- The processing of all such personal data is also Subject to certain applicable laws namely the Personal Data Protection Act 2010 and all relevant by-laws, rules and regulations made thereunder.
- Personal Data
- BACG may collect Personal Data from Subjects in a variety of ways, including, but not limited for affiliates, members of the public and visitors / students to the BACG websites (“hereinafter referred to as Subjects”). In this context, the use of the term “Subject” refers to any individual whose personal data is collected, processed, stored and used by BACG and its affiliates.
- Subjects are encouraged to check the BACG websites for any future changes in BACG’s list of partners and affiliates.
- Personal Data is also collected when Subjects register with BACG for any of the courses offered, enrol for courses and classes, meetings, events, conferences, previews, accommodation, field trips or any such functions organized by BACG; whether it is online registration via any BACG’s websites or registration via BACG’s designated event organizers or promoters or affiliates; or by manual registration at BACG’s main office or at any other branch office in Malaysia or elsewhere in the world.
- BACG shall be at liberty to collect, Subject to obtaining consent from the data Subject the following information:-
a. Personal details such as name (if minors for theirs parents or guardians identification), identity card / passport/ social security number / Employees Provident Fund (EPF) No., age, gender, ethnic background, nationality, birthdates, residential and business addresses, social media website addresses, contact numbers, email address and such other relevant information that identifies the respective student/Subject, member or participant;
b. Information in connection with businesses and/or trade and /or services that the Subjects are engaged in;
c. All payment transactions- either via cheque, credit card, debit card or via PayPal or online transfers from respective bank accounts;
d. All billing records for services, inclusive any cancellations that have been made;
e. Any such other information that are, have been or will be collected by us in future, or such information which members provide to BACG or its affiliates in connection to any course, event, function, accommodation or service. This also includes such data that is collected from any surveys, questionnaires, transactions or any correspondence with the BACG including but not limited to marketing surveys, tele-marketing, short message service (sms) blasting, WhatsApp, Telegram, WeChat, Line, Snapchats, Yellow Messenger and online queries for accommodation, courses or events organised by the BACG and its partners, associates and affiliates;
f. Individual personal preferences of Subjects such as to the language, product or content interest as well as and communication preferences;
g. The Subjects choice in regards to receiving future communication in regards to future meetings, events, conferences or seminars organized by the BACG and its partners, associates and affiliates;
h. Any enquiries, comments or messages sent to the BACG website or any other social media platforms or any query or correspondence sent via email to the BACG or its partners, associates and affiliates;
i. The IP address of such Subjects who visit the BACG website, who apply and register for its courses, send queries or upload posts or comments in any blog posting, picture, post , article and/or tweet hosted by BACG or its affiliates anywhere in the worldwide web or in any social media website.
j. The IP address who visit the BACG website and who apply and register for accommodation with BACG.
- Kindly take note that certain information is deemed mandatory and Subjects shall provide their consent and agree to the processing of such mandatory information to BACG and its partners, associates and affiliates.
- How Personal Data is collected:-
- when Subjects enrol for courses organized by BACG and/or its partners, associates and affiliates;
- when Subjects who are current or alumni students send updates with regards to their personal details or change of address or any other details;
- when Subjects who are students or participants or potential participants of events enquire about any courses, events, seminar or forums organized by BACG or its partners, associates and affiliates;
- when Subjects or anyone at large visits the BACG website and/or any of BACG’s social media webpages;
- when Subjects or participants register with BACG and/or its affiliates and/or its event organizers for courses, seminars, accommodation, talks and / or events whether online or manually;
- any transaction or inquiry or communication made with the BACG and/or its affiliates be it by sms, letter, Telegram, WhatsApp, facsimile or email;
- when such personal data is collected by staff and faculty members, promoters, event managers, event organizers or any marketers of BACG or its partners, associates and affiliates in the course of any event, function, meeting or any marketing, expansion and promotional activities conducted by or on behalf of BACG .
