This Personal Data Protection Notice (“Notice”) is issued by UPM HOLDINGS SDN. BHD. and its subsidiaries (collectively referred to as “UPMHoldings” or “we” or “us”) and is applicable to existing/prospective business associates, customer, employee and/or any third party (“you”). This Notice explains how we collect and handle your personal data in accordance with the Personal Data Protection Act, 2010 (“Act”). Please note that the UPMHoldings reserves the right to make any variations and/or modification to this Notice at any time. Any variations and/or modification to this Notice shall be communicated through modes of communications deemed suitable by the UPMHoldings.


Personal Data

As we may process (to the extent applicable) the following personal data as provided by you and/or a service provider engaged by UPMHoldings and/or obtained from public domains, regulatory authorities, administrative authorities and/or supervisory authorities which may include, but is not limited to –

  1. your identity including photo, signature, name, contact numbers, email address(es), address(es), identification card/passport number, age, gender, race, nationality, marital status;
  2. your bank account numbers, CDS account number, such other information that you provide as existing/prospective business associates, customer, employee of UPMHoldings;
  3. video and voice recordings (including CCTV recordings and security recordings, images, testimonials, photograph and/or any other recordings of you as obtained when you are in UPMHoldings’s premises, facilities and offices and/or when you attend any of UPMHoldings related events, functions, activities and/or meetings);
  4. any other personal data that you provide/declare to the UPMHoldings and/or that are collected from you as; and any other information that you provide or are required to be given to become existing/prospective business associates, customer, employee of UPMHoldings.

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

Where applicable, we will process your personal data for the following purposes –

  1. to give effect and process your status as prospective business associates, customer, employee of UPMHoldings;
  2. to process your request to become prospective business associates, customer, employee, if applicable;
  3. to deliver, communicate and transmit UPMHoldings’s latest information and materials through modes of communication and delivery we deem appropriate (including without limitation verbally, in hard print, electronically or online);
  4. statistical analysis and historical data;
  5. as part of the UPMHoldings’s internal records management, internal compliance and corporate governance (including auditing, internal investigations, compliance, risk management, conflict of interest reporting, management reporting, and security processes);
  6. verification and identification purposes;
  7. compliance with laws, regulations, guidelines, codes and statutory requirements;
  8. to provide you with the services or information requested and for contact purposes;
  9. to defend and/or enforce UPMHoldings’s rights under law and/or obtain legal advice;
  10. to attend to your enquiries and generally to enable resolution of a concern or complaint;
  11. to facilitate your participation in any of UPMHoldings’s functions, activities, meetings and/or events;
  12. administrative and operational purposes, security and access within UPMHoldings’s premises and facilities;
  13. inclusion in media engagement and/or any relevant or related events and publication in any printed materials, website, electronic media and/or social media platform arising from your participation in any UPMHoldings related functions, activities, meetings and/or events;
  14. to better understand your needs as shareholders and/or investors and for any purpose that is incidental, ancillary or in furtherance to the above purposes.

The information you provide is necessary to the UPMHoldings. If you do not provide all the information as requested, we will not be able to keep your complete record of information, thus affecting the UPMHoldings’s ability to accomplish the above stated purposes.


Disclosure of Information

We may disclose your personal data to the following parties (including those overseas) –

  1. entities within the UPMHoldings;
  2. potential or actual purchasers, successors-in-title of the business or share (wholly or in part) of the UPMHoldings (including their advisers and representatives) as a result of a potential, proposed or actual sale of business, disposal, acquisition, merger or re-organisation;
  3. government departments and agencies, law enforcement agencies, regulatory authorities, statutory authorities and/or industry regulators and to whom we are compelled or required to do so under law;
  4. third parties appointed by the UPMHoldings to provide services to the UPMHoldings or on behalf of the UPMHoldings (including the UPMHoldings’s auditors, solicitors, financiers, agents, professional advisors, and other such service providers);
  5. any person, who is under a duty of confidentiality and/or who has undertaken the responsibility to keep such data confidential;
  6. any actual or proposed assignee, participant, sub-participant or transferee of any of our rights or obligations; and
  7. other parties, in respect of whom you have consented to the disclosure of your personal data.


Information Technology

When visiting the UPMHoldings’s websites, we may be able to identify you through collection of the following information during your visit to the UPMHoldings’s websites and/or the fully qualified domain name from which you accessed the UPMHoldings website, or alternatively, through your internet protocol (“IP”) address –

  1. the date and time in which you accessed UPMHoldings’s website;
  2. the URL of any webpage from which you accessed UPMHoldings’s website; and
  3. the web browser which you are using and the pages which you have accessed.

The UPMHoldings’s website may require you to provide a limited amount of information in order to obtain the services you requested and to enable the UPMHoldings to respond to your messages and requests. Any personal data provided will be used for its intended purpose only, i.e., to respond to your request for services, your messages and requests.

Links to other sites

Links to other sites may be provided on the UPMHoldings’s website for your convenience and information. These sites may have their own privacy statement and the UPMHoldings does not control, recommend or endorse these sites and the UPMHoldings will not be held responsible for these sites and their contents. As such, the UPMHoldings encourages you to read the privacy policies and terms of usage of these sites prior to accessing these sites.


Access, corrections and complaints

If you would like to make any inquiries or complaints or requests to access, correct or limit processing of your personal data, you may contact our officer below –

Corporate Office Tel: +6 03 894-17363 (from 9am to 5pm on business days excluding public holidays)


Where you elect to contact our officer via telephone, please also send an e-mail for verification and record purposes. UPMHoldings shall proceed to address your concerns as soon as practicable upon receipt of your request.