FULL POLICY

(A) Personal Data

Type of personal data

• Personal data means any information which relates to you and which was collected or provided to PCM GROUP for the purposes stated in this Policy.
• Personal data may include your name, contact details, address, identification card number, financial and banking account details, closed circuit television (“CCTV”) or security recordings, images (photographs and video recordings), location tracking or global positioning system (“GPS”) information.
• In addition to the above, if you are using PCM GROUP’s mobile application, personal data may also include approximate location permission (non-continuous), phone permission, precise location permission (non-continuous) and storage permission.

Source of personal data

Customer or potential customer: PCM GROUP collects your personal data directly from you or indirectly from third parties, your employer or searches carried out or information obtained from any regulatory or credit reporting agency. For example:

• when you contact us directly through PCM GROUP’s authorised dealers, distributors and / or branches;
• when you contact us directly through PCM GROUP’s Site and / or customer service team, for example, upon enquiry of our products and / or services;
• when you are using PCM GROUP’s mobile applications;
• through marketing activities or events, for example surveys conducted at road shows, exhibitions and / or business card collections via fish bowl method;
• through third parties such as our business partners and / or your agents;
• through regulatory authorities; and
• through cookies from the use of PCM GROUP’s website and / or PCM GROUP’s mobile applications.

Obligatory personal data:

• All information requested from you is obligatory to be provided by you unless stated otherwise.
• Should you fail to provide the obligatory information, we may be unable to:
  • provide you with the relevant product or services requested for; or
  • process the relevant commercial transactions.

Purposes for collecting and further processing (including disclosing) your personal data

Customer or potential customer: Your personal data is collected and further processed as required or permitted by law and to give effect to your requested commercial transaction, including the following:

• to process your order to purchase our products and / or services;
• to provide you with the services or information requested;
• to contact you regarding product information, services, upcoming events, promotions, advertising, marketing and commercial materials which we feel may interest you*;
• to provide you with after-sales services;
• for PCM GROUP’s internal records management;
• to carry out market analysis and research and customer profiling to gauge the market trends;
• to provide you with customer support;
• to facilitate your participation in any contest, event and / or membership programme;
• to ensure that the content of PCM GROUP’s website is presented in the most effective manner for you and for your computer and / or device;
• to improve the quality of PCM GROUP’s products and /or services;
• to provide assistance on your loan application and / or insurance related matters in relation to the purchase of our products;
• to operate our premises in a manner which is physically safe, secure and befitting of health and safety requirements;
• to support the business, financial and risk monitoring, planning and decision making of PCM GROUP;
• for internal investigations, audit or security purposes; and
• to comply with PCM GROUP’s legal and regulatory obligations in the conduct of its business.

*You may opt-out from receiving such marketing or promotional material at any time. You may select the “unsubscribe” option provided in PCM GROUP’s email blasts / short message services (“SMS”) blasts or you may contact PCM GROUP at the details provided in Section (H) below.

When using any of PCM GROUP’s Site or mobile applications, any use of Cookies – or of other tracking tools – by PCM GROUP’s Site or mobile applications or by the owners of third-party services used by PCM GROUP’s mobile applications serves the purposes of providing the services required by you, in addition to any other purposes described in this Policy and in the section relating to Cookies below.

Please note that you are responsible for any third-party personal data obtained, published or shared through PCM GROUP’s Site and/or mobile application and by doing the same, you confirm that you have obtained the third party’s consent to provide the personal data to PCM GROUP.

(B) Mode and place of processing the Personal Data

Methods of processing

PCM GROUP takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of your personal data.

The personal data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to PCM GROUP, in some cases, the Personal Data may be accessible to certain types of persons in charge, involved with the operation of this Site  (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Personal Data Processors by PCM GROUP. The updated list of these parties may be requested from PCM GROUP at any time.

Legal basis of processing

PCM GROUP may process Personal Data relating to you if you have given your consent for one or more specific purposes.

Note: Under some legislations PCM GROUP may be allowed to process Personal Data until you object to such processing (“opt-out”), without having to rely on consent or any other legal bases.

This, however, does not apply, whenever:

• provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which PCM GROUP is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in PCM GROUP;
• processing is necessary for the purposes of the legitimate interests pursued by PCM GROUP or by a third party.
• In any case, PCM GROUP will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

(C) Place, Disclosure and Transfer of Personal Data

Your personal data is processed at PCM GROUP’s operating offices and in any other place where the parties involved in the processing are located.

Depending on your location, personal data transfers may involve transferring your personal data to a country other than your own. If any such transfer takes place, you can find out more by inquiring with PCM GROUP using the contact information provided in Section (H) below.

Your personal data provided to us may also be disclosed to the following classes of third parties (within Malaysia unless otherwise) required under the law pursuant to relevant contractual relationship (for example, where we appoint third party service providers) or for the purposes or directly related to the purposes stated in this Policy:

• potential or actual purchasers, successors-in-title of the business or share (wholly or in part) of PCM GROUP (including their advisers and representatives) as a result of a potential, proposed or actual sale of business, disposal, acquisition, merger or re-organisation;
• PCM GROUP authorised dealers, PCM GROUP distributors and PCM GROUP parts suppliers
• our business partners such as insurance companies, banks and financial institutions;
• government departments or agencies, statutory authorities and industry regulators;
• any person to whom we are compelled or required to do so under law or in response to a competent or government agency;
• law enforcement agencies; and
• third parties appointed by us to provide services to us or on our behalf (such as auditor, lawyer, company secretary, service providers, printing company, telecommunications company, contractor, events and training organisers and other advisers).

