Personal Data Protection Notice for Sunway Medical Centre Sdn Bhd

Sunway Group of Companies, including Sunway Berhad, Sunway Medical Centre Sdn Bhd, subsidiaries of Sunway Berhad, and Sunway Education Group Sdn Bhd (“Sunway”) respects and is committed to the protection of your personal information and your privacy. In this Personal Data Protection Notice, “we”, “us” and “our” refers to Sunway, and “you” and “your” includes third parties whose personal data you have provided to Sunway.

Your data user is Sunway Medical Centre Sdn Bhd. 

This Personal Data Protection Notice explains how we collect and handle your personal information, including your sensitive personal information in accordance with the Malaysian Personal Data Protection Act 2010. Please note that Sunway may amend this Personal Data Protection Notice at any time without prior notice and will publish the amended or revised Personal Data Protection Notice on our website or by email.

Note that your sensitive personal data (e.g. your physical or mental health or condition) and your medical information (e.g. patient medical history, diagnostics, allergies) will not be shared or disclosed to any entity unless where you have provided your express, written consent.

(1) Personal information

1.1 Type of personal information

Personal information means any information which relates to you or any other third party related to you which was collected or provided to Sunway for the purposes stated in Section 2 below.

We process your personally identifiable information which may include your name, NRIC number, contact details, financial and banking account details, medical history and information, information regarding your family, relatives or third party that you provide to us, your preferences in relation to products and services you purchase from us, CCTV/security recordings and location tracking/GPS information.

1.2 Source of personal information

(i) Patient or potential patient/customer, parent or guardian of patients or potential patients/customers: Sunway collects your personal information directly from you or indirectly from your legal representatives (family members, next of kin), agents (e.g. medical tourism agents) and/or employer when you, your legal representatives, agents and/or employers who send us completed enquiry, application and/or registration forms via various means, including online and physical hardcopies at public venues or in our premises. Your personal information may also be collected from cookies through the use of our website. 

(ii) Independent consultants or potential independent consultants: Sunway collects your personal information directly from you or indirectly from headhunters when you and/or our headhunters send us completed enquiry and/or application forms or curriculum vitaes via various means, including online and physical hardcopies. Your personal information may also be collected from cookies through the use of our website. 

(iii) Vendor, supplier or service provider: Sunway collects your personal information directly from you or indirectly from your employer or credit reference agencies when tendering for projects, when you send us completed enquiry and/or credit application forms via various means, including online and physical hardcopies. Your personal information may also be collected from cookies through the use of our website.

1.3 Obligatory personal information

All information requested for in the relevant forms is obligatory to be provided by you unless stated otherwise. Should you fail to provide the obligatory information, we would be unable to process your request and/or provide you with relevant services. 

(2) Purposes  of  collecting  and  further  processing  (including  disclosing)  your  personal information

For patients or potential patients/customers, parent or guardian of patients or potential patients/customers, independent consultants, potential independent consultants, vendors, suppliers or service providers: Your personal information is collected and further processed by Sunway as required or permitted by law and to give effect to your requested commercial transaction, including the following:

• to process your requested medical products and services; 
• to facilitate your participation in any contests or events;
• to administer and communicate with you in relation to our services and/or events;
• to facilitate your medical practice within Sunway, including sharing your personal data with other independent consultants within Sunway for purposes of peer review; 
• to administer and communicate with you in relation to your medical practice; 
• to process your credit account application; 
• to assess your credit worthiness; 
• to administer and give effect to your commercial transaction (tender award, contract for service, consignment agreement);
• to process any payments relevant to you;
• for insurance purposes; 
• to operate our premises in a manner which is physically safe, secure and befitting of health and safety requirements; 
• for internal investigations, audit or security purposes;
• to conduct internal statistical analysis and analysis of patient case studies; 
• to conduct and support internal marketing analysis and analysis of patient/customer patterns/habits, choices and engagement with Sunway’s related companies, subsidiaries, holding companies and affiliate companies; 
• to be collected and stored into a central repository that is accessible by Sunway related companies, subsidiaries, holding companies and affiliate companies; 
• to create and deliver personalized products and services that are unique to you to enhance your customer experience;
• to provide you a more seamless customer experience; 
• to support research and innovation of our products and services;
• to store and carry out data analytics processes; 
• to improve our products and services; 
• for matching of loyalty points provided by a third party/business partner to advertise and market products and services to you;
• for collaborations with a business partner to advertise and market products and services to you;
• to comply with Sunway’s legal and regulatory obligations in the conduct of its business; 
• to contact you regarding products, services, upcoming events, promotions, advertising, marketing and commercial materials which we may feel interest you; 
• to send you seasons greetings, special occasion messages or other similar communications; 
• to allow third parties to contact you for advertising, promotional or marketing campaign conducted by any third-party entities; 
• to ensure that the content from our website is presented in the most effective manner for your and for your computer and/or device;
• for Sunway’s internal records management. 

