SIME MOTORS PRIVACY POLICY

This privacy policy; in accordance with the Malaysian Personal Data Protection Act 2010 (“Act”); setsout how Sime Darby Motors Sdn. Bhd. and its group companies (collectively, “Sime Motors”, “we”,“us” or “our”) use, process and protect any personal data that you provide to Sime Motors.

Sime Motors is committed to ensuring that your privacy is protected. Should we ask you to provide uswith your personal data, then you can be assured that it will only be used in accordance with thispolicy. For the purposes of this policy, “personal data”, “sensitive personal data” and “processing” shalleach have the same meaning as set out in the Personal Data Protection Act 2010 and all applicablelaws and regulations relating to processing of personal data and privacy, including where applicablethe guidelines and codes of practice registered with or issued by the Personal Data ProtectionCommissioner

Sime Motors reserves the right to change this policy from time to time. If we change our policy, we willplace notice(s) on our website or any other appropriate means. Continued use of the service(s) willsignify that you agree to any such changes.

This privacy policy serves to inform you that your personal data (which includes sensitive personaldata) is being processed by or on behalf of Sime Motors and applies to all personal data (includingsensitive personal data) we collected from you.

1. What we collect

In the course of your dealings with us, your personal data (including sensitive personal data) isand will be collected from you through the Vehicle Sales Order/Retail Customer Order/ServiceQuotation/Repair Order/other relevant form(s) and/or from the information you have providedto us, your emails, in any correspondence with us which includes but not limited tocommunication through face to face, telephone, online, social media and any other media, thirdparties (such as banks, insurance companies, credit reference agencies, CompaniesCommission of Malaysia) and/or as a result of our relationship with you.

We may collect the following information:

  • Name, national registration identity card, driving license, company name and job title. A copy of your national registration identity card which (in some jurisdictions) may contain certain information related to religion and be considered as sensitive personal data
  • Biometric data including but not limited to fingerprints and/or facial images collected for identification and verification purposes, which is considered as sensitive personal data
  • Contact information including address, phone number and e-mail address
  • Demographic information such as postcode, preferences and interests
  • Personal/financial information such as EA forms, religion, nationality, marital status, date of birth, age, hobby/interest
  • Other information relevant to motor vehicle purchase, motor vehicle details (which may include but not limited to telematics information such as GPS tracking, mileage, engine diagnostics etc), customer surveys and/or others
  • Other information provided by you in your course of dealings with us in any way of manner, including pursuant to any transactions and/or communications made from/with us.

Provision of your personal data is voluntary. However, if you do not provide us with suchrequired personal data, it may result in (i) us being unable to effectively render our services toyou; (ii) us being unable to administer or continue to administer/perform any arrangement orcontractual relationship in place between you and us; (iii) us being unable to process yourpersonal data for any of the Purposes; and/or (iv) the termination of anyarrangements/agreements/contracts between you and us, without any liability on our part(“Consequences” collectively).

2. What we do with the information we gather

We are processing your personal data to understand your needs and provide you with betterservice, and in particular for the following reasons (“Purposes”):

  • Inspection and/or registration of motor vehicle ownership at the relevant governmental and/or regulatory authorities including but not limited to Puspakom Sdn Bhd (or any other authorised vehicle inspection company) and/or Road Transport Department Malaysia (Jabatan Pengangkutan Jalanraya);
  • Internal record keeping which includes the updating of our after-sales service records of the motor vehicle. This relevant information will be used by us, our appointed after-sales service dealers, agents and/or sub-contractors to provide the relevant after-sales service and/or repair as well as to communicate with you on any matter relating to the provision of the service in general including notifying you on the next/subsequent date/mileage for routine service for the motor vehicle;
  • Improvement of our products and services;
  • Customisation of our website and/or any other platforms such as social media;
  • Activation of motor vehicle warranty with the relevant motor importers/distributors and/or relevant motor/manufacturer overseas and the activation of motor vehicle extended warranty with the relevant insurance company(ies);
  • Disclosure of your information to service providers, agents and/or contractors from time to time to help us to provide and market our products and services to you and you have the option to elect not to receive any direct marketing promotional information from us;
  • For statistical analysis and includes our disclosure of your information to our customer service agencies for research and analysis purposes so that we can monitor and improve the services we provide; for administrative purposes and statistical analysis;
  • Disclosure of your information to bank(s) and/or financial institutions for them to reach out to you on the exploration of possible financing arrangement(s) on your purchase of vehicle(s) from us;
  • Compliance with any legal requirements;
  • Marketing;
  • Provision of services and/or products to you;
  • Communicating with you;
  • Legitimate business activities; and/or
  • Market and development survey/research purposes in order to improve through quality Page 6 of 20 assurance and improvement activities as a result thereof.

