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PRIVACY AND PERSONAL DATA PROTECTION POLICY
The Personal Data Protection Act 2010 (the “Act”), which regulates the processing of personal data in commercial transactions apply to the JRX Global Sdn Bhd (Hereafter refer to as JRX) and its subsidiaries and related corporations (“our”, “us” or “we”). 
This Policy sets out how JRX uses and protects your personal information that you give us. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this Policy.
Consent
This Policy serves to inform you that your personal data is being processed by us or on our behalf. By providing us with your Personal Data or continuing to communicate with us, we shall regard that you have consented to the processing of such data pursuant to this Policy.
Description of Personal Data 
We may collect a variety of information and/or data about yourself (“Personal Data”) including but not limited to your name, date of birth, race, religion, gender, company name, Malaysian Identification Card number, nationality, biometrics information, e-mail address, address, contact number, credit card details, bank account details, health information, food preference, allergy, photographs, occupation, marital status, video recording, CCTV images, and all other personal data we again collect from you on any subsequent occasion.
Purpose 
Your Personal Data is being or is to be collected and further processed for:
(a) Ensuring that you continue to receive our service;
(b) Contacting you in case of any change of appointment dates;
(c) Managing records and reports;
(d) Facilitating payment processes;
(e) Reporting personal data to the relevant bodies and/or third parties under the laws applicable;
(f) Sharing personal data with our global partners and related companies in order to perform your requested task.
(g) Conducting research, analysis and improvement;
(h) Marketing and advertisement purposes and surveys;
(i) Facilitating overseas personal requirements (for example, visa and residency information);
(j) Administering and responding to request, queries, complaints and legal issues;
(k) Facilitating human resource management activities relating to employees;
(l) For submission, registration of relevant forms, licences to regulatory authorities and/or third parties under laws applicable;
(m) For education and training (with anonymized data where possible);
(o) Assessing your credit worthiness and processing any payments relevant to you;
(p) Insurance purposes, third party administration and any other third parties;
(q) Purposes of enforcing our legal rights and / or obtaining professional or legal advice;
(r) Internal records management;
(s) Conducting internal activities such as evaluating the effectiveness of marketing, market surveys/research, trend analysis, statistic compilation, reporting, audit, compliance, risk management, and data analytics to improve our services;
(t) Complying with any legal or regulatory requirements such as audit and/or requests from regulatory bodies;
(u) Instituting debt recovery proceedings against defaulters
(Collectively, the “Purposes”).
Source of Personal Data
Your Personal Data is being or is to be collected:
(i) directly from you when you or your representative fill in the registration forms at our facilities, or contact us via emails, online enquiry forms, social media chat, mobile app chat platform, letters or telephone calls, or when taking part in customer surveys and promotions and during marketing activities,
(ii) From any third parties connected with you such as your friend / family / employer / potential employer, agents, insurance companies, other facilities/providers you authorised.
(iii) From such other sources to whom you have given your consent to disclose information relating to you,
(iv) From events,
(v) From CCTV recordings,
(vi) From audio/video recordings,
(vii) From doctors’ letters,
(viii) From medical reports/records,
(ix) From all other personal data we again collect from you on any subsequent occasion, and
(x) From all other information that you may provide us from time to time.
Access to, correction of and limiting the processing of Personal Data
You have the right to request access to and to request correction of your personal data and to contact us with any inquiries or complaints in respect of your personal data (including the possible choices and means for limiting the processing of your personal data or, to cease or not begin processing your Personal Data for purposes of direct marketing) through our website enquiry forms.
(a)    Subject to applicable legal restrictions, contractual conditions and reasonable time period given to us, you may withdraw or amend, in full or in part, your consent given previously for use of your Personal Data.
(b)    Depending on your request, there may be circumstances where we refuse to comply with a data access request or a data correction request and shall, by notice in writing, inform you of our refusal and the reasons of our refusal.
(c)    We may also require the requestor of Personal Data (where the requestor is not the owner of Personal Data) to provide consent form of the owner of Personal Data authorizing and indemnifying us to release or correct the Personal Data.
Compulsory Personal Data 
It is obligatory that you supply us the details in our registration form. If you fail to supply us the Compulsory Personal Data, this can result in us being unable to provide you with the services requested and/or unable to perform the contract entered into.
Consequences of Refusal / Failure to Provide Personal Data
The refusal or failure to provide Personal Data may result in the following for which we shall not be held liable for any of the consequences arising from:
