Crown Privacy Policy | Crown Equipment Sdn. Bhd

1. Introduction

1.1 This Privacy Policy describes how Crown Equipment Sdn Bhd (“Crown") manages personal data (as defined in paragraph 2 below) which is in our possession or under our control in accordance with applicable data protection laws and regulations, including the Personal Data Protection Act 2010 (Act 709) and its subsidiary legislations, orders, gazettes, etc ("PDPA”). 

 

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

  

2. What is Personal Data?

2.1 Pursuant to the PDPA, “Personal Data” refers to any information in respect of commercial transactions, that relates directly or indirectly to an individual who is identified or identifiable from that information which is in Crown’s possession and includes any sensitive personal data and expression of opinion about the individual. 

 2.2 In this respect, we may collect the following: 

(a) your name, NRIC, passport or other identification number, telephone number(s), residential address, mailing address, email address;

(b) driver’s license details work experience and other qualification details;

(c) financial and banking information;

(d) photographs and video footage;

(e) any other personal data reasonably required in order for us to provide the services requested by you.

 

 3. How and when does Crown collect Personal Data?

3.1 Crown collects personal data in a variety of ways in the course of conducting its businesses, including: 

(a) in agreements it enters into with customers, suppliers, contractors and other personnel;

(b) when providing equipment and services and related information to customers, and administering customer accounts;

(c) when engaging suppliers, contractors and other personnel;

(d) when responding to questions regarding our products and our business;

(e) by interacting with people via our websites, email and telephone;

(f) when conducting trade promotions and competitions; and

(g) by security video surveillance at Crown sites;

(h) as applicable, publicly available or publicly accessible information;

 

3.2 At or soon after the time when Crown collects Personal Data, Crown will take reasonable steps to ensure that the person is aware that Crown has collected the information, the purpose(s) of the collection, the main consequences (if any) if the information is not collected, the types of organisation (if any) to which the Personal Data may be disclosed (including those located overseas), any law that requires the particular Personal Data to be collected, and the fact that this Privacy Policy contains details on the access, correction and complaints in regards to Personal Data. 

 

3.3 Personal Data collected by Crown may be held in a variety of formats, including hard copy format and on Crown’s computer systems. If Crown receives Personal Data that Crown has not requested (unsolicited information) and Crown determines that Crown could not have collected that information under the PDPA, then Crown will destroy or de-identify the Personal Data if it is lawful and reasonable to do so.

 

4. How does Crown use Personal Data?

4.1 We may use your Personal Data for our business purposes, including the following purposes (“Purposes”): 

(a) provide, maintain and improve the services provided by Crown;

(b) to understand your needs and preferences;

(c) responding to your queries or requests and providing customer service;

(d) matching any Personal Data held which relates to you for any of the purposes listed herein;

(e) verifying your identity for the purposes of providing our services to you;

(f) to manage and develop our business operations;

(g) to comply with any applicable laws or any request from any relevant governmental or regulatory authority;

(h) enforcing obligations owed to us;

(i) seeking professional advice, including legal advice;

(j) any other reasonable purposes in connection with the provision of the services or authorized by any applicable laws; or

(k) fulfilling any purpose directly related or ancillary to the above Purposes.

  

5. Disclosure of Personal Data

5.1 Crown respects the privacy of Personal Data and we will take reasonable steps to keep it strictly confidential. 

 

5.2 Crown will disclose Personal Data to third parties if it is necessary for the primary purpose of collecting the information, or for a related secondary purpose, if the disclosure could be reasonably expected (e.g. disclosure to a customer for the purpose of delivering equipment ordered from Crown, or to allow Crown to perform its obligations under the agreement). Where such a disclosure is necessary, Crown will require that the third party undertake to treat the Personal Data in accordance with the applicable legislation. 

 

5.3 Crown will only disclose Personal Data to third parties without the consent of the person to whom it relates if the disclosure is: 

(a) necessary to protect or enforce Crown’s legal rights or interests or to defend any claims;

(b) necessary for the purpose of preventing or detecting a crime, or for the purpose of investigations;

(c) necessary to prevent or lessen a serious threat to a person’s health or safety;

(d) required or authorised by law; or

(e) permitted by another exception in the PDPA and local legislation. 

 

5.4 Under no circumstances will Crown sell Personal Data without the consent of the person to whom it relates. Crown may disclose Personal Data to overseas recipients and such disclosure will be made pursuant to the provisions of the PDPA;

 

6. Information Security

6.1 Crown will take all reasonable steps as required under applicable laws, regulations and standards to ensure that all Personal Data held by Crown is secure from any loss, misuse, modification, accidental or unauthorised access, disclosure, alteration or destruction. However, Crown does not guarantee that Personal Data cannot be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosures will not occur. 

