PRIVACY POLICY

We, Ponderosa Golf & Country Resort Berhad (Company Registration No. 199101005957 (216267-M) (hereinafter referred to as the "PGCR") view and treat your personal data seriously, and has therefore developed this Privacy Policy and to keep you informed on personal data protection and privacy practices.

DEFINITION

Your personal data is being processed by or on behalf of PGCR and for the purposes of understanding, the terms "personal data" and "processing" shall have the meaning prescribed in the Personal Data Protection Act 2010 (hereinafter referred to as the "PDPA").

1. Description of your personal data
   All personal data processed by PGCR includes personal details (such as name, age, gender, identity card number, passport number, date of birth, race, ethnic origin, nationality and photo), contact details (such as address, email, and phone numbers) family information (such as marital status, name of spouse or child or immediate family) and occupation.



2. Purposes for the processing of your personal data
   PGCR will process your personal data, including any additional information you may subsequently provide, for the following purposes (hereinafter referred to as the "Purpose" or "Purposes"):
   
   • Offer you an opportunity to take part in the events/activities/competitions organized by Ponderosa Golf & Country Resort Berhad;
   • Communication with you including responding to your enquiries;
   • Processing of your entry to the said events/activities/competitions;
   • For marketing and data analysis purposes and research purposes;
   • Sending you Corporate Social Responsibility (CSR) news, event news and updates, advertising and promotion materials, news on products and services and various other types of news and/or media with relation to Ponderosa Golf & Country Resort Berhad via electronic mail to your provided email address or via any other method of communication as may be suitable;
   • The record keeping of PGCR; and
   • Any other purposes relating or incidental to any of the above.



3. Source of your personal data
   
   • Your personal data is collected from you when you supply your personal data to PGCR by submitting an entry containing your personal data to the events/activities/competitions organized by Ponderosa Golf & Country Resort Berhad.
   • Apart from the above, PGCR may also collect personal data from your informal interactions with PGCR or its employees (e.g. telephone conversations, messages from WhatsApp or online interactions on social networking websites).
   • Further personal data may be collected by PGCR as updates from you from time to time as PGCR deems fit.



4. Your rights
   You have the following rights in relation to your Personal Data:
   
   • To make a data request in writing to PGCR for information of your personal data that is being processed by or on behalf of PGCR [Section 30(2) of PDPA];
   • To make a data correction request in writing to PGCR to correct any of your personal data which is inaccurate, incomplete, misleading or not up-to-date [Section 34(1) of PDPA];
   • To limit the processing of your personal data including personal data relating to other persons who may be identified from your personal data [Section 7(1)(f) of PDPA]; and
   • All other rights as expressly provided under the PDPA.
   
   
   If you have any requests in relation to the abovementioned rights or any inquiries or complaints in respect of your personal data, please write in to PGCR at:-
   
   ADMIN OFFICE
   Ponderosa Golf & Country Resort
   NO. 3, Jalan Ponderosa 1, Taman Ponderosa,
   81100 Johor Bahru,
   Johor, Malaysia.
   Telephone: 607-354 9999 l Fax: 607 -357 0133
   
   PGCR may refuse to comply with your data access request or your data correction request under the circumstances specified in the PDPA and if PGCR does so, PGCR will inform you of its refusal and the reason(s) for its refusal.



5. Class of third parties to whom PGCR may disclose your personal data
   This is the class of persons to whom PGCR may disclose your personal data:
   
   • Related companies of PGCR;
   • PGCR's lawyers or auditors;
   • Any person or party that acts as the agents, service providers and/or professional advisers of PGCR;
   • Your authorized lawyers, agents, executor, administrator or legal representative;
   • Regulatory bodies, government agencies, the police, law enforcement bodies and courts, both within and outside Malaysia; and
   • Such persons or bodies to whom PGCR is legally required to make disclosures.



6. Your obligations
   
   • It is obligatory for you to supply PGCR with your personal data and failure to do so will result in PGCR being unable to process your personal data for any of the Purposes.
   • You will take reasonable steps to ensure that your personal data is accurate, complete, not misleading and kept up-to-date.
   • All other obligations as expressly provided under the PDPA.



7. Security of your personal data
   PGCR, when processing your personal data, takes practical steps to protect your personal data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction.



8. Retention of your personal data
   PGCR will keep your personal data for the duration that is necessary to carry out the Purpose for which your personal data was collected and also for the other Purposes set out in this Privacy Policy.



9. Amendment to this Privacy Policy and Personal Data Notice
   PGCR reserves the right to amend this Privacy Policy at any time and will disseminate the changes either through its website or through other mediums deem suitable.



10. Others rights
    For avoidance of doubt, nothing in this Privacy Policy shall limit such other rights of yourself or PGCR under the PDPA.