(a)    the inability of parties to formalize any contract and/or agreement, to facilitate provision of our services or to hire human resources;
(b)    the inability for us to provide you with services and/or products requested;
(c)    the inability for us to update you on our latest services and/or products and/or appointment dates;
(d)    the inability to complete transactions in relation to our products and/or services; and
(e)    the inability to comply with any applicable law, regulation, direction, court order, guidelines and/or codes applicable to us.
Disclosure of Personal Data 
We disclose or may disclose your Personal Data to the following
(a)    other entities within the JRX and our related corporations,
(b)    our medical specialists, including medical specialists and experts from our related corporations;
(c)    insurance companies,
(d)    banks, financial institutions, credit card or debit card issuers for processing of payment,
(e)    credit check companies,
(f)    debt collection agencies to recover outstanding debt owing to us,
(g)    your employer or your organisation of work,
(h)    your next of kin and your authorised second contact,
(i)    research organizations,
(j)    social welfare organization,
(k)    medical and healthcare professionals,
(l)    external counterparts for situation deemed emergency or necessary,
(m)    parents or guardians of minors,
(n)    agents, contractors and vendors who process data for us,
(o)    laboratories and diagnostic service providers 
(p)    data centers which host data for the company
(q)    external lawyers;
(r)    external auditors and accountants
(s)    governmental bodies, their agencies and other related organisations such as Ministry of Health, Ministry of Human Resources, Ministry of Home Affairs, Malaysian Anti-Corruption Commission, Inland Revenue Department, Malaysian Department of Insolvency, Royal Malaysian Police, Malaysian Medical Council, Malaysian Dental Council and Malaysian Medical Association,
(t)    regulatory and/or statutory bodies,
(u)    accreditation bodies and
(v)    any such third party requested or authorized by you for any of the Purposes.
Third parties are required to process your Personal Data in line with principles specified by us and/or the applicable law. They are also held responsible for securing your Personal Data at an appropriate level of security in relation to applicable data protection laws and accepted industry standards.
Protection of Personal Data
Your Personal Data will be kept and processed in a secured manner. We are committed to take appropriate administrative and security safeguards and procedures to prevent unlawful processing of, and the accidental loss, destruction or damage to your Personal Data. Access to your Personal Data is limited to and provided only to relevant users for the purpose of performing their duties.
Third party personal data 
We may require your assistance if the personal data relating to other persons (for example, your next of kin or appointed secondary contact) is required to process your Personal Data for the Purposes and you hereby agree to use your best endeavors to assist us when required. In the event that personal data of any third party is supplied by you to us, you shall ensure that such third party has read this Policy and consented to us collecting his/her personal data for any of the Purposes prior to the supply of his/her personal data to us.
Transfer of Personal Data to places outside Malaysia 
To the extent where this is permitted under law, we may transfer your Personal Data to a place outside Malaysia and you hereby give your consent to the transfer. JRX is the contracted distributor of Revotera Medikal Teknolojiler A.Ş., a global company affiliates with partners in different countries. JRX has an international presence and for contractual or assessment purposes must also share your data with so-called third countries within the JR’s partner, in particular also to CTech Labs Edwar Technology Company based in Indonesia and Argea Teknoloji A.S based in Turkey. By providing your personal data, there is a separate request of your consent to this transfer, storage or processing. For example, if you are a Malaysia citizen and you provide your information for health assessment purposes, your personal information will be sent to the Indonesia and Turkey. We take all reasonable steps to process your personal data securely and in accordance with this Privacy Policy. 
Accuracy of your Personal Data 
You are responsible for ensuring that the information you provide us is accurate, complete, not misleading and kept up to date.
Conflict 
In the event of any inconsistency between the English version and other languages translated version of this Policy, the English version shall prevail.
Security
The safety of your personal data is an important concern for us. We take appropriate steps, including technical, administrative, and physical security measures to protect the personal data provided to us against loss, misuse, and unauthorized access, disclosure, amendment, and deletion. However, no Internet security or physical transmission processes is deemed to be 100% safe. Although we will do our level best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Always exercise caution when transmitting personal data via the Internet.
Changes to this Policy 
We Review Our Policy from time to time in order to ensure compliance with applicable law, and to optimize and further develop them, since the protection of your personal data is an important concern for us. We may change this Policy by updating this page as and when needed without notification in order to comply with the changes in business operations or laws or regulations. Please check here periodically for all updates and changes to our privacy policy.