 

6.2 Should your Personal Data be transferred, held or collected by a third party authorised by Crown, we will ensure that such third party will provide similar and sufficient guarantees in protecting your Personal Data. 

 

6.3 Crown will take reasonable steps to destroy or permanently de-identify Personal Data if it is no longer needed for the purposes for which Crown is authorised to use it.

  

7. Accessing Personal Data

7.1 A person may request to access Personal Data about them held by Crown. Such a request can be made by contacting Crown via our contact details provided under the “Contact Crown” heading below. 

 

7.2 Crown will grant a person access to their Personal Data within the timeframe provided under applicable laws and regulations, subject to the circumstances of the request. 

 

7.3 A request to access Personal Data may be rejected if: 

(a) providing access would disclose confidential commercial information;

(b) providing access would have an unreasonable impact on the privacy of another person;

(c) providing access would pose a serious and imminent threat to the life or health of any person;

(d) providing access would prejudice Crown’s legal rights;

(e) such access to Personal Data regulated by another law; or

(f) there are other legal grounds under the PDPA to deny the request. 

 

7.4 Should Crown refuse your request, Crown will provide you with written notice of the refusal and our grounds of refusal within a reasonable timeframe. 

 

7.5 Crown may charge a fee for reasonable costs incurred in giving access to an individual’s Personal Data. Such costs may be as prescribed under applicable laws and regulations. The fee (if any) will be disclosed prior to it being levied.

  

8. Correcting Personal Data

8.1 Crown will take reasonable steps to ensure the accuracy and completeness of the Personal Data we hold. However, if a person believes that any Personal Data that we hold about them is inaccurate or out of date, then they should contact Crown via our contact details provided under the “Contact Crown” heading below. Crown will process your request within a reasonable timeframe and manner in accordance with the PDPA. Should Crown deny your request for correction, Crown will provide you with a notice in writing of our reasons for the refusal.

  

9. Additional information regarding Credit Information

9.1 This Privacy Policy also applies in relation to Crown’s collection and use of credit information of individuals in connection with commercial credit provided through Crown. 

 

9.2 The types of credit information that Crown collects and uses for the purpose of assessing an application for commercial credit typically include: 

(a) names, addresses and other contact details of accountholders and guarantors (both prospective and current);

(b) bank account details;

(c) driver’s licence details;

(d) financial information;

(e) information on the assets held by an individual. 

 

9.3 Such information is collected from the relevant individual and from credit reporting bodies, as well as from publicly available information. Crown uses the information collected to create an internal credit assessment report. 

 

9.4 Crown discloses credit information to credit reporting bodies: 

(a) to obtain a credit report from the credit reporting body; and

(b) for the purposes of lodging a default listing against the individual. 

 

9.5 When lodging a default listing we may do this ourselves or by our agents.

  

10. Google Analytics

10.1 Crown’s website also uses Google Analytics which is a web analytics tool offered by Google Inc. that generates detailed statistics about a website's traffic and traffic sources. Crown uses Google Analytics for statistical reasons, e.g. to measure how many users have clicked at a certain product information. Google Analytics uses Cookies to obtain information about your use of Crown’s website including your IP-address. As your IP-address is an individual element that would allow identifying you, Crown has implemented a specific code to ensure that your IP-address will only be collected in a shortened and anonymised form. Thus, Google will not be able to identify you from the IP-address that is collected from you when using this website. The information collected by this Cookie will be transferred to Google Inc. in the United States of America.

 

10.2 You  may  opt  out  of  Google  Analytics  by  using  the  following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB Most browsers are initially set to accept Cookies. However, you have the ability to modify the usage of or disable Cookies if you wish, generally through changing your internet software browsing settings.

Note: if Cookies are disabled, it may mean that you experience reduced functionality or you may be prevented from using elements of the Crown website altogether.

  

11. Withdrawal of consent

11.1 You may at any time via written notice in our “Contact Crown” heading below, communicate to Crown your intention to withdraw your consent to our usage, storage or collection of your Personal Data. We will respond to your request within a reasonable timeframe. Should you withdraw your consent, it may not be possible for Crown to perform our services and our contractual obligations to you. Notwithstanding this, Crown may use, store or collect your Personal Data if authorised or required to under applicable laws.

  

12. Transfer of Personal Data to places outside Malaysia

12.1 Crown may also transfer your Personal Data to third-party service providers or to other Crown entities which may be located outside of Malaysia. Your agreement to this Privacy Policy and your use or continued use of our services represents your acknowledgement and consent to such transfers. Notwithstanding this, Crown may transfer your Personal Data to such entities if required or as authorised under the PDPA.

