Novugen Pharma (Malaysia) Sdn. Bhd. (hereinafter referred to as “we”, “our” or “us”, which expressions include our employees, representatives and/or agents) treats your personal data (“Personal Data”) seriously.

This Personal Data Protection Notice (“Notice”) specifies how we manage and safeguard Personal Data in compliance with the Personal Data Protection Act 2010 (the “Act”). We encourage you to read this Notice carefully to ensure that you know and understand the purposes for which we collect, process, use, retain and disclose your Personal Data.

“Personal Data” refers to any and all information in respect of commercial transactions that relates directly or indirectly to an individual, who is identified or can be identified from that information or in combination with other information in the possession of a data user and includes the meaning otherwise as defined in the Act as amended from time to time.

“you” or “your” means any individual/party who is the subject of the Personal Data to whom the Act applies.

By using or accessing our official website at www.novugen.com (“Official Website”), you agree and consent to us collecting, processing, using, retaining and disclosing your Personal Data in accordance with this Notice.

This Notice does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data. Your consent to the contents of this Notice is in addition to any other rights which we may have at law to collect, process, use, retain and disclose your Personal Data.

1. Introduction

1.1This Notice describes how we collect, process, use, retain and disclose your Personal Data obtained through, amongst others, your e-mail communication with us, your participation in our events and/or other promotional activities, through our general business contact with you and through our abovementioned Official Website.

1.2 We are responsible for maintaining and protecting your Personal Data under our control. We have designated an individual or a group of individuals who is/are responsible for compliance with this Privacy Policy (“Privacy Officer(s)”). Further details pertaining to our Privacy Officer(s) are specified in paragraph 6 below.

2. Types of Personal Data Collected

2.1 The types of Personal Data and documents which we may collect from you including, but not limited, to the following:-

  1. personal details such as name, title, gender, date of birth, national registration identity card/passport number and other identification documents/information, if applicable;
  2. relevant details required for contacting you such as correspondence address, delivery address, e-mail address, fax number and telephone number; and
  3. any other Personal Data and documents as may be requested of you or which you may provide in or pursuant to any specific form/document/contract involving you or your participation.

2.2 The extent of and the exact Personal Data and/or documents that are collected from you may vary from case to case depending on a range of factors and circumstances, such as the nature of the transaction and dealings with you.

3. Sources of Personal Data Collection and Consent

3.1 Personal Data may be collected from you in one or more of the following ways:-

  1. when you use or access our Official Website;
  2. when you contact us or request that we contact you;
  3. when you respond to or participate in our campaigns or other initiatives or attend our events;
  4. when we receive references from business partners and third parties, for example, where you have been referred by them;
  5. when you provide your Personal Data to us for any other reasons; and/or
  6. when we collect your Personal Data by other lawful means.

3.2 By accessing our Official Website and/or you providing us with the Personal Data, you warrant and represent to us that; (a) Personal Data which you provided to us is accurate and complete; and (b) where you volunteer Personal Data of another person to us, that you are authorized by such other person to disclose such Personal Data to us, and that such Personal Data is accurate and complete.

4. Purposes of Personal Data

4.1 Your Personal Data may be or may have been collected, processed, used, retained and/or disclosed for any of the following purpose(s) (collectively “Purposes”) in connection with our process:-

  1. to manage, develop, improve and ensure that content from our Official Website is presented in the most effective manner for you and for your computer;
  2. to facilitate the provision of products or our services to you;
  3. to respond and deal with enquiries, complaints and other related matters or otherwise communicate with you;
  4. to send you information and updates in relation to our products or services;
  5. to carry out our obligations arising from any contract which may be entered into between you and us;
  6. to facilitate your participation in interactive features of our services, when you choose to do so;
  7. to notify you about changes to our products or services;
  8. to comply with legal and regulatory requirements;
  9. to disclose to any person(s) in connection with or to facilitate any joint venture, collaboration, business asset transactions (which may extend to any mergers, reconstruction, acquisitions or asset sales) or any proposal relating thereto involving us or all or any part of our businesses, assets or liabilities;
  10. for other purposes for which we have obtained your consents thereof; and/or
  11. for any other purposes reasonably necessary, ancillary or related to the above specified purposes.