- Purpose of collecting Personal Data:-
- to communicate with Subjects about their academic matters, fees, inquiries on courses, accommodation inquiries and events or any other related or non-related requests;
- to facilitate the availability of BACG Events and/or future events or promotional events to its students, alumni and to the world at large;
- to respond to queries from Subjects who are students, potential students and members of the public;
- for administrative purposes, including but not limited to billing, payment, accommodation, registration of Subjects who are new students and renewal for current students;
- to monitor and upgrade BACG’s services and for its current and future marketing strategy, promotional activities and policies ;
- for direct and indirect marketing and advertising services; to provide student updates, information and promotions on upcoming events to the BACG’s event organizers;
- to conduct direct or indirect marketing, research, surveys and statistical analysis for any reports, meetings, courses or conferences. BACG has the sole prerogative to determine, disseminate and control the amount of information to be used in its reports.
- To send emails on updates or any courses, talks, training, meetings, seminars or events that would be of interest to each respective student or to the public at large.
- Kindly also note that BACG uses information that is collected to operate, maintain and provide the features and functionality of the website, to analyse how the website is used, diagnose website or technical problems, maintain security, personalize content, remember information to help users efficiently access account, monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns, and track content and users as necessary to comply with applicable laws.
- If at any time, the Subject does not want to receive any emails from the BACG and its affiliates pertaining promotions, surveys, advertisements, marketing projects, statistical analysis or other related marketing material, then they may choose the option to unsubscribe from BACG’s mailing list. BACG still retains the right to store and keep such personal data of the Subject in its database for purposes of record only; unless informed specifically by the Subject to remove or delete the said personal data.
- In regards to para 14 above, such notice from the Subject to BACG shall be in writing and shall be sent by email to firstname.lastname@example.org or by post or hand to the address Ground Floor, Block B, VSQ @ PJ City Centre, Jalan Utara, Section 14, 46200, Petaling Jaya, Selangor. If sent by post, such service shall only be deemed effective if received and acknowledged by BACG.
- It shall be the responsibility of each respective Subject to inform BACG of their decision not to receive any future communication from BACG and its affiliates in regards to future courses, events, promotions, surveys, advertisements, statistical analysis or such other marketing related material from the partners, affiliates and associates of BACG and/or event organizers appointed by BACG, in Malaysia or overseas.
- In the event BACG does not receive any such notice from the respective Subject then it shall be deemed that the respective Subject acknowledges and agrees to be included on the correspondence list; and further agrees to receive such information from BACG and its partners, affiliates, associates or any event organizer or marketer appointed by BACG and its partners, associates and affiliates.
- A cookie, also known as an HTTP cookie, web cookie, or browser cookie, is a small piece of data sent from the BACG website and stored in a visitor’s web browser while the Subject browses the website. Every time Subjects or visitors upload the BACG website on their personal computers, laptops, mobile devices, note pads etc., the browser sends the cookie back to the server to notify the website of the visitor’s previous activity. Cookies are designed to be a mechanism for the website to remember information or to record the Subject’s browsing activity. Cookies do not collect personal data or any such information that is related to or deemed as personal identification information.
- If Subjects or Visitors do not wish to have their information stored, then they are advised to remove cookies from their hard drives after each browsing session. It shall be the responsibility for each respective Subject or visitor to BACG’s website to remove cookies and BACG shall not be held liable.
- Log Files
When the website is accessed, BACG servers automatically record certain information sent by user’s web browser. These server logs may include information such as web requests, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how users interact with links on the website, domain names, landing pages, pages viewed, mobile carrier, and other such information.
- Third Party Tools
- Links / Related websites
- Sensitive Personal Data
- It is an express Policy of BACG not to collect Sensitive Personal Data unless required by any applicable or relevant laws. Members are advised NOT to submit any sort of sensitive personal data if they do not want BACG to collect, disseminate or to process it.
- Sensitive Personal Data means any personal data consisting of the physical or mental health or condition, political opinions, religious or spiritual beliefs or other beliefs of a similar nature, the commission or alleged commission of an offence or any such other Personal Data described under the law as sensitive personal data.
- BACG As such by the act of submitting such sensitive personal data, Subjects are deemed to have consented, acknowledged and agreed to allow such sensitive personal data to be processed by and also to be shared with its partners, associates and affiliates.