 

13. Promotions and Direct marketing

13.1 In certain circumstances, Crown may use Personal Data for promotional or direct marketing purposes. However, a person may at any time via written notice request Crown to cease or not to use their Personal Data for sending direct marketing material to that person. Such a request can be made by contacting Crown via our contact details provided under the “Contact Crown” heading below. There is no fee for making such a request.

  

14. Contact Crown

14.1 If there are any questions or complaints regarding the Crown Privacy Policy or the way that Crown manages Personal Data or if there are any concerns about Crown’s treatment of Personal Data, then Crown may be contacted by post, telephone or email:

Crown Privacy Officer
No.9, Persiaran Pasak Bumi Section U8,
Bukit Jelutong, Selangor 40150
Telephone: (603) 5033 8500
Email: privacy.my@crown.com

 

14.2 Crown deals with complaints via our internal data privacy complaint process, under which a Crown contact officer will be allocated to assess your complaint and respond to you within a reasonable timeframe. Crown takes all complaints seriously and any further action after our initial response to you will vary depending on the nature of your complaint.

 

 

LEARNING MANAGEMENT SYSTEM


Privacy Policy

Your privacy is important to Crown. This Privacy Policy outlines the practices employed by Crown to explain how Crown collects, transfers, uses, discloses, and stores your information. Please review this policy to understand how your personal information will be treated as you use Crown’s learning.crown.com website. Please e-mail the Crown Privacy Office if you have any questions or concerns about this Privacy Policy.

 (a)       Collection of Information

Crown’s Learning Management System is used by Crown employees, branches, dealers and select customers to provide training materials. To access Crown’s Learning Management System, information such as name, address, email and phone number must be provided to Crown to enable Crown to set up an account for purposes of secure access and use. Further information to allow tracking of training modules completed may be required.

 (b)      Cookies

Cookies are small pieces of data that are sent to your browser from a web server and are stored on your device’s hard drive. Cookies are used on this site for various reasons including managing authentication and bookmarking progress within a training session. Cookies must be enabled to use the learning.crown.com site. Crown’s web servers also collect certain non-personal data such as domain names and IP addresses when you visit our website. This data is used only to measure and improve our website performance, not to personally identify users. We may also collect additional non-personal information such as location and language to help us improve the learning.crown.com website.

 

(c)        Transfer of Information

Information you provide is transferred over an encrypted connection. However, no data transmission over the internet can be guaranteed to be secure. Data transmission is at your own risk. Crown endeavors to protect the transfer of your information but cannot guarantee against, and will not be liable for, disclosure due to errors in transmission or unauthorized acts of third parties.

 (d)      Use of Information

Crown may collect, use, transfer, and disclose non-personal information for any purpose. Personal information provided by you will be used by Crown only to respond to your request, provide you services, and to assist Crown in developing, improving, and delivering our products and services including the learning.crown.com website. Crown may also use your information internally for data analysis and research.

 (e)       Disclosure of Information

In general, information provided by you will be used only by Crown Equipment Corporation. Personal information collected through the Learning Management System is limited to Crown employees to fulfill your request and the duties of their jobs. Crown will also share the personal information collected with your employer to confirm completion of training programs. Crown may also disclose your personal information if required to do so by law, if Crown believes in good faith such disclosure is required, or in urgent circumstances if Crown believes disclosure is necessary. Except as set forth in this Privacy Policy, Crown will not sell or share your personal information with third parties.

(f)        Storage of Information

Crown will store information you provide for the time necessary to respond to your request or otherwise in compliance with Crown’s retention policies. Crown takes precautions to safeguard your personal information against loss, theft, and misuse through administrative, technical, and physical measures. You may update or request that your information be removed at any time by emailing the Crown Privacy Office at privacyoffice@crown.com or by sending a letter to: Attn: Privacy Office, Crown Equipment Corporation, 44 South Washington St., New Bremen, OH 45869.

 (g)      Links to Other Sites

The learning.crown.com website may contain links to other sites, such as Crown dealers and affiliates. This Privacy Policy does not apply to such other sites. Crown is not responsible for the privacy practices of any such other sites. Please review the privacy policies of any sites you visit.

(h)       Consent

By using the learning.crown.com website, you consent to the collection and use of this information by Crown.

 (i)        Updates

Crown may update this Privacy Policy from time to time. If the policy is changed in a material way, a notice will be posted on the learning.crown.com website along with the updated Privacy Policy.

 

If there are any questions regarding the Policy, the way that Crown manages personal information, or if there are any concerns about Crown’s treatment of your personal information, then Crown may be contacted by post, telephone or email:

Crown Privacy Officer
No.9, Persiaran Pasak Bumi Section U8,
Bukit Jelutong, Selangor 40150
Telephone: (603) 5033 8500
Email: privacy.my@crown.com