Dokumen ini disediakan dalam bahasa Inggeris. Jika versi terjemahan disediakan, versi bahasa Inggeris akan diguna pakai sekiranya terdapat percanggahan.
1Introduction
Regal Global Sdn Bhd (“Regal Global”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.
This Privacy Policy and Personal Data Protection Notice (“Privacy Policy”) explains how we collect, use, process, disclose, store and protect personal data when you:
- visit www.regalglobal.com.my;
- register your interest in a property;
- make a property enquiry;
- request a property viewing;
- subscribe to our newsletters or marketing communications;
- communicate with us through telephone, email, WhatsApp, social media or other channels;
- create or use a client account;
- buy, sell, rent, lease or market a property through us;
- submit a property for sale or rental;
- participate in our events, exhibitions or promotions; or
- otherwise use our property consultancy, real estate or related services.
This Privacy Policy is intended to comply with the Personal Data Protection Act 2010 (Act 709) of Malaysia (“PDPA”), as amended from time to time, together with applicable regulations, standards, guidelines and requirements issued by the Personal Data Protection Commissioner of Malaysia.
For the purposes of applicable Malaysian personal data protection law, Regal Global acts as a data controller in respect of personal data for which we determine the purposes and means of processing.
2Scope of This Privacy Policy
This Privacy Policy applies to personal data processed by Regal Global in connection with our business and services.
It applies to, among others:
- website visitors;
- prospective purchasers;
- purchasers;
- property investors;
- prospective tenants;
- tenants;
- landlords;
- property owners;
- vendors;
- developers;
- clients;
- prospective clients;
- persons making enquiries;
- subscribers;
- event participants;
- business contacts; and
- users of our online platforms or client portals.
Separate notices, consent forms or contractual provisions may apply to certain services or transactions.
Where a specific privacy notice is provided for a particular service, transaction or campaign, that notice should be read together with this Privacy Policy.
3What Is Personal Data?
“Personal Data” generally means information relating directly or indirectly to an individual who is identified or identifiable from that information or from that information together with other information in our possession or likely to come into our possession.
Depending on your interaction with Regal Global, Personal Data may include information described in this Privacy Policy.
4Personal Data We May Collect
The type of Personal Data we collect depends on your relationship and interaction with Regal Global.
4.1Identity Information
We may collect:
- full name;
- identification document type;
- NRIC or MyKad number;
- passport number;
- nationality;
- date of birth;
- gender;
- photograph;
- signature;
- marital status; and
- other identification information where required for a transaction or by law.
We generally do not require identity-document information merely for browsing the Website or making a basic property enquiry.
4.2Contact Information
We may collect:
- mobile telephone number;
- home or office telephone number;
- WhatsApp number;
- email address;
- residential address;
- mailing address; and
- preferred communication method.
4.3Property Preference Information
When you enquire about a property, we may collect information concerning your property requirements, including:
- preferred location;
- property type;
- preferred development;
- purchase or rental intention;
- budget;
- preferred price range;
- desired floor area;
- preferred number of bedrooms;
- preferred facilities;
- investment objectives;
- expected move-in date;
- rental period;
- furnishing requirements;
- property viewing preferences; and
- other information you provide concerning your property requirements.
We may use this information to recommend properties that may be relevant to you.
4.4Property Transaction Information
Where you proceed with a property transaction, we may collect information such as:
- property details;
- property address;
- purchase or rental price;
- booking information;
- offer details;
- tenancy information;
- reservation information;
- Sale and Purchase Agreement information;
- tenancy agreement information;
- ownership information;
- transaction status;
- financing status;
- payment information;
- legal documentation;
- correspondence relating to the transaction; and
- other information necessary to facilitate the transaction.
5Information From Property Owners and Landlords
If you engage Regal Global to market, sell or rent a Property, we may collect:
- your name;
- contact details;
- identity information;
- proof of ownership;
- title information;
- property address;
- property photographs;
- property specifications;
- asking price;
- rental rate;
- tenancy information;
- bank information where required for legitimate transaction purposes;
- relevant property documentation;
- utility or management information;
- authority to market the Property; and
- correspondence between you and Regal Global.
We may also collect information concerning authorised representatives, joint owners, tenants or other parties involved in the Property where necessary.