- BACG shall not be held liable or responsible for any dissemination or if in the event such sensitive personal data is distributed to its partners, affiliates and associates.
- How BACG protects Personal Data
- BACG adopts appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Personal Data. As a responsible organization, the welfare of its Subjects is paramount and continuously conducts in house training for all its staff, consultants and members of its faculty.
- In the event Personal Data is no longer required to be used by BACG or its partners, affiliates or associates, BACG may delete and destroy such Personal Data from its records. Likewise BACG may choose to keep such personal data in its database as part of its records.
- In such case in the event of cessation of the relevant course, termination, expulsion and/or graduation of any Subject, and in the case of Subjects who are employees or faculty staff; upon their retirement, resignation or termination of employment or service; then such personal data of the respective Subject shall be stored in BACG’s database; unless the Subject in question serves a written notice with clear instructions to BACG requesting for such personal data to be destroyed and deleted from the its data base. BACG shall at all time take reasonable measures to ensure sufficient security measures are taken to protect the personal data in its database.
- In the case of Subjects who are current students or alumni members; should the individual Subject wish to enrol for further courses organised by BACG or its partners, associates and affiliates, then it shall be the responsibility of the said Subject to confirm the details of its personal data to be processed by respective entity of BACG. Subjects shall be responsible for any changes or updates to their personal data and shall be responsible to inform the BACG accordingly. BACG shall not be liable for any act or omission of the respective Subject in failing to give them full and complete personal data or to update them of any changes made.
- If the Subject has agreed and consented to receive such promotional or future marketing information from BACG and its partners, associates and affiliates, then BACG shall store such Personal Data in accordance to the terms of this Privacy Notice and the Subject shall be bound accordingly to the terms and conditions herein.
- BACG In the case of Subjects who are students; upon completion of the enrolled course or graduation or expulsion, the respective Subject has the choice as to whether they wish to receive any future correspondence from BACG and its partners, associates and affiliates in regards to future marketing information and material.
- It shall be the responsibility of each individual Subject to inform BACG as to whether they wish to remain on BACG’s mailing list. Failure on the part of Subjects to give such notice to BACG shall be deemed as consent to receiving future emails, correspondences and such marketing material from BACG as well as its partners and associates.
- At all material times, BACG shall take all reasonable and necessary measures to ensure that all Personal Data stored in its records is secure and protected. By enrolling for courses, events, seminars and functions organized by BACG and its partners, associates and affiliates; Subjects hereby agree and consent to giving BACG the sole unfettered prerogative in determining the manner in which their personal data is to be stored.
- BACG websites are encrypted to ensure that the information collected therein is secure. All reasonable measures are taken to ensure such information is secure and to prevent any loss, alteration, theft or third party interference.
- BACG has used its best endeavours to provide the best method of protection for Personal Data in its database. However sometimes unforeseen or unpredictable acts by third parties; to which BACG and its affiliates has no control; may result in unauthorized leakage, dissemination, theft or publication of Personal Data. Despite all reasonable measures taken by BACG calamitous events such as fire, burglary, break-in, hacking, strike, riot, calamity or any natural disaster or Act of God are beyond BACG’s control and are unforeseeable.
- BACG will not be able to foresee nor control or prevent such acts of information theft or corporate espionage, fraud, forgery and malfeasance; that are unknown to the BACG at the time of commission; which may occur resulting in the theft of personal data from its database and subsequent sale, trade and/or misuse of such personal data.
- In the event of any of the events as stated in paragraph X and XI of section 23 above, then BACG shall not be liable if in the event of any unforeseen acts such as information theft of its data base and records or hardware or of any burglary/break in BACG’s offices; and/or if in the event of BACG’s computers, server and/or websites are hacked, resulting in the displacement, dissemination, publication or unauthorized leakage of such Personal Data or if by reason of any strike, riot or such calamity of nature such as an earthquake, flood or tempest whereby manual records and database of the BACG’s Subjects are lost, stolen, appropriated, leaked or made available to unauthorized Third Parties.
