This Notice is given to you pursuant to Section 7 of PDPA as:

• Our Customer and/or
• Our Business Associates.

It is given to you by us in relation to your Personal Data collected, held or processed by us or to be collected by us.

Information, which is Personal Data, is regulated by PDPA. This Notice is to help you understand when and why we collect information about you, the type of information we collect, the third parties to whom we may disclose such information and some of your rights and choices and the related matters. 

 

Definitions

When we use the terms below, we mean them to have the following meanings:

CCTV	Closed circuit television.
Our Business Associates	Our supplier, contractor, sub-contractor or whoever that has any type of business dealing with us, whether past, current or intended.
Our Customer	Our customer whether past, current or intended.
PDPA	Personal Data Protection Act 2010 of Malaysia.
Personal Data	Information about yourself (where applicable, this includes information which relates to other persons who may be identified from information about yourself) which is “personal data” as defined by Section 4 of PDPA.
You / your / yourself	The addressee of this Notice.
We / our / us / ourselves	Global Top Training PLT Registration No. 201404002236 (LLP0003683-LGN)

When we refer to a written law in this Notice, we mean to include, any amendments, modifications or substitution to it and any subsidiary legislation, guidelines, regulations and similar things made under or in relation to such written law.

 

How do we collect your Personal Data

• When you provide us your details for registration of our trainings and or when you communicate with us to become our customer and/or business associates.
• We maintain a website or websites which give information about ourselves. We may collect your details when you visit our website at globaltoptraining.com
• When we record our trainings through zoom or other electronic means, your images and action, voice & names may be recorded as well.
• When we take photos during physical trainings at your premises or at the hotels or any other places, your images may be photographed.
• When you visit out officers, your images, actions and voice may be recorded by our CCTV surveillance systems and other surveillance systems. 

 

What sort of Personal Data we collect  

We may collect a variety of Personal Data pursuant to Section 4 of PDPA as follows:  

• details of any person referring you to us.
• details of any contract or other arrangement which you may have with us.
• your name, photograph and/or other images, sound recordings, age, identity card, passport or other identification document numbers and details, address, gender, race and/or ethnic origin, nationality, current and savings account number, credit card details, bank name and other pertinent banking information, tax file identification number, EPF number, SOSCO number, date of birth, details of your spouse and/or your marital or other relationship, children or other family members or persons with whom you may be in a relationship, occupation, financial information (including financing arrangements), assets, qualifications, work experience, employment information, employer, income information, telephone, electronic mail and other means of communication and other Personal Data. 

What we do with the Personal Data collected

We collect, use and process your Personal Data for the following purposes:

• To register you for our training programmes.
• To prepare your Certificate of Attendance.
• To send you video of the training that you have registered with us.
• To send you newsletters about our training programmes and activities.
• To correspond with you or any other relevant person (this may be by letter, electronic mail, telephone call or any other way and may be with persons in any jurisdiction) in relation to our business arrangement with you and/or any relevant matters.
• To prepare the relevant agreements, contracts, legal documentation or forms or any other applicable documents.
• To carry out our administration and daily operation.
• To conduct credit checks and other backgrounds checks as we may determine to be necessary or appropriate.
• To maintain our books and records (these may be kept in any media, and include, paper and electronic) for the purpose of review or audit by independent professionals for compliance, security, integrity and/or good governance (including auditors from accounting firms and independent anti-money laundering procedure auditors).
• To transfer your Personal Data (these may be in electronic, paper or other media) to our third-party service or storage providers or contractors or sub-contractors (these may be in any jurisdiction) for purposes of data storage, back up or processing.
• To provide your Personal Data to our third-party service providers, agents, contractors or management companies for the purpose of rendering services to you directly.
• To meet any requirements of laws or regulations or court order or direction, guideline, practice note, circular, code or other requirement of any governmental, public or regulatory authority.

Apart from Malaysia, our collection, use and processing of Personal Data (including any disclosure) may be in, to, or from any jurisdiction outside Malaysia. We may continue to collect, use and process your Personal Data even after you are no longer our customer or business associate. 

 

What if you do not give us your Personal Data or we cannot collect, use or process it

• We will not able to register you for our training programmes.
• We will not be able to send you newsletters about our training programmes and activities.
• We will not be able to accept or retain you as a customer and/or a business associate as it could adversely affect our operations and/or obligations. 

 

Who we disclose to

We generally keep your Personal Data confidential. However, we may disclose them to the following in certain circumstances:

• Any governmental, public or regulatory authority in any jurisdiction when required by such authority or under the law or regulation of any jurisdiction which applies to us.
• Any persons you consent to under our business agreement with you.
• Our auditors, independent anti-money laundering auditors, lawyers and other financial or professional advisers.
• Our third-party service, product or storage providers, contractors, sub-contractors, agent.

We may give or disclose to any of them even if they are outside Malaysia and even if you are no longer our customer or business associate. 

 

Security

We are required under PDPA, when processing your Personal Data, to take certain practical steps to protect your Personal Data from any loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction. 

 

You have right to access and correct your Personal Data and to withdraw your consent given to us to handle your Personal Data

You may:

• Ask us to tell you whether we hold or use your Personal Data and ask to access it
• Ask us to correct any of your Personal Data which is not accurate, complete or up-to-date
• Ask us to retain Personal Data for only as long as is necessary to fulfil the purpose for which we collected it
• Ask that we specify or explain our policies and procedures in relation to Personal Data and the types of Personal Data we handle.
• Object to the use of Personal Data for newsletters or other materials to inform you of our training programmes and activities.
• Withdraw, (in writing) wholly or partly any consent you provided previously subject to a reasonable time period.

Your right above may be restricted. You may have entered into contractual arrangements which limit your rights or your rights may be limited by law or regulation or the particular circumstances.

You may contact us as below if you wish to exercise any of your rights above and reasonable administration fee may be imposed:

Personal Data Protection Affairs Manager

Global Top Training PLT

Block 1-3-5 Azuria, No. 18, Jalan Lembah Permai, 11200 Tanjung Bungah, Penang.   Tel/Fax: 04-8901602

Email: ooi@globaltoptraining.com or yen@gloabltoptraining.com or globaltop.anna@gmail.com

 

Consent

If you give or continue to give us your Personal Data, you will be deemed to consent to your Personal Data being collected, held or processed by us in the way as specified in this Notice and or in any other notices issued under Section 7 of PDPA.

You may also be regarded as giving your consent by your particular act or conduct in certain circumstances. Please be informed that even if you do not give your consent (whether by expressed consent or in any other way), we may still be authorised or required by applicable laws or regulations or in certain circumstances to disclose or give your Personal Data. Your consent will remain effective regardless of any change in your relationship with us, for example, you are a current customer or business associate then you cease to be one.