If you provide us with Personal Data relating to another person, you are responsible for ensuring that you are authorised to provide such Personal Data to us where required by law.
6Financial and Financing Information
Where relevant to a transaction or where you request assistance with financing, we may collect information concerning:
- preferred financing amount;
- loan requirements;
- financing status;
- proof of income;
- employment information;
- bank-related documents;
- financial information;
- booking or deposit information; and
- other information reasonably required by banks, mortgage consultants, lawyers, developers or transaction parties.
Regal Global will only collect financial information where reasonably necessary for the relevant purpose.
We do not request that you disclose online banking passwords, PIN numbers, credit card PINs or similar security credentials to Regal Global.
7Employment and Occupancy Information
For certain rental or tenancy transactions, landlords may require tenant-profile information.
Where relevant, we may collect:
- occupation;
- employer;
- employment location;
- position;
- household size;
- number of occupants;
- relationship between occupants;
- expected tenancy commencement date;
- intended tenancy period;
- nationality;
- immigration or visa information where relevant; and
- other information reasonably requested by a landlord for the purpose of considering a tenancy application.
We will seek to limit such information to what is reasonably relevant to the proposed tenancy.
8Website and Technical Information
When you access the Website, certain technical information may be collected automatically.
This may include:
- IP address;
- browser type;
- operating system;
- device type;
- device identifiers;
- referring website;
- pages visited;
- links clicked;
- date and time of access;
- approximate location based on IP information;
- language preference;
- Website usage information;
- session information; and
- cookie or similar technology identifiers.
We may use this information for Website functionality, security, analytics and improvement.
9Client Account Information
If you create or are provided with an account on a Regal Global platform or client portal, we may process:
- username;
- encrypted or hashed password information;
- account identifier;
- account permissions;
- saved properties;
- enquiry history;
- transaction information;
- login history;
- account activity;
- communication preferences; and
- other account-related information.
You are responsible for keeping your account credentials confidential.
10Communications With Regal Global
We may retain records of communications between you and Regal Global, including communications through:
- Website enquiry forms;
- telephone calls;
- email;
- WhatsApp;
- messaging applications;
- social media;
- live chat;
- meetings;
- property viewings; and
- other communication channels.
These communications may contain Personal Data depending on the information you choose to provide.
Where calls or communications are recorded, we will comply with applicable notification and consent requirements.
11Marketing and Communication Preferences
If you subscribe to our updates or consent to receive marketing information, we may record:
- your marketing consent;
- your subscription status;
- communication preferences;
- properties or developments in which you have expressed interest;
- marketing messages sent to you;
- event participation;
- engagement with communications; and
- unsubscribe or opt-out requests.
12Sources of Personal Data
We may obtain Personal Data:
Directly from you
For example, when you:
- complete a Website form;
- register your interest in a Property;
- contact us;
- subscribe to updates;
- create an account;
- attend an event;
- request a viewing;
- enter into a transaction;
- provide documents to us; or
- communicate with our representatives.
From property-related parties
We may receive information from:
- property developers;
- property owners;
- landlords;
- vendors;
- purchasers;
- tenants;
- joint owners;
- authorised representatives;
- property managers; and
- other persons involved in a property transaction.
From professional and business partners
Where appropriate, information may be received from:
- lawyers;
- bankers;
- mortgage consultants;
- valuers;
- financial institutions;
- developers;
- referral partners;
- business partners; and
- other professional advisers.
From publicly available sources
We may obtain information from publicly accessible sources where permitted by law.
Through technology
We may obtain Website and usage information through:
- cookies;
- log files;
- analytics systems;
- Website technologies; and
- third-party technology providers.
13Purposes for Which We Process Personal Data
We may process Personal Data for purposes including the following.
13.1Property Enquiries
To:
- respond to enquiries;
- identify suitable Properties;
- provide property information;
- send brochures or floor plans;
- arrange consultations; and
- follow up on properties in which you have expressed interest.
13.2Property Recommendations
To understand your requirements and recommend properties that may be relevant to your:
- budget;
- location preference;
- property requirements;
- investment objectives;
- rental requirements; or
- other stated preferences.