3. Protection of Personal Data

We are committed to ensuring that your information is secure. In order to prevent unauthorizedaccess or disclosure we have put in place suitable physical, electronic and managerialprocedures to safeguard and secure the information that we collect from you and via online.

We will not sell or lease your personal data to third parties unless we have your permission orare required by law.

4. Disclosure

We may share your personal data with third parties, which may be located in or outside ofMalaysia. The list of third parties is accessible via the link of https://www.simemotors.com.my/pdpa-notice/business-units. The list of third parties may bechanged, amended and/or updated from time to time. If we change, amend and/or update thelist, we will place notice(s) on our website or any other appropriate means. Continued use ofthe service(s) will signify that you agree to any such changes.

For purposes of easy reference, the third parties include but not limited to the following:

  • our group of companies, including affiliated companies and business partners.
  • our financial, professional or legal advisers.
  • our joint venture/business partners and third-party service providers, suppliers, vendors, contractors, data processors or agents that provide related products and/or services in connection with our business, or discharge or perform one or more of the above purposes stated in this privacy policy and other purposes required to operate and maintain our business.
  • bank(s) and/or financial institution(s) for the purposes of applying and obtaining credit facilities and hire-purchase arrangement(s) for your purchase of vehicle(s) from us, if necessary.
  • our manufacturers and/or insurance companies, which will provide the necessary warranties and/or extended warranties (if any) for the vehicle.
  • our appointed after-sales service dealers, our agents and our sub-contractors to provide the relevant after-sales service and/or to repair the vehicle as well as to communicate with you on any matter relating to the provision of the service in general.
  • government agencies, law enforcement agencies, courts, tribunals, regulatory bodies, industry regulators, ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities.

5. Retention and Disposal of information

We will retain your personal data for the following time duration and will dispose the samethereafter:

  • Up to twelve (12) months after the expiry of the maximum warranty period or extended warranty period (as the case maybe) of the vehicle/parts fitted in the vehicle from the date:
    • of the motor vehicle is registered into your ownership; or
    • when any other party inform us that he/she/they is/are the new owner of the motor vehicle;
  • Up to twelve (12) months after the expiry of the maximum warranty period or extended warranty period (as the case maybe) of the vehicle/parts fitted in the vehicle from the:
    • date the motor vehicle warranty is activated with the motor manufacturer overseas and/or the date the motor vehicle extended warranty is activated with the insurance company(ies); or
    • last date the motor vehicle was sent to our after-sales service centre/workshop for service and/or repair works;
  • Up to twelve (12) months from the date when the vehicle was sent to our after-sales service centre/workshop for servicing in cases where there are no parts warranty applicable;
  • Two (2) years from the date you submit your information and/or details to us (other than for the purposes of vehicle purchases, aftersales services, and/or vehicle rental services) through submission via our website or any other platforms such as social media etc. and/or our consent form(s) when you visit us and/or our appointed sales and/or after-sales dealer(s);
  • Six (6) months from the date of vehicle test drive being conducted with you;
  • In the case of 360 Customer Mobile Application, such as OneGo Application, two (2) years from the date of your last interaction within the Application;
  • In the case of information submitted via website or any other online platforms such as contactless application for the purposes of vehicle rental services, two (2) years from the date of your last interaction within the online platform;
  • In the case of information submitted via offline platforms such as Hertz CarRental Kiosk for the purposes of vehicle rental services, two (2) years; or
  • any period as may be required by applicable laws or regulations.

