Turning Point, to the extend approved by the laws;
(h) to consider your personal data in the coupon and through other methods of us obtaining your personal data;
(i) to consider your application, queries and order;
(j) to communicate with you;
(k) to improve Turning Point’s services;
(l) to provide you with information, such as activities, events, offers or promotions, relating to our services and our partners and businesses, to the extend approved by the laws;
(m) to send you festive messages, to the extend approved by the laws;
(n) to customise Turning Point’s website according to your interests, as and when applicable and to the extend approved by the laws and the rules and/or guidelines imposed by the Board of Counsellors and Malaysia Society of Clinical Psychology;
(o) to process payment transactions and verify and execute the said transaction;
(p) to improve our communication with you;
(q) for administration of your participation in our campaigns;
(r) for internal record keeping;
(s) to implement internal requirements and activities of Turning Point;
(t) for the purpose of dispute resolution;
(u) to allow us to carry out our legal rights to recover any debts you owe us, if any;
(v) for internal investigation, compliance, audit or security purposes including, without limitation, criminal detection, crime prevention and prosecution;
(w) for market survey and interest analysis;
(x) for queries regarding sales and reward details;
(y) for other authorized business activities of Turning Point;
(z) for research on the demographic and behavioural pattern of our customers;
(aa) to meet any legal or regulatory requirements and to prevent or investigate any fraudulent or criminal activity; and/or

(collectively, “Meanings”).

Disclosure and Personal Data Transfer
Where required, we disclose or will disclose your personal data to our related corporations, business partners, service providers, credit reporting agencies, our financial or professional advisors, banks, government departments and agencies, law enforcement agencies, courts, tribunal, industry regulator(s), third party debt collectors, regulatory and/or statutory bodies and any third parties requested or authorized by you for any of these purposes in accordance with this Privacy Notice, all applicable data protection legislation and the rules and/or guidelines imposed by the Board of Counsellors and Malaysia Society of Clinical Psychology.

Where required, we may also give your personal data as a response to court order(s), subpoena(s), law enforcement agencies, government agencies and/or any other party to whom you have given express or implied permission. We also have the right to report to law enforcement agencies for any activity which we believe is illegal. We may disclose your personal data when we have reasonable grounds to believe such disclosure is necessary for the purpose of complying with and enforcing any of our terms of use or terms and conditions, or to protect the rights, property and security of others and Turning Point.

Your personal data may also be transferred to location(s) outside Malaysia to any third parties mentioned above, and kept in the file server (‘server’) located in or outside of Malaysia, for any Meanings stated in this Notice. You hereby consent to such transfer.

Mandatory Personal Data
It is mandatory for you to provide us with the information required which has been marked with asterisk (*) in the registration form (collectively, “compulsory personal data”). If you fail to provide us with such compulsory personal data, we may refuse to process your personal data for any of the Meanings stated above and/or cause us to be unable to provide you with the services requested.

Access To, Amendment, Enquiry and Complaint to and Limit of Processing of Personal Data
You have the right to request for access, enquire and request for amendments to your personal data held by us which is related to you. You also have the right to contact us with any questions or complaints regarding your personal data (including requests to limit the processing of your personal data or to stop or stop processing your personal data for direct marketing purposes). In general and subject to certain exceptions contained in the Act, you may, upon payment of a prescribed fee, make a data access request or a data amendment request in writing to us. We may refuse to comply with requests for data access or data amendment requests and must, by written notice, notify you of such refusal and the reasons therefore.

All inquiries, complaints, requests and applications may be made by registered post, telephone call (during office hours) or email to the address below, to our personal data protection officer.

Designation: Personal Data Protection Officer Turning Point Integrated Wellness Sdn Bhd
Telephone No.: +603-80638981,+603-80514518
Address: 10-2 & 10-3, Jalan Puteri 2/4, Bandar Puteri Puchong, 47100 Puchong, Selangor, Malaysia.

Update and Privacy Notice Amendment
This Notice may be amended from time to time to reflect the changes in law and business practices and the latest version will apply and replace all previous versions, including but not limited to versions in catalogues, marketing materials, or printed copies. Any amendment will be effective as soon as notice of it has been given to you through, including but not limited to, the broadcast made through e-mail, sms or through other methods which you will be notified of. Continued use of our services will be considered as your acceptance and consent to such modifications, updates or amendments.

Security of Personal Data
We shall keep and process your personal data provided by you in a secure manner. We will ensure your personal data is secure and we shall require any third party that handles or processes the said personal data for us to do the same. We shall, where practicable, implement the appropriate administrative and security safeguards and procedures in accordance with the applicable laws and regulations to prevent any unauthorised or unlawful processing of your personal data and to avoid any loss, misuse, modification, unauthorised or accidental access or disclosure, alteration and/or destruction of your personal data.

Retention of Personal Data
We will retain your personal data in compliance with this Notice for the duration the purpose of the personal data is required or your relationship with us (whichever is later). We will then destroy your personal data from our records in accordance with our internal policy.

Conflict
In the event of any inconsistency or discrepancy between the English version and the Malay version of this Notice, the Malay version shall prevail over the English version.

Accuracy of Personal Data
You are responsible to ensure that the information you provide to us is accurate, complete, not misleading and up to date. You will promptly update us in the event of any change to your personal data. The personal data collected and processed by us is deemed to be accurate until and unless you inform us otherwise in writing.

Third Partys’ Personal Data
We may seek your assistance if personal data relating to others is required to process your personal data for the Meanings and you hereby agree to use your best efforts to assist us when required. If any third-party personal data has been provided to us by you, you must ensure that such third party has read this Notice and agrees to process its personal data for any Meanings before providing it to us personally. You represent and warrant that you are authorised to provide the third-party personal data to us and you have obtained their consent to the processing (including disclosure and transfer) of their personal data in accordance with this Notice.

Acknowledgment and Consent
By communicating, engaging with Turning Point or use Turning Point’s services, you acknowledge that you have read and understood this Notice and agree and consent to the use, processing, disclosure and transfer of your personal data by Turning Point. You can also withdraw your consent by written notice or fill in the form available at our office.

Baca: Notis Privasi