13.3Property Viewings
To:
- schedule property viewings;
- coordinate with developers, owners, landlords or tenants;
- arrange access;
- manage appointments; and
- follow up following a viewing.
13.4Property Transactions
To facilitate:
- reservations;
- bookings;
- offers;
- property purchases;
- property sales;
- leasing;
- rental transactions;
- tenancy applications;
- negotiations;
- document preparation;
- handovers; and
- other activities connected with a real estate transaction.
13.5Owner and Landlord Services
To:
- verify ownership or authority;
- create Property Listings;
- market Properties;
- communicate with prospective purchasers or tenants;
- organise viewings;
- negotiate offers;
- manage enquiries; and
- facilitate property transactions.
13.6Financing and Professional Services
Where requested or appropriate, to facilitate introductions or communications with:
- financial institutions;
- mortgage consultants;
- lawyers;
- valuers;
- tax advisers;
- insurance providers; or
- other professional service providers.
Any services provided by such third parties are subject to their own terms and privacy practices.
13.7Customer Relationship Management
To:
- manage our relationship with you;
- maintain enquiry records;
- maintain transaction records;
- manage follow-up activities;
- provide customer support;
- understand client requirements; and
- improve our services.
13.8Account Administration
To:
- create and administer accounts;
- authenticate users;
- provide secure access;
- maintain account settings;
- investigate unauthorised access; and
- provide account support.
13.9Marketing
Subject to applicable law and consent requirements, we may use your Personal Data to send information relating to:
- new property launches;
- selected Property Listings;
- investment opportunities;
- exhibitions;
- property events;
- open houses;
- promotional campaigns;
- market updates;
- newsletters;
- Regal Global services; and
- other information that may be relevant to you.
13.10Website Operation and Analytics
To:
- operate the Website;
- analyse Website traffic;
- understand Website usage;
- improve Website performance;
- diagnose technical problems;
- improve user experience;
- develop new functionality; and
- measure the effectiveness of Website content.
13.11Security and Fraud Prevention
To:
- authenticate users;
- protect accounts;
- detect suspicious activities;
- prevent fraud;
- investigate security incidents;
- prevent unauthorised access;
- maintain audit logs; and
- protect Regal Global, our clients and third parties.
13.12Legal and Regulatory Compliance
To:
- comply with applicable laws;
- respond to regulatory authorities;
- comply with lawful requests;
- establish or defend legal claims;
- maintain statutory or business records;
- conduct appropriate verification;
- comply with court orders; and
- meet other legal or regulatory obligations.
13.13Internal Business Administration
To:
- administer our business;
- maintain internal records;
- conduct audits;
- manage business risks;
- perform business analysis;
- train employees and representatives;
- improve internal processes; and
- manage complaints or disputes.
14Basis for Processing
Regal Global will process Personal Data in accordance with applicable Malaysian law.
Depending on the circumstances, processing may take place:
- with your consent;
- where necessary for purposes directly related to the provision of services you request;
- in connection with contractual arrangements;
- to comply with legal or regulatory requirements;
- to protect legal rights;
- for purposes otherwise permitted under the PDPA; or
- under another lawful basis recognised by applicable Malaysian law.
Where consent is required, we will seek the appropriate consent.
You may withdraw consent in accordance with applicable law, subject to contractual or legal restrictions and reasonable notice.
Withdrawal of consent may affect our ability to provide certain services where the relevant Personal Data is necessary to perform those services.
15Whether Providing Personal Data Is Mandatory
Unless otherwise stated, providing Personal Data to Regal Global is generally voluntary.
However, certain information may be required to:
- respond effectively to an enquiry;
- arrange a property viewing;
- verify identity;
- perform a transaction;
- prepare documentation;
- comply with legal requirements;
- create an account;
- process a tenancy application;
- assist with financing; or
- perform other requested Services.
Where information is mandatory, failure to provide it may result in our inability to provide the relevant Service or proceed with the transaction.
16Disclosure of Personal Data
Regal Global does not sell your Personal Data to third parties.
We may disclose Personal Data where reasonably necessary for the purposes described in this Privacy Policy.
Recipients may include the following categories.
16.1Regal Global Personnel and Representatives
Including our:
- directors;
- employees;
- authorised real estate negotiators;
- sales personnel;
- consultants;
- contractors; and
- authorised representatives.
