Collection of Personal Data

2.1. During the course of your dealings with HHQ, you may be requested to provide or has provided us your Personal Data for us to render our legal services or when you apply for a position with us. These are relevant in connection with our business process and execution, services, client relationship, management and business development activities.

2.2. It is obligatory that you supply us with the Personal Data requested by us in order for us to process your request and provide you with our services. If you fail to provide us with the requested Personal Data, we will not be able to process and/or provide you with relevant services you requested for.

2.3. If you provide Personal Data of any third party to us, you represent and warrant that you have obtained the necessary consent, license and/or permissions from that third party to share and transfer his/her Personal Data to us, and for us to collect, store, use, disclose and process that Personal Data in accordance with this Notice.

Purpose of us collecting your Personal Data

3.1. Your Personal Data is collected, stored, used and processed by us for the following purposes:

1. 3.1.1. to implement, perform and complete any transactions or dealings or provide you or any third parties with our legal services and advice;
2. 3.1.2. to correspond with you in the course of business either as a client or as a business contact;
3. 3.1.3. to perform our obligations or to exercise our rights under the law;
4. 3.1.4. to conduct checks or verify your identity;
5. 3.1.5. to prepare all necessary documents, agreements and/or contracts for our project and/or services with you for execution including any obligations arising from any contracts and/or agreements entered into between you and us and to provide you with the information and services that you request from us;
6. 3.1.6. to maintain and upkeep internal client records, administration, management, business development, continuous professional development, education, research, internal operations, troubleshooting, data analysis, statistical and survey purposes, employment and social activities;
7. 3.1.7. to meet any legal or regulatory requirement relating to our services and to make disclosure under the requirements of any applicable law, regulation, directive, guideline, by-law, code, circular, government authorities and/or court of competent jurisdiction;
8. 3.1.8. to operate our website and information technology software (including the collection of internet protocol address and cookies) including all internet related activities;
9. 3.1.9. to provide you with a subscription to our regular alerts, updates, newsletters, publication notices, and other information which might be of interest to you;
10. 3.1.10. to notify you about our events, provide you with the relevant event materials and obtain relevant feedback from you;
11. 3.1.11. to respond to your queries, requests or feedbacks;
12. 3.1.12. to be named as potential referees to editors/researchers in legal ranking publications and journals;
13. 3.1.13. to process your job application, conduct pre-recruitment screening and to manage your employment with us; and
14. 3.1.14. for any other related purposes in the course of business.

Nature of Personal Data

4.1. Personal Data refers to personal information relating directly or indirectly to an individual who is identified or identifiable from that information or from that and other information in our possession. At HHQ, Personal Data collected by us includes, but is not limited to, the following:

1. 4.1.1. name, job title;
2. 4.1.2. age, gender, date of birth, nationality, national registration identity card number, passport number, photograph;
3. 4.1.3. race, ethnic origin;
4. 4.1.4. contact information including address, email address and phone number;
5. 4.1.5. marital status, details of family members, occupation, work history, performance review, income range, employer, references and any other details of past employer;
6. 4.1.6. type of loans applied for in relation to purchase of property;
7. 4.1.7. bank account information, tax file identification number, SST registration number, EPF number, SOCSO number;
8. 4.1.8. criminal history; and
9. 4.1.9. any other relevant information and data to enable us to provide you with our services and to share information that may be of interest to you.

4.2. We do not knowingly collect or process Personal Data of individuals under the age of 18 without the prior consent of their parent or legal guardian. In the event we collect or process Personal Data of individual under the age of 18, we will require consent from their parents or legal guardians.

4.3. We may also collect the following sensitive Personal Data [in relation to employment purposes]:

1. 4.3.1 your physical or mental health conditions;
2. 4.3.2 your religious beliefs or other beliefs of similar nature;
3. 4.3.3 your commission or alleged commission of any offence; and
4. 4.3.4 biometric data.

Source of Personal Data

5.1. We may collect Personal Data directly from you or from third party such as from our clients, business partners, contractors, employees and other individuals such as job applicants and potential clients. The Personal Data in our possession are sourced from, including but not limited to:

1. 5.1.1. official registration forms (either electronic or printed) for seminars or in-house talks, newsletter subscription or any other promotional events;
2. 5.1.2. your job application, curriculum vitae, resume, and official request for information forms that are provided to you by HHQ’s employees;
3. 5.1.3. any queries, emails or any correspondences that we have received from you requesting for information or making enquiries;
4. 5.1.4. any forms or requests that you have submitted through our website;
5. 5.1.5. from government agency or registry, or any referrals that we may have obtained from existing clients whom we have verifiable personal contact details;
6. 5.1.6. your real estate agent in a property transaction, or letters of offer from financial institutions for pre-approved loans;
7. 5.1.7. business cards that were dropped or given to our partners, associates or employees;
8. 5.1.8. CCTV or security recordings;
9. 5.1.9. cookies or other similar technologies;
10. 5.1.10. publicly available sources (including the results of searches conducted at public registries, and information obtained from any regulatory agency).