(D) Websites

Links to other sites

Links to other sites may be provided on this Site for your convenience and information. These sites may have their own privacy statement and PCM GROUP does not control, recommend or endorse these sites and PCM GROUP will not be held responsible for these sites or their contents. As such, PCM GROUP encourages you to read the privacy policies of these sites.

Location enabled products or applications

Location enabled products or applications transmit your location information to us. PCM GROUP will not use the information sent or provided by you for any other purposes other than to provide the services you requested. Location enabled features are opt-in and you have control over your participation and can turn these services off at any time or uninstall them. Some mobile applications will utilise Google Analytics (or a similar tool) to help PCM GROUP better serve you through improved products, services and revisions to the mobile applications. The information collected will not allow PCM GROUP to identify you. It may, however, let us know anonymously, the services and products most searched by you within the application as well as device type used and your country of origin.

Cookies

• In processing your information, cookies, which is a text file placed into the memory of your computer, may be used. PCM GROUP is able to use these cookies to identify you. PCM GROUP may be able to collect the following information during your visit to our website and / or the fully qualified domain name from which you accessed our site, or alternatively, through your internet protocol (“IP”) address:
  • the date and time in which you accessed our website;
  • the URL of any webpage from which you accessed our website; and
  • the web browser which you are using and the pages which you have accessed.
• Some websites may require you to provide a limited amount of information in order to obtain the services you requested (i.e. name, email address, contact number). This personal data will only be used for its intended purpose only, i.e. to respond to your message or deliver the requested service.

(E) Mobile Application(s)

Device permissions for personal data access

Depending on your specific device, PCM GROUP’s mobile application may request certain permissions that allow it to access your device data described below.

By default, these permissions must be granted by you before the respective information can be accessed. Once the permission has been given, it can be revoked by you at any time. In order to revoke these permissions, you may refer to the device settings or contact PCM GROUP for support at the contact details provided in the present document.

The exact procedure for controlling application permissions may be dependent on your device and software.

Please note that the revoking of such permissions might impact the proper functioning of PCM GROUP’s mobile application.

If you grant any of the permissions listed below, the respective personal data may be processed (i.e accessed to, modified or removed) by PCM GROUP’s mobile applications.

Approximate location permission (non-continuous)

Used for accessing your approximate device location. PCM GROUP’s mobile applications may collect, use, and share your location data in order to provide location-based services.

Your geographic location is determined in a manner that is not continuous. This means that it is impossible for PCM GROUP’s mobile applications to derive your approximate position on a continuous basis.

Phone permission

Used for accessing a host of typical features associated with your phone. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

System logs and maintenance

For operation and maintenance purposes, PCM GROUP’s mobile application and any third-party services may collect files that record interaction with PCM GROUP’s mobile application (System logs) and use other personal data (such as the IP Address) for this purpose.

How “Do Not Track” requests are handled

PCM GROUP’s mobile application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

(F) Right to Access and Correct Personal Data

You have the right to access, verify, update and correct your personal data held by us. We will make every endeavour to ensure your personal data is accurate and up-to-date therefore we ask that if there are any changes to your information you should notify us directly via the contact details provided in Section (H) below.

You will also have the right, under certain circumstances, to restrict the processing of your personal data. In this case, PCM GROUP will not process your personal data for any purpose other than storing it.

If you would like to access your personal data, please send a query to the contact details in Section (H) below. If you would like to correct your personal data, please contact us at the details provided in Section (H) below.

In relation to PCM GROUP’s mobile application, you will have the right to receive your data in a structured, commonly used and machine-readable format, and if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

Legal action

Your personal data may be used for legal purposes by PCM GROUP in Court or in the stages leading to possible legal action arising from improper use of this Site or the related services.

You declare to be aware that PCM GROUP may be required to reveal personal data upon request of public authorities.

(G) Retention period

The personal data collected shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• Personal data collected for purposes related to the performance of a contract between PCM GROUP and you shall be retained until such contract has been fully performed;
• Personal data collected for the purposes of PCM GROUP’s legitimate interests shall be retained as long as needed to fulfil such purposes. You may find specific information regarding the legitimate interests pursued by PCM GROUP within the relevant sections of this document or by contacting PCM GROUP.
• PCM GROUP may be allowed to retain personal data for a long period if consent has been obtained for such processing, so long as such consent is not withdrawn. Furthermore, PCM GROUP may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, personal data shall be deleted. Therefore, the right to access, verify, update and correct your personal data cannot be enforced after the expiry of the retention period.

(H) Limiting the processing of personal data and further enquiries

PCM GROUP endeavours to take appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the personal data.

If:

• you would like to obtain further information on how to limit the processing of your personal data; or
• you would like to make an enquiry or have any requests in respect of your personal data;

you may write to us at customersupport@toyota.com.my or call our Customer Relations Executive at 1800-8-TOYOTA(869682).

In any case, PCM GROUP will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.