4.2 Your Personal Data may be disclosed for the Purposes indicated in paragraph 4.1 above to any of the following categories/classes of third parties whether within or outside Malaysia:-

  1. our officers and employees;
  2. our parent, affiliates, and any other related corporations (including those to be established in the future);
  3. relevant government regulators or authorities or law enforcement agencies;
  4. our business partners;
  5. contractors, service providers, advisors, and consultants which includes, without limitation, the following persons or entities:-
    • our insurers and advisors, including consultants, auditors and lawyers;
    • data intermediaries; and
  6. any other party to whom you authorize us to disclose your Personal Data.

4.3 Your Personal Data may be transferred to our corporate headquarters, our regional offices, and/or related corporations (whether within or outside of Malaysia) for processing and storage. Your Personal Data may also be transferred to, stored and/or processed in one or more country or territory outside Malaysia if required or deem necessary or desirable by us in connection with any of the Purposes. By accessing our Official Website and/or providing Personal Data to us, you consent to any such transfer, storage and/or processing of your Personal Data outside Malaysia. We will, however, ensure that any party to whom we transfer your Personal Data outside Malaysia shall comply to a standard of protection at least comparable to the protection under the Act.

5. Failure to provide Personal Data & Withdrawal of Consent

5.1 It is obligatory for you to provide your Personal Data and relevant documents to us to enable us to process such Personal Data for any of the Purposes specified in paragraph 4.1 above.

5.2 You may withdraw your consent to our continued use, processing, and disclosure of your Personal Data at any time by contacting our Privacy Officer(s) via e-mail as specified in paragraph 6.3 below.

5.3 In failing to provide your Personal Data to us, or in withdrawing your consent, you acknowledge that we may not be able to use, process or disclose or continued to use, process or disclose your Personal Data to facilitate or continue facilitating (as applicable) the provision of services to and effective use and access to our Official Website by you or for any of the other Purposes, and we may cease facilitating such provision accordingly without any liability.

6. Accuracy, Access and Correction

6.1 We will endeavor to ensure that your Personal Data that we use is sufficiently accurate and complete.

6.2 To help us maintain the accuracy of your Personal Data, we encourage you to inform us within a reasonable time when there are changes to your Personal Data which you have provided us by writing to our Privacy Officer(s) via e-mail as specified in paragraph 6.3 below. We will correct or complete your Personal Data as soon as reasonably practicable.

6.3 If you have any question about this Notice or would like to make a complaint or to correct or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) or limiting the processing of your Personal Data, please contact our Privacy Officer(s) emailing to the e-mail address stated below:-

Email address: privacy@novugen.com

6.4 Any withdrawal of consent, request of access or request of correction or limiting the processing of your Personal Data is subject always to the requirements, restrictions and the provisions of the Act and any rules, regulations, orders, codes and our rights thereunder.

7. IP Addresses and Cookies

7.1 We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is only statistical data and does not identify any individual.

7.2 We may use "cookies", which are small pieces of information that are stored by your browser on your computer’s hard drive, to enhance the user experience of our Official Website. You may at any time refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies.

8. Security and Protection

8.1 We will use reasonable endeavor to protect your Personal Data in our possession or control against risks of loss, misuse, unauthorized or accidental access or disclosure, unauthorized collection, use, copying, modification, disposal or destruction, through reasonable and appropriate security measures. We strive to ensure that our systems are secure and meet industry standards.

8.2 To prevent unauthorized access, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Personal Data we collect. Notwithstanding our security measures for protecting your Personal Data, you acknowledge that no data transmission over the internet is completely secure and by providing your Personal Data, you are transmitting information and/or documents at your own risk.

9. Retention of Personal Data

We will retain your Personal Data for as long as you use or access our Official Website and as may be necessarily required or relevant for business or legal purposes. We will take all reasonable steps to ensure that your Personal Data is destroyed or permanently deleted if it is no longer required for the purpose for which it was to be processed.

10. Security and Protection

This Notice applies only to our Official Website, and not to any other websites owned by third parties. Although we endeavor to only link to sites with high privacy standards, this Notice will no longer apply once you leave our Official Website. Additionally, we are not responsible for the privacy and personal data protection practices employed by third party websites.

11. Revision of Notice

We may review, update and/or modify this Notice from time to time as deemed necessary by us. You are advised to check our Official Website regularly to ensure that you have read the most recent version of our Notice. Subject to your rights at law, you agree to be bound by the prevailing terms of this Notice as updated from time to time.