Gamuda Berhad in Malaysia, a leading Malaysian construction, infrastructure and real estate company, respects the privacy of individuals with regard to personal data. This Privacy Notice is formulated in accordance with the applicable laws and Vietnamese regulations on personal data protection, including but not limited to Decree No. 13/2023/ND-CP on Personal Data Protection (the “Decree”) and applies to:

1. Gamuda Land Vietnam LLC;
2. Gamuda Land Vietnam JSC (HCMC); and
3. The subsidiaries, associates, jointly controlled entities and affiliates in Vietnam (including but not limited to entities with capital and/or management of Gamuda Berhad such as Gamuda Group of Companies and their associates, jointly controlled entities, affiliates mentioned here which are collectively referred to as “Group”).

For the purpose of this Privacy Notice, “Personal Data” shall have the meaning as ascribed to it in the Decree; and “we” and “us” shall refer to any of the companies within the Group and “you” shall refer to yourself and/or such other persons or companies represented by you of which you are providing Personal Data; and “process”, “processed” or “processing” shall refer to the act of collection, analysis, storage, modification, evaluation, processing, usage, encoding, decryption, copying, transmission, provision, sharing, transfer, deletion, destruction, and other related actions.

A.  INFORMATION PROCESSED

The Personal Data about you which we or the Group may collect via print and digital platforms (including but not limited website, social media and mobile apps)
 

1. Information collected when you register or update an online profile or when you fill in or update your information with us, which may include personal data such as your photograph, name and contact details;
2. The contents of all printed and electronic forms or documents submitted to us via printed collateral or forms, our website and any digital and mobile platforms (eg. Email, Facebook, X, Instagram, WhatsApp, Viber and any social media and apps), including identity documents and proof of address;
3. Information input or submitted to online facilities such as search tools and calculators;
4. Personalization preferences you select as you use our website, digital and mobile platforms;
5. Information submitted if you participate in survey or competition whether via online or otherwise; any messages or comments you submit to us via our website or in whatever manner, which may include personal data such as name, email address and telephone number; information obtained independently by us or the Group from other lawful sources; and
6. The contents of all forms and/or documents submitted and/or collected by us.

B.  PURPOSE OF PROCESSING OF PERSONAL DATA

1. By providing any of your Personal Data to us whether via online or otherwise, you hereby agree that we shall process the Personal Data for the following purposes:
   1. Providing you with services or benefits under any of our businesses or policies; and/or
   2. Processing your application under any of our programs;
   3. Where relevant, marketing of goods and services and sending any updates, new products, special offers, advertising, promotional material and/or commercial material to you (including emails, short message services or other means) and/or to be used in, to provide and/or improve our services, processing invoices and payments (including card payments) and providing other services to enhance and support the relationship of us and you and/or such other persons or companies represented by you;
   4. Conducting research on planning, products, goods, services, security and testing;
   5. Carrying out matching procedure in accordance with the law;
   6. Performing statistical analysis and info for various objectives in Gamuda, Group and providing this information within the Group;
   7. Purposes connected with the operation, administration, development, record- keeping or enhancement of our businesses including for the purpose of which is relevant to support and/or assist in any of our businesses or our website;
   8. Purposes connected with the administration, management and/or enforcement of the commercial transaction and for contact and communication with you;
   9. where required by law, where we consider that such use or disclosure is necessary to respond to any claims or legal process, or where we suspect that fraud or unlawful activity has been, is being or may be engaged in;
   10. Where a third party acquires or wishes to acquire, or makes inquiries in relation to acquiring, an interest in Gamuda;
   11. Where a third party requires in order for such third party to perform functions or services as required by us or the Group;
   12. Enabling us or where a third party requires in order for such third party to perform functions or obligations as required under the laws, rules, regulations, by laws and/or guidelines (whether or not having the force of law) or as required by any governmental and/or non-governmental authorities, agencies or departments or a third party requires in order to ensure compliance with agreement(s) or document(s);
   13. Where a third party requires for purposes of preparation and submission of any claims or payments to any party or for any audit/checks by any party for whatever purpose related to our businesses;
   14. Purposes connected with the enforcement of our rights pursuant to any letters, agreements and/or documents including seeking legal and financial advice, taking any preliminary steps or commencing any legal actions;
   15. Making such disclosures as may be required for any of the above purposes or by law;
   16. Customer loyalty programs;
   17. Performance of rights and obligations under contracts signed with you, and/or obligations under our commitments;
   18. For any other purposes that is incidental or ancillary or in furtherance to our purposes;
   19. Establishing, performing and protecting our legal rights and obligations;
   20. Compliance with applicable provisions of law from time to time; and/or
   21. Other lawful purposes in accordance with the laws.
2.  We may contact you for the purpose as set out in (B.) above either via telephone calls, emails, short message services, social media, post, facsimile or by whatsoever form of available communication as permitted under Vietnamese laws.