5.2. References to the term ‘you’ and ‘your’ shall include your representatives and agents.

Disclosing your personal data

6.1. In the course of our business and in order to provide you with our services, we may disclose your Personal Data to our affiliates or third parties, located within Malaysia or outside of Malaysia, for the purposes mentioned in this Notice. These third parties include, but are not limited to:

1. 6.1.1. affiliate firms or companies within the Andersen Global network;
2. 6.1.2. our affiliated law firms or business partners;
3. 6.1.3. any persons, government agencies, law enforcement agencies, statutory authorities and/or industry regulators where we are compelled to disclose Personal Data pursuant to any law, regulation or court orders;
4. 6.1.4. our suppliers, contractors, sub-contractors, service providers, representatives and agents as may be necessary or appropriate;
5. 6.1.5. our and/or our client’s auditors, consultants, accountants or any relevant financial institutions or professional advisers;
6. 6.1.6. counterparties or counterparties’ advisers, agents and representatives in any legal and/or commercial transaction, financial institutions for loan documentation processing; and
7. 6.1.7. any other individual or party or agency to whom you have consented to the disclosure of your Personal Data to.

6.2. By consenting to this Notice, providing us with your Personal Data or continuing to engage with us, you have consented to the disclosure and transfer of your Personal Data out of Malaysia, as necessary, for the purposes outlined in this Notice.

6.3. We will take reasonable and appropriate security measures to ensure that any disclosure of your Personal Data to any third parties is implemented in a safe and secure manner. These measures include transfer of data through secured channels or platform.

Securing your Personal Data

7.1. We take reasonable security arrangements such as implementation of access controls, regular cybersecurity risk assessments, anti-virus and firewall protection, access restrictions based on roles and responsibilities, employee training on data protection and handling procedures to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in our possession.

7.2. While we implement security measures to protect your Personal Data, no system can be entirely free from risk. We will continuously review and enhance our security measures to mitigate potential threats and safeguard your data to the extent reasonably possible.

Right to Access, Correct and Withdraw Consent to the Processing of Your Personal Data

8.1. It is important that your Personal Data in our possession is accurate and complete for us to provide you with our best services. You are responsible for informing us of changes to your Personal Data, or in the event, you believe that the Personal Data we have about you is inaccurate, incomplete, misleading, or outdated. You have the right to request to access, correct, update and modify your Personal Data within our possession by contacting us through the contact details below. When processing your request, we may ask you for information to verify your identity. Where permissible under law, we may refuse to comply to such requests.

8.2. You may partially or fully withdraw your consent to the collection, use, disclosure, storing and/or processing of your Personal Data by contacting us using the contact details below, subject to the conditions and/or limitations imposed by applicable laws or regulations.

8.3. Depending on the extent of your withdrawal of consent, we may not be able to continue to provide you with some or all of our services or to perform any contract we have with you and we will not be liable in the event that we do not continue to provide our services to, or perform our contract with you. Our rights and remedies are expressly reserved in such an event.

Contact Details

8.4. For any queries or requests in relation to your Personal Data, please contact us at:

• Contact Person: Ong Johnson
• Designation: Data Protection Officer
• Email: dpo_hhq@hhq.com.my

Retention

9.1. We will retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected. Upon fulfilment of those purposes, we will continue to retain your Personal Data yup to an additional period of 7 years to comply with legal, regulatory, accounting, or business requirements. Thereafter, your Personal Data will be securely disposed of or anonymised in accordance with our internal data retention and disposal policies.

Cookies and links on our website

10.1. Cookies are small text files containing small amounts of information which are downloaded and may be stored on your user devices such as your computer, smartphone or tablet. Cookies gather information about your operating system including, but not limited to, browser type, and Internet Protocol (IP) address. We may use this information to analyse the traffic on our website and better serve you when you return to our website. You have the option to configure your Internet browser to notify you when you receive a cookie, giving you the option to decide whether to accept the cookies. Further, you may have the option to block all cookies. Please note, however, that if you refuse or otherwise block cookies you may not be able to use all of the functionality available on the website.

10.2. Our website may contain links to third party websites. We are not responsible for the privacy practices or content on such linked third party websites and users are encouraged to review the privacy policies applicable to the respective third parties website

Language

11.1. This Notice is issued in both English and Bahasa Malaysia languages. In the event of any inconsistencies between the English version and the Bahasa Malaysia version, the English version shall prevail.

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