Access will be limited according to appropriate business requirements.
16.2Property Developers
Where you enquire about or purchase a development, relevant Personal Data may be provided to the developer or its authorised representatives to:
- register your interest;
- confirm availability;
- make reservations;
- administer bookings; or
- facilitate the transaction.
16.3Property Owners and Landlords
Where you enquire about a sub-sale or rental Property, necessary information may be shared with the property owner or landlord to:
- consider an offer;
- consider a tenancy application;
- arrange a viewing;
- negotiate a transaction; or
- complete the transaction.
16.4Purchasers and Tenants
Where Regal Global acts for a vendor or landlord, relevant information may be shared with prospective or confirmed purchasers or tenants where necessary to facilitate a transaction.
16.5Professional Advisers and Service Providers
Personal Data may be disclosed where appropriate to:
- solicitors;
- banks;
- financial institutions;
- mortgage consultants;
- valuers;
- accountants;
- auditors;
- tax advisers;
- insurance providers;
- property managers;
- building management; and
- other relevant professional service providers.
16.6Technology and Operational Service Providers
We may engage third parties to provide:
- Website hosting;
- cloud hosting;
- database services;
- customer relationship management systems;
- email services;
- SMS services;
- WhatsApp or messaging services;
- analytics;
- cybersecurity;
- backup services;
- document storage;
- marketing technology;
- technical support; and
- other business infrastructure.
Such providers may process Personal Data on our behalf or in connection with the services they provide.
Where required, we will take reasonable steps to ensure appropriate data protection obligations are imposed on such providers.
16.8Corporate Transactions
Personal Data may be disclosed in connection with:
- a merger;
- acquisition;
- restructuring;
- investment;
- sale of business or assets;
- corporate reorganisation; or
- similar transaction,
subject to appropriate confidentiality and legal safeguards.
17Third-Party Platforms
You may communicate with Regal Global using third-party platforms such as:
- WhatsApp;
- Facebook;
- Instagram;
- LinkedIn;
- WeChat;
- Xiaohongshu;
- email services; or
- other social or messaging platforms.
When using such platforms, your Personal Data may also be processed by the relevant platform provider in accordance with its own privacy policy and terms.
Regal Global does not control the independent processing performed by those third-party platform providers.
You should review their privacy policies before providing Personal Data through those services.
18Cross-Border Transfer of Personal Data
Some of our service providers, technology infrastructure, professional advisers, developers, partners or recipients may be located outside Malaysia, or may store or process information using infrastructure located outside Malaysia.
Accordingly, your Personal Data may in certain circumstances be transferred to or accessed from jurisdictions outside Malaysia.
Where Regal Global transfers Personal Data outside Malaysia, we will take steps reasonably required to comply with the PDPA and applicable cross-border personal data transfer requirements.
Depending on the applicable transfer mechanism, these measures may include:
- assessing the protection available in the destination jurisdiction;
- implementing appropriate contractual or organisational safeguards;
- ensuring the transfer is necessary for an applicable permitted purpose; or
- obtaining your consent where consent is relied upon as the legal basis for the transfer.
Where we specifically rely on your consent for a cross-border transfer, we will provide information regarding the relevant class of third-party recipient and purpose of the transfer as required by applicable law.
19Direct Marketing
Where permitted by law and subject to applicable consent requirements, Regal Global may use your contact information to communicate with you regarding property and related opportunities.
Marketing communications may be sent through:
- email;
- WhatsApp;
- telephone;
- SMS;
- messaging applications; or
- other communication channels.
You may request that we stop processing your Personal Data for direct marketing purposes at any time.
You may:
- click an unsubscribe link where provided;
- reply to the communication requesting to unsubscribe;
- inform the Regal Global representative contacting you; or
- contact Regal Global using the details in Section 32.
We will process valid opt-out requests as required under applicable law.
You may continue receiving non-marketing communications that are necessary for an existing enquiry, appointment, Property transaction, contractual relationship or legal obligation.
21Analytics
Regal Global may use Website analytics services to understand Website usage and improve our digital services.
Analytics providers may collect information such as:
- IP address;
- device information;
- browser details;
- referring pages;
- Website activity;
- session duration; and
- interactions with Website content.
