LION STEELWORKS SDN BHD

PERSONAL DATA PROTECTION POLICY

Lion Group of Companies and Lion Group of Companies’ associates, jointly controlled entities and affiliates (collectively, “Group”) respects the privacy of individuals with regard to personal data. This Personal Data Protection Policy formulated in accordance with the Personal Data Protection Act 2010 (“Act”). For the purpose of this, “Personal Data” shall have the meaning as ascribed to it in the Act. For the purpose of this Personal Data Protection Policy we shall refer to any of the companies within the Group and “you” shall refer to yourself and such other persons or companies represented by you of which you are providing the Personal Data.

NATURE OF PERSONAL DATA

Such Personal Data may be subject to applicable data protection, privacy and other similar laws and may include information concerning name, age, identity card number, passport number, address, gender, date of birth, photograph, children basic details, marital status, occupation, income range, contact information, email address, employer, race, ethnic origin, nationality and information obtained independently by the Group from other lawful sources.

PURPOSE OF COLLECTION OF PERSONAL DATA

By providing any of your Personal Data to the Group, you hereby agree that the Group shall collect, retain and use the Personal Data for the following purposes:

providing you with services or benefits under any of the Group’s business or policies; and/or

processing your application under any of the Group’s programme; and/or

where relevant, marketing of goods and services and sending any updates, new products, special offers, advertising, promotional material and/or commercial material to you (including emails, short messages services or other means) and/or to be used in, to provide and/or improve the services of the Group, processing invoices and payments (including card payments) and providing other services to enhance and support the relationship of the Group and you and/or such other persons or companies represented by you; and/or

conducting research on planning, product, goods, services, security and testing; and/or

carrying out matching procedure in accordance with the law; and/or

performing statistical analysis for various objectives in the Group and providing this information within the Group; and/or

purposes connected with the operation, administration, development, record-keeping or enhancement of the Group’s business including for the purpose of which is relevant to support and/or assist in any of the Group’s businesses; and/or

purposes connected with the administration, management and/or enforcement of the commercial transaction and for contact and communication with you and/or such other persons or companies as represented by you; and/or

where required by law, where the Group consider that such use or disclosure is necessary to respond to any claims or legal process, or where the Group suspects that fraud or unlawful activity has been, is being or may be engaged in; and/or

where a third party acquires or wishes to acquire, or makes inquiries in relation to acquiring, an interest in any company within the Group; and/or

where a third party requires in order for such third party to perform functions or services as required by the Group; and/or

enabling the Group or where a third party required in order for such third party to perform functions or obligations as required under the laws, rules, regulations, by laws and/or guidelines (whether or not having the force of law) or as required by any governmental and/or non-governmental authorities, agencies or departments or a third party requires in order to ensure compliance with agreement(s) or document(s); and/or

where a third party requires in order for purposes of preparation and submission of any claims or payments to any party or for any audit/checks by any party for whatever purpose related to the Group’s business; and/or

purposes connected with the enforcement of the Group’s rights pursuant to any letter, agreement and/or document including seeking legal and financial advice, taking any preliminary steps or commencing any legal action; and/or

making such disclosures as may be required for any of the above purposes or by law.

credit assessments and other background checks of users as we may determine to be necessary or appropriate.

prevention of crime (including but not limited to fraud, money-laundering, bribery)

We may either contact you for the purpose as set out in (B) above via telephone calls, emails, short message services or by whatsoever form of available communication.

USE AND DISCLOSURE

You further agree that the Group may disclose and transfer (whether in Malaysia or abroad) amongst any company within the Group and/or to third parties including but not limited to the Group’s agents, consultants, solicitors, auditors, employers, contractors, sub-contractors, suppliers, partners, joint venture partners, advertisers, purchasers, network operators, associated companies, any relevant authorities, embassies, statutory bodies, regulatory bodies, industry regulators, organisations or any relevant financial institutions, ,professional advisers, any other persons under a duty of confidentiality to the Group or any company within the Group, any of the companies within the Group, actual or proposed assignees or transferees or buyers of any of rights/businesses/assets of the companies within the Group, third party service providers for the Group’s operational, administration and development requirements and to organizations who provide archival, auditing, professional advisory, debt collection, insurance, banking, marketing, advertising, mailhouse, delivery, recruitment, call centre, technology, research, utility and security services to use, disclose, hold, process, retain or transfer such Personal Data for the purposes of (B) above for and on behalf of Group.

The Group uses and discloses aggregated non-personally identifying information collected by us as part of the Group’s process of constantly improving our business and/or the Group’s business.

IMPACT OF NON PROVISION OF PERSONAL DATA

The failure to supply such Personal Data will:-

result in us being unable to provide customers/prospective customers with the notices, services and/or products requested; and/or

result in us being unable to update you on our latest product.

SAFEGUARDS

We shall keep and process your data in a secure manner. We endeavour, where applicable, to implement the appropriate administrative and security safeguards and procedures in accordance with the applicable laws and regulations to prevent the unauthorized or unlawful processing of your Personal Data and the accidental loss or destruction of, or damage to, your Personal Data.

DATA TRANSFER & SHARING

Where we consider it necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your Personal Data to another member of our Group or third party service or product providers within or outside the country in which we are established, under conditions of confidentiality and similar levels of security safeguards.

YOUR RIGHTS OF ACCESS AND CORRECTION

You have the right to request access on payment of a prescribed fee to and correction of information about you held by us and in this respect, you:

check whether we hold or use your Personal Data and request access to such data;

request that we correct any of your Personal Data that is inaccurate, incomplete or out-of-date;

request that your personal data is retained by us only as long as necessary for the fulfilment of the purposes for which it was collected;

request that we specify or explain its policies and procedures in relation to data and types of Personal Data handles by us;

communicate to us your objection to the use of your Personal Data for marketing purposes whereupon we will not use your Personal Data for these purposes; and

withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period.

The department to whom written requests for access to Personal Data or correction and/or deletion of Personal Data or for information regarding policies and procedures and types of Personal Data handled by us is:

Department Name:	Credit Control
Contact No.:	(603)-33413822
Fax No.:	(603)-33421224 / (603)-33427630
Email Address:	gunaselvi@lion.com.my
Address:	Lot 4 Solok Waja , Kawasan Perindustrian Bukit Raja , 41050 Klang, Selangor.

CONFIDENTIALITY

Personal Data held by the Group will be kept confidential in accordance with this Personal Data Protection Policy pursuant to any applicable law that may from time to time be in force.

Any questions, comments, suggestions or information other than Personal Data submitted to us in whatever manner will be deemed voluntarily provided to the Group on a non-confidential and non-proprietary basis.

The Group reserves the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely as set out in (C) above.

PERSONAL DATA GIVEN BY YOU

You hereby confirm that you have obtained the consent from the persons or companies represented you for you to provide their respective Personal Data to us.

CHANGES TO PERSONAL DATA PROTECTION POLICY

The Group reserves the right to amend this Personal Data Protection Policy from time to time without prior notice. The Group advises that you check this Personal Data Protection Policy on a regular basis.