This Policy applies to the Nawawi Tie Leung group of companies, namely Nawawi Tie Leung Property Consultants Sdn Bhd and Nawawi Tie Leung Real Estate Consultants Sdn Bhd.

We at Nawawi Tie Leung respect the privacy and confidentiality of our Clients’ personal data. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Malaysia Personal Data Protection Act 2010.

We have developed this Data Protection Policy to assist you in understanding how we collect, use, disclose, process and retain your personal data with us.

How We Collect Your Personal Data

The PDPA defines personal data as “data, whether true or not, about an individual who can be identified a) from that data; or b) from that data and other information to which the organisation has or is likely to have access.”

We collect the personal data of our Clients or potential Employees/Associates in the following ways:

• When you leave your contact details with us after attending our events e.g.,marketing events such as roadshows and seminars;
• When you leave your contact details with us after visiting our websites and portals, or making enquiries on other third party portals;
• When you visit our showrooms or open houses and leave behind your contact details or express an interest to preview a unit;
• When you express an interest on the property we are marketing e.g., to book a unit at our property launch; When you interact with our Employees, Associates or Coordinators, e.g. via telephone calls, faxes, text messages, face-to-face meetings or emails;
• When you respond to some of our marketing collaterals e.g. advertisements, brochures or flyers;
• When you fill in our application, registration, enquiry or survey forms;
• When you engage our Employees or Associates to help market and transact the sale, purchase or leasing of a property;
• When you book or reserve a serviced apartment online;
• When you engage our valuation or auction services, or participate in our auctions;
• When you engage our services or do transactions with us in other business areas;
• When you respond to our job advertisements in newspapers, websites, etc;
• When you submit your job application form and CV to us; and
• When you provide feedback or make a complaint to us.

Types of Personal Data We May Collect About You

• Personal contact information
• Personal particulars;
• Family details – for job applicants/associates;
• Financial information – for job applicants/associates;
• Work experience – for job applicants/associates.

How We Use Your Personal Data

We use the personal data we have collected about you for one or more of the following purposes:

• Inform you of property launches, sale or leasing of properties;
• Conduct balloting exercises at property launches;
• Check with government agencies;
• Service your booking of a unit at property launches;
• Follow up on your expression of interest to purchase or rent a property;
• Process and complete a property sale or leasing transaction;
• Perform valuation of properties;
• Conduct property auctions;
• Conduct market research and analysis; and
• Process job applications.

Who We Disclose Your Personal Data To

We may disclose some of the personal data we have collected about you to the following parties or organisations outside Nawawi Tie Leung:

• Property developer or owner – Client (buyer’s) particulars;
• Property buyer – Client (seller’s) particulars;
• Landlord – Client (tenant’s) particulars;
• Tenant – Client (landlord’s) particulars;
• Partners – Client’s particulars;
• Co-brokers – Client’s particulars;
• Government agencies;
• Industry associations – Employees’/Associates’ particulars; and
• External service providers (mailing houses, courier services, delivery services) – Client’s contact information.

How We Manage the Collection, Use and Disclosure of Your Personal Data

Obtaining Consent
To the fullest extent required by the PDPA, before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We next obtain written confirmation from you on your expressed consent. As far as possible, we will not collect more personal data than necessary for the stated purpose.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you enter into an Option to Purchase in the sale of a property.

Third-Party Consent
If you have a one-on-one meeting with us or do a transaction with us on behalf of another individual, you must first obtain consent from that individual in order for us to collect, use or disclose his/her personal data.

Withdrawal of Consent
If you wish to withdraw consent, you should give us reasonable advance notice. You have to be aware, though, of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future property launches.

Your request for withdrawal of consent can take the form of an email or letter to us, or through the “UNSUB” feature in an online service.

How You Can Access and Make Correction to Your Personal Data

You may write in to us, to find out how we have been using or disclosing your personal data. We are obligated under the PDPA to allow you access to your personal data of the past one year, and to make any correction if there is any error or omission. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will try to respond to your request within 30 days. By which time we will give you an estimate of how long it is going to take to retrieve all the relevant data.

How We Ensure the Accuracy of Your Personal Data

We will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up-to-date. From time to time, we may do a verification exercise with you to update us on any changes to your personal data.

Protection of Personal Data

We will take the necessary security arrangements to protect your personal data that is in our possession to prevent unauthorised access, use, disclosure, or similar risks. All our Employees/Associates will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.

Retention of Personal Data

We will not retain any of your personal data under our charge when it is no longer necessary for any business or legal purposes. Based on our Data Retention Policy, we will ensure that your personal data that are no longer needed by us will be destroyed or disposed of in a secure manner.

Handling Queries and Complaints

If you have any query or feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer at:

Nik Nor Mazneen Nik Mustapa
Tel: +603 2161 7228
Email: [email protected]

Any query or complaint should include, at least, the following details:

• Your full name and contact information
• Brief description of your query or complaint

We treat such queries and complaints seriously and will deal with them confidentially and within reasonable time.

¹“Associate” refers to any Salesperson, registered with the Board of Valuers, Appraisers and Estate Agents Malaysia, who enters into an Associate Agreement with Nawawi Tie Leung Property Consultants Sdn Bhd and Nawawi Tie Leung Real Estate Consultants Sdn Bhd.