C.  USE AND DISCLOSURE

1. You further agree that we may disclose and transfer (whether in Vietnam or abroad) amongst any company within the Group and/or to third parties including but not limited to our and the Group’s agents, consultants, solicitors, auditors, employers, contractors, suppliers, partners, joint venture partners, advertisers, purchasers, network operators, service providers, associated companies, any relevant authorities (governmental and/or non-governmental), embassies, statutory bodies, regulatory bodies, organizations and/or any relevant financial institutions, any other persons under a duty of confidentiality to us or any companies within the Group (including those established or incorporated from time to time), actual or proposed assignees or transferees or buyers of any of rights/businesses/assets of the companies within the Group, service providers (including those who assist us in providing/developing/maintaining our website and digital platforms) for the our operational, administration and development requirements and to organizations who provide archival, auditing, professional advisory, debt collection, insurance, banking, marketing, advertising, mail house, delivery, recruitment, call center, technology, research, utility, loyalty programs and security services to use, disclose, hold, process, retain or transfer such Personal Data for the purposes of (B.) above for and on behalf of the Group.
2. The Group uses and discloses aggregated non-personally identifying information collected by us as part of our process of constantly improving our website and/or our businesses.

D.    IMPACT OF NON PROVISION OF PERSONAL DATA

1. Please note that in the event that sufficient Personal Data is not supplied or is not satisfactory to us, then your application or request to us for any of the purposes as set out in (B.) above may not be accepted or acted upon or your request to browse some information on our website may be denied or we will not be able to provide the full range of benefits and/or services and/or perform its obligations under any potential or existing contract with you.
    

E.   STORAGE AND RETENTION OF THE PERSONAL DATA

1. Your Personal Data shall be stored either in hard copies in our offices or stored in servers located in or outside Vietnam and operated by us, the Group or its service providers in or outside Vietnam.
2.  Any Personal Data supplied by you will be retained by us after your consent is obtained for as long as necessary for the fulfillment of the purposes stated in (B.) above or as required by any legal, regulatory and/or accounting requirements or to protect our interests.
3. The Group do not offer any online facilities for you to delete your Personal Data held by us and/or the Group.

F.  HOW WE HANDLE EMAIL AND "CONTACT US" MESSAGES

1. We may preserve the content of any emails or “Contact us” or other electronic messages that we receive.
2. Any personal data contained in those messages will only be used or disclosed in ways set out in this Privacy Notice.
3. The message content may be monitored by our service providers or employees for purposes including compliance, auditing and maintenance or where email abuse is suspected.

G.  COMMUNICATION OR UTILIZATION DATA

1. Through your use of telecommunications services to access the Group’s Website, your communications data (e.g. Internet Protocol address) or utilization data (e.g. information on the beginning, end and extent of each access and information on the telecommunications services you accessed) are technically generated and could conceivably relate to Personal Data.
2. To the extent that there is a compelling necessity, the collection, processing and use of your communications or utilization data will occur and will be performed in accordance with applicable laws and the Decree.

H.    NON-PERSONAL DATA COLLECTED AUTOMATICALLY

1. When you access our website, we may automatically collect non-personal data.
2. We may use this data and share it with the rest of the Group to monitor the attractiveness of our website and to improve their performance or content.