- In the event of graduation, termination or expulsion (for Subjects who are students) or in the event of retirement, resignation or termination from employment or the completion of their projects with BACG (for Subjects who are staff and members of the faculty), then the Subject in question has deemed to have consented to allow their personal data to be stored in BACG’s database and shall be duly bound by this Privacy Notice so long as their data is kept by BACG.
- Subjects have the right and prerogative to inform BACG to remove their personal data from BACG’s database. It shall be the responsibility and duty of the individual Subject in question to inform BACG in writing of their request for their personal data to be removed. The Subject shall not have the option to have their data in the form of enrolment forms and certificates to be returned to them. In the event such documents are stored, Subjects may also request that BACG deletes and destroys all their personal data from its records and database.
- In the event BACG does not receive any such written notice from the individual Subject, then it shall be deemed that the Subject has agreed and consented to have their personal data stored by BACG; and further, that BACG shall be allowed to use such data for its marketing purposes, to conduct surveys, for statistical analysis and for purposes of preparing reports. BACG shall also be allowed to share such personal data with its partners, associates and affiliates for the purposes mentioned above.
- In regards to paragraph XVI of section 23 above, such notice from the Subject shall be in writing. Subjects will be able to make a request at the BACG offices, whereby a form will be made available to them for processing their request. Such personal data shall be made available to them within twenty one (21) working days from the date of submission of the form. In the event the individual Subject requests for their data to be deleted and destroyed, the Subject shall receive an Acknowledgement Letter from BACG in regards to their request. BACG has the prerogative whether to issue the Acknowledgement Letter and may refuse to issue such letter if the Subject has not adhered to the necessary procedures.
- Upon the completion of the form and return of such personal data; BACG shall cease to keep any future records of the Subject and it shall be the sole duty and responsibility of the individual Subject to provide BACG with their personal data in the event they wish to be part of the BACG’s alumni or enrol for future courses or receive future marketing material from BACG.
- Sharing of Personal Data
- BACG will not sell, trade or rent out its Subjects Personal Data to any unauthorized third parties. It shall be the express policy of BACG to take stern disciplinary action on any of its staff or faculty members who are involved or who cause or allow such personal data to be sold, traded or rented to such unauthorized third parties. If any staff or faculty member is caught committing such an act, then BACG shall immediately conduct a domestic Inquiry; whereby if found at fault; the staff or faculty member in question shall be terminated with immediate effect and also be liable to reimburse BACG for any fine, penalty or damages imposed by the Commissioner of the Jabatan Data Peribadi.
- BACG has the sole prerogative and discretion as to whether it may share such Personal Data with its partners, associates and affiliates, accommodation providers, including other Universities or Institutions of Higher Education; whether in Malaysia or abroad, promoters, event organizers, researches, marketers and advertisers to conduct statistical analysis of current or future trends as well for marketing, advertising and promotional purposes of future courses, previews or events.
- BACG may use third party service providers to help operate its organization and its website; as well as all other social media websites and/or administer activities on BACG’s behalf, such as to send out newsletters and/or emails, to conduct text messaging blasting and/or surveys.
- BACG may share such personal data with its lawyers, legal counsel, accountants, actuarists, auditors, consultants, promoters, marketers, telemarketers, event organizers, real estate agents and such other service providers in the conduct and administration of its affairs. BACG shall share such information with these third parties for those limited purposes.
- Subjects are also given the option to opt out or to cease from receiving such emails, surveys and any other information by informing BACG. Subjects shall be responsible to inform BACG in writing that they do not wish to have their personal data shared with such third parties for the purposes as stated above.
- Such Notice to be excluded shall be given in writing and be sent either by email to email@example.com or by post or hand to BACG whose address is at Ground Floor, Block B, VSQ @ PJ City Centre, Jalan Utara, Section 14, 46200, Petaling Jaya, Selangor, Malaysia. Such notice shall only be deemed received by BACG if it has been duly received and acknowledged by BACG.
- In the event such notice is sent by post, then it is deemed to be delivered effectively only if received by BACG. If in the event the Subject does not send such notice to BACG then the Subject shall be deemed to have given their consent to BACG to share their personal data with the third parties for the reasons and purposes stated above.