Where appropriate, we will configure analytics services and consent controls in accordance with applicable data protection requirements.
22CAPTCHA and Website Security Services
Our Website forms may use CAPTCHA or similar anti-abuse technology to distinguish legitimate users from automated or malicious activity.
Such technology may collect technical information about your device, browser, network and interaction with the Website.
Where a third-party CAPTCHA provider is used, that provider may process information in accordance with its own terms and privacy policy.
23Automated Tools, Recommendations and Profiling
Regal Global may use technology to assist with:
- property matching;
- property recommendations;
- enquiry prioritisation;
- marketing segmentation;
- Website personalisation;
- client relationship management; or
- analysis of property preferences.
For example, a system may recommend Properties based on your stated:
- budget;
- location;
- property type;
- previous enquiries; or
- preferences.
Where automated processing or profiling is used, Regal Global will seek to comply with applicable Malaysian personal data protection requirements.
Unless specifically disclosed to you and permitted by applicable law, Regal Global does not intend to make decisions that produce significant legal effects concerning you solely through automated decision-making without appropriate safeguards.
24Data Accuracy
We take reasonable steps to ensure that Personal Data used by Regal Global is accurate, complete, not misleading and kept up to date where necessary for the relevant purpose.
You are encouraged to notify us promptly if your information changes.
You may request correction of Personal Data in accordance with Section 29 of this Privacy Policy.
25Data Security
Regal Global takes reasonable practical steps to protect Personal Data against:
- loss;
- misuse;
- modification;
- unauthorised access;
- unauthorised disclosure;
- alteration;
- accidental destruction; and
- unlawful processing.
Depending on the systems and information concerned, security measures may include:
- access controls;
- authentication;
- password controls;
- encryption;
- secure communications;
- antivirus and endpoint protection;
- firewalls;
- monitoring;
- logging;
- backups;
- employee access restrictions;
- confidentiality obligations;
- vendor controls; and
- security procedures.
However, no Internet transmission, electronic communication or storage system can be guaranteed to be completely secure.
Users should also take reasonable precautions to protect their devices and account credentials.
26Personal Data Breaches
Regal Global maintains procedures for assessing and responding to suspected Personal Data breaches.
Where a Personal Data breach occurs, we will assess the incident and take appropriate steps in accordance with applicable law.
Where notification thresholds or other legal requirements are met, we will notify the Personal Data Protection Commissioner and affected data subjects within the periods required by applicable Malaysian law.
We may also take measures to:
- contain the incident;
- investigate its cause;
- reduce potential harm;
- recover affected systems;
- implement corrective measures; and
- prevent recurrence.
27Retention of Personal Data
Regal Global will retain Personal Data only for as long as reasonably necessary for the purpose for which it was collected or for another permitted purpose.
Retention periods may depend on:
- the nature of our relationship with you;
- whether a property transaction takes place;
- legal requirements;
- regulatory requirements;
- accounting requirements;
- tax requirements;
- contractual requirements;
- limitation periods;
- dispute or litigation requirements;
- fraud prevention;
- security requirements; and
- legitimate recordkeeping needs permitted by law.
When Personal Data is no longer required, we will take reasonable steps to:
- securely delete it;
- destroy it;
- anonymise it; or
- otherwise prevent further processing,
subject to applicable legal and operational requirements.
28Your Rights
Subject to the PDPA and any applicable exceptions, restrictions, conditions or procedures, you may have rights concerning Personal Data held by Regal Global.
These may include the following.
28.1Right to Be Informed
You have the right to receive information about the collection and processing of your Personal Data.
This Privacy Policy is intended to provide such information.
28.2Right of Access
You may request access to Personal Data held by Regal Global concerning you, subject to applicable legal requirements and exceptions.
28.3Right to Correction
You may request correction of Personal Data that is:
- inaccurate;
- incomplete;
- misleading; or
- not up to date.
28.4Withdrawal of Consent
Where processing is based on your consent, you may withdraw that consent by providing notice to us.
Withdrawal of consent does not automatically affect processing that took place lawfully before the withdrawal.
It may also affect our ability to continue providing a Service that requires the relevant Personal Data.
28.5Right to Prevent Direct Marketing
You may request that Regal Global stop processing your Personal Data for direct marketing purposes.