6. Access and Correction of your personal data

Subject to the provisions of the Act, you have a right to:

  1. request a copy of your personal data we hold about you (for which we may charge a small fee as permitted by applicable laws, if necessary) for granting you access to your information. If you wish to exercise this right, you may put your request in writing by emailing to data.protection@sime.com to request for such access or if necessary, Page 9 of 20 to obtain the form for completion of the details therein and upon completion of the said form, to email it back to data.protection@sime.com; and/or
  2. correct any inaccuracies in or update your data (for which we may charge a small fee as permitted by applicable laws, if necessary). If you wish to exercise this right, you should put your request in writing by emailing to data.protection@sime.com to request for such correction and/or update or if necessary, to obtain the form for completion of the details therein and upon completion of the said form, to email it back to data.protection@sime.com.

We will reply to you within twenty-one (21) days from our receipt of your aforesaid request,either by way of post to the address mentioned in paragraph no. 14 below or email to the emailaddress mentioned in paragraph no. 14 below.

We may 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.

7. Your rights

In addition to the above, subject to the provisions of the Act, you also have the right to:

  • request us to limit the processing and use of your personal data;
  • meminta kami untuk memberhentikan pemprosesan ataupun tidak bermula melakukan pemprosesan maklumat peribadi anda untuk tujuan pemasaran dan bahan promosi. Jika bantahan anda bukan terhadap pemasaran langsung secara Page 10 of 20 umum, tetapi terhadap pemasaran melalui saluran tertentu (sebagai contoh, sms, e-mel atau telefon), sila nyatakan saluran yang anda bantah; dan/atau
  • by notice in writing, inform us on your withdrawal (in full or in part) of your consent given to us to process your personal data, subject to any applicable legal restrictions, contractual conditions and reasonable duration of time for the withdrawal of consent to be affected;

by contacting us in the manner as described in paragraph 14 below.

If you limit the processing or withdraw your consent to any or all use of your personal data, itmay result in any of the Consequences (as specified in paragraph 1 above).

8. Other Privacy Policies

You may visit our website and/or any other platforms such as social media etc., during whichyou may access links or functions provided by any other independent businesses (e.g. motorprincipals, banks and/or financial institutions) located within our website and/or any otherplatforms such as social media etc. Any such independent businesses shall have theirrespective specific privacy policies in relation to their respective processing, use and retentionof your personal data. Please refer, read and understand their respective specific privacypolicies (“other privacy policy(ies)”) as your personal data will be governed by the terms andconditions of the other privacy policy(ies).

By virtue that the other privacy policy(ies) are controlled by such other independent businesses,we:

  1. has no control nor the ability to control/influence how such other independent businesses use, manage and/or retain your personal data.
  2. shall not be held responsible for such other independent businesses in relation to their processing, use and/or retention of your personal data.

9. Personal Data of other persons

We may require your assistance if the personal data of some other person(s) is required toPage 11 of 20process your personal data for the Purposes and you hereby agree to use your bestendeavours to assist us when required.

In the event that personal data of any third party is supplied by you to us, you shall ensure thatsuch third party has read this policy and consented to us collecting his/her personal data forany of the Purposes prior to the supply of his/her personal data to us.

10. Submission of your personal data on behalf

Where another person is providing/submitting any of your personal data to us, you agree thatyou have authorised the disclosure of your personal data to us and consented to the processingof your personal data by us in accordance with this privacy policy.

11. Transfer out of Malaysia

We may transfer your personal data to the following classes of third parties outside Malaysiaand you hereby give your consent to the transfer:

  • principals, manufacturers and/or third-party service providers, suppliers, vendors, contractors, data processors and/or agents for the purposes of providing related products and/or services in connection with our business, for discharging or performing one or more of the purposes stated in this privacy policy, and/or other purposes necessary to operate and maintain our business.
  • manufacturers and/or insurance companies for the purposes of providing the required warranties and/or extended warranties (if any) for the vehicle.
  • third-party service providers, suppliers, vendors, contractors and/or data processors for the purposes of data storage and back-up.

12. Personal Data to be accurate, complete and up to date

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

13. Conflict

In the event of any conflict between the English version of this privacy policy with a versiontranslated in another language, the English version will prevail.

14. Inquiries and complaints

If you would like to contact us with any queries or comments in respect of your personal data,you may contact us by sending us an email or writing to our data protection officer as follows:

Designation: Data Protection
Telephone No.: 03-7623 2000
Email-Address: data.protection@sime.com
Postal/Correspondence Address: Level 9, Menara Sime, Oasis Corporate Park, Jalan PJU 1A/2, Ara Damansara, 47301 Petaling Jaya, Selangor, Malaysia