I. COOKIES
 

1. When you view our website, we may store some data on your computer in the form of a “cookie” to automatically recognize your personal computer the next time you visit.
2. Cookies can help us in many ways, for example, by allowing us to tailor a website to better match your interests or to store your password to save you from having to re-enter it each time.
3. If you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer’s hard drive, block all cookies or to receive a warning before a cookie is stored.
    

J.  CONFIDENTIALITY

1. Personal Data held by us will be kept confidential in accordance with this Privacy Notice pursuant to any applicable laws that may from time to time be in force.
2. Any questions, comments, suggestions or information other than Personal Data submitted to us in whatever manner (including those sent or posted on our website) will be deemed voluntarily provided to us on a non-confidential and non- proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely as set out in (C.) above.

K.  SAFETY OF PERSONAL DATA

1. We use a number of appropriate and necessary organizational, technical and administrative mechanisms to protect the security and integrity of your Personal Data.
2. For the Internet, unfortunately, no data transmission over the Internet can be guaranteed as completely secure against cyber incidents. So while we strive to protect such Personal Data, we cannot ensure or warrant the security of any Personal Data transmitted to us and you do so at your own risk. Once any Personal Data comes into our possession, we will take reasonable steps to protect that information from misuse and loss and from unauthorized access, modification or disclosure.
3. A username and password may be essential for you to use some sections of our website. For your own protection, you are advised to keep these confidential and to change your password regularly (if required).

L.  TRANSFER OF PERSONAL DATA

1. Due to the global nature of our and the Group’s businesses, we may transfer your Personal Data to the other members of the Group (which may be located in other countries) or to any parties located in other countries (including countries that have a different data protection regime than is found in the country where you are based). Any Personal Data transferred shall be used for the purposes as set out in (B.) above and disclosed to parties stated in (C.) above.
2. If transferring Personal Data abroad, we will comply with compulsory procedures and requirements in accordance with applicable laws from time to time.

M.  PROCESSING PERSONAL DATA OF CHILDREN

We and the Group do not actively process Personal Data of children unless required to fulfill our obligations. If you provide us with Personal Data of children, you are responsible for ensuring that the rights of children are fully respected in accordance with the applicable laws prior to providing us with Personal Data of children, for example, the consent of children and their parents or guardian is required in the case of processing children’s Personal Data who is older than 7 years old, unless otherwise provided by laws. If you have reason to believe that a child has provided us with Personal Data or that Personal Data of a child has been provided to us without being permitted by applicable laws, please contact us using the information provided in (R.).
 

N.  THIRD-PARTY SITES

1. Our website may contain links to other sites and pages. By activating a link, for example by clicking on the banner of an advertiser, you leave our website, we no longer exercise control over any Personal Data or any other information you give to any other entity after you have left our website.
2. Please note that collection of your Personal Data by third parties may not have the same level of protection as those collected by us, and we cannot guarantee the confidentiality of such data.

O.  YOUR RIGHTS AND OBLIGATIONS

1. Depending on applicable laws from time to time, you own rights relating to your Personal Data processing, including but not limited to:
   