Updated date: 16 January 2022

PRIVACY AND PERSONAL DATA PROTECTION POLICY

The Personal Data Protection Act 2010 (the “Act”), which regulates the processing of personal data in commercial transactions apply to the JRX Global Sdn Bhd (Hereafter refer to as JRX) and its subsidiaries and related corporations (“our”, “us” or “we”).

This Policy sets out how JRX uses and protects your personal information that you give us. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this Policy.

Consent

This Policy serves to inform you that your personal data is being processed by us or on our behalf. By providing us with your Personal Data or continuing to communicate with us, we shall regard that you have consented to the processing of such data pursuant to this Policy.

Description of Personal Data

We may collect a variety of information and/or data about yourself (“Personal Data”) including but not limited to your name, date of birth, race, religion, gender, company name, Malaysian Identification Card number, nationality, biometrics information, e-mail address, address, contact number, credit card details, bank account details, health information, food preference, allergy, photographs, occupation, marital status, video recording, CCTV images, and all other personal data we again collect from you on any subsequent occasion.

Purpose

Your Personal Data is being or is to be collected and further processed for:

(a) Ensuring that you continue to receive our service;

(b) Contacting you in case of any change of appointment dates;

(c) Managing records and reports;

(d) Facilitating payment processes;

(e) Reporting personal data to the relevant bodies and/or third parties under the laws applicable;

(f) Sharing personal data with our global partners and related companies in order to perform your requested task.

(g) Conducting research, analysis and improvement;

(h) Marketing and advertisement purposes and surveys;

(i) Facilitating overseas personal requirements (for example, visa and residency information);

(j) Administering and responding to request, queries, complaints and legal issues;

(k) Facilitating human resource management activities relating to employees;

(l) For submission, registration of relevant forms, licences to regulatory authorities and/or third parties under laws applicable;

(m) For education and training (with anonymized data where possible);

(o) Assessing your credit worthiness and processing any payments relevant to you;

(p) Insurance purposes, third party administration and any other third parties;

(q) Purposes of enforcing our legal rights and / or obtaining professional or legal advice;

(r) Internal records management;

(s) Conducting internal activities such as evaluating the effectiveness of marketing, market surveys/research, trend analysis, statistic compilation, reporting, audit, compliance, risk management, and data analytics to improve our services;

(t) Complying with any legal or regulatory requirements such as audit and/or requests from regulatory bodies;

(u) Instituting debt recovery proceedings against defaulters

(Collectively, the “Purposes”).

Source of Personal Data

Your Personal Data is being or is to be collected:

(i) directly from you when you or your representative fill in the registration forms at our facilities, or contact us via emails, online enquiry forms, social media chat, mobile app chat platform, letters or telephone calls, or when taking part in customer surveys and promotions and during marketing activities,

(ii) From any third parties connected with you such as your friend / family / employer / potential employer, agents, insurance companies, other facilities/providers you authorised.

(iii) From such other sources to whom you have given your consent to disclose information relating to you,

(iv) From events,

(v) From CCTV recordings,

(vi) From audio/video recordings,

(vii) From doctors’ letters,

(viii) From medical reports/records,

(ix) From all other personal data we again collect from you on any subsequent occasion, and

(x) From all other information that you may provide us from time to time.

Access to, correction of and limiting the processing of Personal Data

You have the right to request access to and to request correction of your personal data and to contact us with any inquiries or complaints in respect of your personal data (including the possible choices and means for limiting the processing of your personal data or, to cease or not begin processing your Personal Data for purposes of direct marketing) through our website enquiry forms.

  1. Subject to applicable legal restrictions, contractual conditions and reasonable time period given to us, you may withdraw or amend, in full or in part, your consent given previously for use of your Personal Data.

  2. Depending on your request, there may be circumstances where we refuse to comply with a data access request or a data correction request and shall, by notice in writing, inform you of our refusal and the reasons of our refusal.

  3. We may also require the requestor of Personal Data (where the requestor is not the owner of Personal Data) to provide consent form of the owner of Personal Data authorizing and indemnifying us to release or correct the Personal Data.

Compulsory Personal Data

It is obligatory that you supply us the details in our registration form. If you fail to supply us the Compulsory Personal Data, this can result in us being unable to provide you with the services requested and/or unable to perform the contract entered into.