28.6Right to Prevent Certain Processing
Where provided by applicable law, you may object to or request the cessation of processing that causes or is likely to cause unwarranted damage or distress.
28.7Data Portability
Where applicable under the PDPA, you may request the transmission of your Personal Data to another data controller, subject to:
- applicable legal conditions;
- technical feasibility;
- compatibility requirements; and
- any exceptions prescribed by law.
28.8Rights Concerning Automated Decision-Making
Where applicable under Malaysian law, you may have rights relating to certain decisions based solely on automated processing.
Regal Global will comply with applicable requirements concerning automated decision-making and profiling.
29Exercising Your Rights
Requests regarding Personal Data may be submitted to Regal Global using the contact details provided in Section 32.
Please provide sufficient information for us to:
- identify you;
- identify the information concerned; and
- understand the nature of your request.
For security reasons, we may need to verify your identity before processing certain requests.
Requests will be handled in accordance with applicable Malaysian law.
Where permitted by law, we may refuse or limit a request in certain circumstances and will provide an appropriate explanation where required.
30Children and Minors
Regal Global's Website and property services are generally intended for adults.
We do not knowingly seek to collect Personal Data from children through general property enquiry or marketing functions.
Where a transaction legitimately involves Personal Data concerning a minor, we will seek to process such information in accordance with applicable legal requirements, including requirements concerning parents or legal guardians where relevant.
If you believe a child has provided Personal Data to Regal Global without appropriate authority, please contact us.
31Third-Party Websites
Our Website may contain links to external websites operated by:
- developers;
- banks;
- government agencies;
- social media platforms;
- mapping providers;
- professional service providers; or
- other third parties.
This Privacy Policy does not govern independent websites or services operated by those third parties.
Regal Global is not responsible for their independent privacy practices.
You should review the privacy policy of the relevant third-party website or service before providing Personal Data.
32Contacting Regal Global About Personal Data
If you have questions, requests or complaints regarding this Privacy Policy or the way Regal Global processes Personal Data, please use the contact details set out at the end of this page.
If Regal Global appoints a Data Protection Officer in accordance with applicable law, the appropriate Data Protection Officer contact information may also be published on the Website or provided upon request.
33Data Protection Officer
Regal Global will appoint and register one or more Data Protection Officers where required under applicable Malaysian personal data protection law.
The Data Protection Officer, where appointed, will support Regal Global in matters including:
- PDPA compliance;
- internal data protection policies;
- data-subject requests;
- Personal Data breaches;
- data protection assessments;
- regulatory communications; and
- other Personal Data protection matters.
Data subjects may contact Regal Global using the details in Section 32 regarding any data protection matter.
34Complaints
If you have concerns about how Regal Global handles your Personal Data, we encourage you to contact us first so that we can investigate the matter.
You may also have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia in accordance with applicable law.
35Changes to This Privacy Policy
Regal Global may update this Privacy Policy from time to time to reflect:
- changes to our Services;
- changes to the Website;
- changes to technology;
- changes to our processing activities;
- legal or regulatory developments; or
- changes to our business operations.
The latest version will be published on www.regalglobal.com.my with the updated revision date.
Where required by law, we will provide additional notice or obtain additional consent for material changes.
You are encouraged to review this Privacy Policy periodically.
36Language
This Privacy Policy may be made available in English, Bahasa Malaysia, Chinese or other languages.
Where different language versions are provided, Regal Global will endeavour to ensure that they are consistent.
Where permitted by law, the English version may be designated as the prevailing version in the event of inconsistency.
37Relationship With Terms of Use
This Privacy Policy should be read together with Regal Global's Terms of Use and any other terms or notices applicable to specific Services.
If a transaction is subject to a separate agreement containing additional Personal Data provisions, those provisions shall apply together with this Privacy Policy to the extent relevant.
38Acknowledgement
By providing Personal Data to Regal Global, you acknowledge that you have been provided with this Privacy Policy and understand the manner in which Regal Global may collect, process, use, disclose and protect Personal Data as described herein, subject to applicable law.
Where consent is specifically required under the PDPA, Regal Global will obtain such consent through the appropriate form, checkbox, declaration, agreement or other method.
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