- BACG encourages Subjects to frequently check its website for any changes to also stay updated and informed about how it is helping to protect Personal Data that is collected from Subjects.
- By virtue of their enrolment with BACG or continued membership in the Alumni, and in the case of staff and faculty members; by virtue of their continued employment, Subjects are deemed to have accepted the Privacy Notice and any future changes made thereafter.
- In accordance with paragraph 2 (of this section 26), BACG has the sole arbitrary discretion to transfer each individual Subjects Personal Data to another country outside Malaysia.
- Each Subject is deemed to have given their consent to the BACG to transfer their Personal Data outside Malaysia and to any country or jurisdiction, even if such country does not have equal or adequate levels of personal data protection. The Subject is fully aware of such risks and BACG shall not be liable for any breach of any of the personal data principles in the recipient country which receives the personal data.
- Likewise, each Subject is deemed aware that the Government of Malaysia (“the Government”) is not bound by the provisions of the Personal Data Protection Act 2010 and any regulations made thereunder. The Subject hereby gives such acquiescence to BACG to share such personal data with The Government (if required); in the event BACG deals with any government agency or government ministry. Thus BACG shall not be liable for any leakage, information theft or if such personal data is compromised when it is shared with The Government.
- Unless written notice to the contrary is given by the members to BACG, each respective member is deemed to have consented and agreed to allow BACG to transfer their Personal Data outside Malaysia and to any such jurisdiction or country by BACG as required.
- Such written notice can be sent by email to firstname.lastname@example.org or by post to or by post or hand to the BACG office; whose address is at Ground Floor, Block B, VSQ @ PJ City Centre, Jalan Utara, Section 14, 46200, Petaling Jaya, Selangor, Malaysia. If delivered by hand, such notice shall only be deemed received by BACG if it is duly acknowledged.
- In the event such notice is sent by post, then it is deemed to be delivered effectively only if received and acknowledged by BACG.
- Access or updates on Personal Data
- Subjects are personally responsible for providing BACG with accurate and updated information about themselves as well as any other Personal Data pertaining to third parties (for example: the personal information of their parents, guardians, children, next of kin or spouses) that they may submit to BACG or its staff or faculty members.
- As such in the event such information and Personal Data submitted is incorrect or becomes out dated, then each respective Subject is duly responsible to make such corrections or to update such information by contacting the BACG within a reasonable time frame. In such case a reasonable time frame would be such period of time that does not exceed one (1) calendar month. BACG shall not be responsible for any delays in updating its records where the Subject caused such delay and/or in circumstances whereby such information is provided after one (1) calendar month.
- BACG shall not be responsible for any omission or delay or negligence on the Subject’s part in failing to update their Personal Data or to submit their request for rectification.
- The Subject member, may choose to inform BACG and:-
- Request for a copy of the Personal Data kept by BACG;
- Request to update their respective Personal Data;
- Request to rectify their respective Personal Data
- Upon receiving the member’s request, BACG may comply or refuse to such request to access or rectify such information. If in the event there is a refusal, no reason for such refusal shall be notified to the Subject.
- The Subject is required to provide a full set of credentials and corresponding verification identification to confirm their identity before any such request can be entertained.
- If, In the event the member in question is unable to prove, confirm and verify their identity then BACG shall deny such access or request for rectification, in order to safeguard the Personal Data of the Subject in its records.
- BACG shall have the sole prerogative as to whether to allow any rectification or updates to its data base in order to protect any false or fraudulent changes or incorrect variations and further to prevent any misuse, identity theft, corporate espionage or any illegal act.
- Affiliates of BACG such as event organizers, event managers, Marketers, Tele-marketers, Promoters and any related of associated body are expected to adhere strictly and comply with the laws in regarding to the collecting and processing of Personal Data namely the Personal Data Protection Act 2010 and any rules and regulations made thereunder.
- Each Subject and affiliate who is bound by this Privacy Police Notice shall give full indemnity to BACG in the event of any non-compliance or breach of the rules, regulations and by laws made hereunder and shall further indemnify BACG in the event of any criminal prosecution, or imposition of any fine or penalty or in the event any complaint is lodged or civil suit is instituted as a result of any breach of the law.