Consequences of Refusal / Failure to Provide Personal Data

The refusal or failure to provide Personal Data may result in the following for which we shall not be held liable for any of the consequences arising from:

  1. the inability of parties to formalize any contract and/or agreement, to facilitate provision of our services or to hire human resources;

  2. the inability for us to provide you with services and/or products requested;

  3. the inability for us to update you on our latest services and/or products and/or appointment dates;

  4. the inability to complete transactions in relation to our products and/or services; and

  5. the inability to comply with any applicable law, regulation, direction, court order, guidelines and/or codes applicable to us.

Disclosure of Personal Data

We disclose or may disclose your Personal Data to the following

  1. other entities within the JRX and our related corporations,

  2. our medical specialists, including medical specialists and experts from our related corporations;

  3. insurance companies,

  4. banks, financial institutions, credit card or debit card issuers for processing of payment,

  5. credit check companies,

  6. debt collection agencies to recover outstanding debt owing to us,

  7. your employer or your organisation of work,

  8. your next of kin and your authorised second contact,

  9. research organizations,

  10. social welfare organization,

  11. medical and healthcare professionals,

  12. external counterparts for situation deemed emergency or necessary,

  13. parents or guardians of minors,

  14. agents, contractors and vendors who process data for us,

  15. laboratories and diagnostic service providers

  16. data centers which host data for the company

  17. external lawyers;

  18. external auditors and accountants

  19. governmental bodies, their agencies and other related organisations such as Ministry of Health, Ministry of Human Resources, Ministry of Home Affairs, Malaysian Anti-Corruption Commission, Inland Revenue Department, Malaysian Department of Insolvency, Royal Malaysian Police, Malaysian Medical Council, Malaysian Dental Council and Malaysian Medical Association,

  20. regulatory and/or statutory bodies,

  21. accreditation bodies and

  22. any such third party requested or authorized by you for any of the Purposes.

Third parties are required to process your Personal Data in line with principles specified by us and/or the applicable law. They are also held responsible for securing your Personal Data at an appropriate level of security in relation to applicable data protection laws and accepted industry standards.

Protection of Personal Data

Your Personal Data will be kept and processed in a secured manner. We are committed to take appropriate administrative and security safeguards and procedures to prevent unlawful processing of, and the accidental loss, destruction or damage to your Personal Data. Access to your Personal Data is limited to and provided only to relevant users for the purpose of performing their duties.

Third party personal data

We may require your assistance if the personal data relating to other persons (for example, your next of kin or appointed secondary contact) is required to process your Personal Data for the Purposes and you hereby agree to use your best endeavors to assist us when required. In the event that personal data of any third party is supplied by you to us, you shall ensure that such third party has read this Policy and consented to us collecting his/her personal data for any of the Purposes prior to the supply of his/her personal data to us.

Transfer of Personal Data to places outside Malaysia

To the extent where this is permitted under law, we may transfer your Personal Data to a place outside Malaysia and you hereby give your consent to the transfer. JRX is the contracted distributor of Revotera Medikal Teknolojiler A.Ş., a global company affiliates with partners in different countries. JRX has an international presence and for contractual or assessment purposes must also share your data with so-called third countries within the JR’s partner, in particular also to CTech Labs Edwar Technology Company based in Indonesia and Argea Teknoloji A.S based in Turkey. By providing your personal data, there is a separate request of your consent to this transfer, storage or processing. For example, if you are a Malaysia citizen and you provide your information for health assessment purposes, your personal information will be sent to the Indonesia and Turkey. We take all reasonable steps to process your personal data securely and in accordance with this Privacy Policy.

Accuracy of your Personal Data

You are responsible for ensuring that the information you provide us is accurate, complete, not misleading and kept up to date.

Conflict

In the event of any inconsistency between the English version and other languages translated version of this Policy, the English version shall prevail.

Security

The safety of your personal data is an important concern for us. We take appropriate steps, including technical, administrative, and physical security measures to protect the personal data provided to us against loss, misuse, and unauthorized access, disclosure, amendment, and deletion. However, no Internet security or physical transmission processes is deemed to be 100% safe. Although we will do our level best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Always exercise caution when transmitting personal data via the Internet.

Changes to this Policy

We Review Our Policy from time to time in order to ensure compliance with applicable law, and to optimize and further develop them, since the protection of your personal data is an important concern for us. We may change this Policy by updating this page as and when needed without notification in order to comply with the changes in business operations or laws or regulations. Please check here periodically for all updates and changes to our privacy policy.

 

Updated date: 16 January 2022

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