   1. Right to be informed: You have the right to be informed your Personal Data processing, unless otherwise provided by laws;
   2. Right to consent: You have the right to consent or decline our processing of your Personal Data, unless otherwise provided by laws;
   3. Right to access: You have the right to access, view, modify, or request correction of your Personal Data, unless otherwise provided by laws
   4. Right to request re-examination, correction, update and modification: You have the right to request us to re-examine, correct, update, modify your Personal Data under our control or processing;
   5. Right to revoke consent: You have the right to revoke your consent, unless otherwise provided by laws;
   6. Right to deletion of Personal Data: You have the right to request us to delete your Personal Data that we are controlling or processing, unless otherwise provided by laws;
   7. Right to restriction: You have the right to obtain restriction on the processing of your Personal Data, unless otherwise provided by laws;
   8. Right to obtain Personal Data: You have the right to request us to provide You with your Personal Data that we are controlling or processing, unless otherwise provided by applicable laws;
   9. Right to objection: You have the right to object to your Personal Data processing to prevent or limit the disclosure of Personal Data or using it for promotion purpose, unless otherwise provided by applicable laws;
   10. Right to self-protection, filing complaint, denunciations and lawsuits: You have the right to self-protection, filing complaint, denunciations, lawsuit according to the law; and
   11. Other rights according to applicable laws from time to time. If you wish to exercise any of these rights, or if you have any inquiries regarding these rights or any section of this notice, or your Personal Data processing, please reach out to us using the contact details provided in (R.)
2. Depending on applicable laws from time to time, you shall have the following obligations relating to your Personal Data processing, including but not limited to:
   1. Self-protection of your Personal Data, request other relevant organizations, individuals to protect your Personal Data;\
   2. Respect and protect Personal Data of others;
   3. Fully and accurately provide Personal Data upon consent to processing of Personal Data, ensure the accuracy of the provided Personal Data and promptly notify us about any changes to your provided Personal Data;
   4. Comply with all requirement applied to your provision of Personal Data in accordance with the laws; and
   5. Comply with regulations on Personal Data protection and participate in prevention against violations of regulations on Personal Data protection.
3. When you provide Personal Data of another individual (including that of your children, relatives) for our processing under this notice, you possess, among other things, the following rights and obligations:
   1. Be informed that we handle Personal Data in accordance with the law, regulations and statements outlined herein;
   2. Respect and protect the personal data of others; ensure that the consent of the data subject is obtained, and/or the provision of Personal Data to us is lawful;
   3. Fully and accurately provide Personal Data upon consent to processing of Personal Data, ensure the accuracy of the provided Personal Data and promptly notify us about any changes to the provided Personal Data;
   4. Comply with all requirements applicable to your provision of Personal Data under the law;
   5. Ensure that we are free from any hindrance, risks, or legal consequences related to or arising from Personal Data processing activities in accordance with your needs and requests;
   6. In case of any risks or legal consequences, you will take full responsibility and compensate us in accordance with the law. Please note that notwithstanding the withdrawal of your consent, we may still proceed to process your Personal Data in circumstances recognized and permitted by law and as required under the contractual conditions; and
   7. We reserve the right to charge you a reasonable fee for our fulfillment of any data access or data provision request.

P.   VENDORS, SUPPLIERS AND/OR SERVICE PROVIDERS

1. If you are processing Personal Data on behalf of Gamuda as a vendor, supplier and/or service provider, you shall be required to take all necessary steps to ensure that you are in compliance with:the Decree; and/or
   1. any other laws, rules, regulations, by laws and/or guidelines (whether or not having the force of law) or as required by any governmental and/or non-governmental authorities, agencies or departments.
2. In the event you fail to comply with any items stated in (O.) above, you shall indemnify Gamuda against any actions, claims, demands, fines, suits proceedings, prosecution, losses, damages, penalties, costs and expenses (including but not limited to legal costs on solicitor and client basis) howsoever arising which may be brought or made against or incurred by Gamuda.

Q.  CHANGES TO PRIVACY NOTICE

We reserve the right to modify, update and/or amend this Privacy Notice from time to time without prior notice. We advise that you check this Privacy Notice on our website on a regular basis.

If you have any questions regarding this Privacy Notice or if you wish to exercise your rights regarding the processing of your Personal Data for the purposes as set out in (B.) above or for the transfer of your Personal Data to the parties stated in (C.) above, you may send your request in writing to the following companies:
 

Gamuda Land Vietnam LLC
Address: Km 1.5 Phap Van, Yen So Park, Yen So, Hoang Mai District, Ha Noi, Viet Nam

Person in charge 1: Ms. Mai Nam Phuong – Head of Media Department
Email: glvn.info@gamudaland.com.my
Tel No: 024 3 944 5699

Or

Person in charge 2: Mr. Bui Quang Xuan – Head of IT Department (Northern region)
Email: glvn.it@gamudaland.com.my
Tel No: 024 3944 5699

Or

Person in charge 3: Mr. Huynh Tran Hải Đăng – Head of IT Department (Southern region)
Email: glvn.it@gamudaland.com.my
Tel No:028 6252 9999