*Where you have indicated your consent to receiving marketing or promotional updates from Sunway,  you may opt-out from receiving such marketing or promotional material at any time. You may select the “unsubscribe” option provided in Sunway’s email blasts or you may contact Sunway at the details  provided in Section (6) below.

Data Analytics Processing

Sunway wants to share and consolidate your data into a single platform to be shared across the Sunway Group of Companies, including Sunway Berhad and Sunway Education Group Sdn Bhd. We  will use and share your data for analytics and measurement purposes to understand how our products and services are used, to help improve the products and services we offer, to provide you with more personalized products and services, and provide a more seamless customer experience. 
 
For example, we analyse data about your choice and preferences in relation to the products and services you purchase from us to send you targeted advertisements and promotional materials. We also process data about the ads you interact with to help us and advertisers understand the performance of various ad campaigns. 

(3) Disclosure of personal information

3.1 Entities within Sunway Group of Companies

Your personal information provided to us may be processed by and disclosed to entities (in or outside of Malaysia) within the Sunway Education Group and Sunway Group of Companies (including related companies, subsidiaries, holding companies, associated companies and outsourcing partners), for the purposes stated in Section 2 (Purposes of collecting and further processing (including disclosing) your personal information) above, especially when you are an employee of any company within the Sunway Education Group or Sunway Group of Companies. 

Sunway will ensure that: 

• Access to your personal information is restricted to staff who are contractually required to process your personal information in accordance with their respective job requirements. 

3.2 Classes of third parties

Your personal information may be disclosed to relevant third parties (in or outside of Malaysia) as required under law, pursuant to the relevant contractual or business relationships, our service providers or for the purposes stated in Section 2 Purposes of collecting and further processing (including disclosing) your personal information above (or directly related to those purposes).

3.3.Advertisers, business partners or other third-party entities 

Your personal information (including your sensitive personal data or non-sensitive personal data) may be disclosed or provided to advertisers, business partners or other third party entities and their advisers /representatives (in or outside of Malaysia) for purposes of any advertising, promotional or marketing campaigns conducted by any third party entities. 

In the event of a potential, proposed or actual sale of business, disposal, acquisition, merger or re-organisation (“Transaction”), your personal information may be required to be disclosed or transferred to a third party as a result of the Transaction. You hereby acknowledge that such disclosure and transfer may occur and permit Sunway to release your personal information to the other party and its advisers/representatives.

For patients or potential patients/customers, parent or guardian of patients or potential patients /customers, independent consultants, potential independent consultants, vendors, suppliers or service providers, your personal information may be disclosed to the following classes of third parties: 

• The Ministry of Health (“MOH”) or any other statutory or non-statutory authorities or bodies having authority or jurisdiction established by the MOH and other relevant government departments or agencies; 
• Relevant accreditation bodies such as the Malaysian Society for Quality in Health (MSQH);
• Our independent consultants and specialists within Sunway; Third party private  healthcare institutions or government healthcare institutions; 
• In the case of pre-employment health screenings, to the patient’s employer / prospective employer;
• Third parties appointed by us to provide services to us or on our behalf (such as  auditors, lawyers, company secretary, printing companies, consignment vendors, contractors, conference/event organisers, other advisers, and insurance companies);
• The respective foreign embassies of foreign patients who received treatment in  Sunway; and law enforcement agencies, including the local police. 

Transfer of your personal data outside Malaysia. It may be necessary for us to transfer your personal information outside of Malaysia if any of the third parties mentioned in section 3 (Disclosure of personal information) above including our service providers or business partners who are involved in providing any services to us are located or have processing facilities in countries outside of Malaysia.

You consent to us transferring your personal information outside Malaysia to such third parties and for the purposes set out in section 2 (Purposes of collecting and further processing (including disclosing) your personal information).  

We shall take necessary steps to ensure that any such third parties are contractually bound to protect your personal information and that they can only process your personal information under our instructions

(4) Websites

4.1 Links to other sites
Links to other sites is provided for your convenience and information. These sites may have their own privacy statement in place, which we recommend you review if you visit any linked websites. We are not responsible for the content on the linked sites or any use of the site. 

4.2 Location enabled products or applications
Location enabled products or applications transmit your location information to us. We do not use the information sent or provided other than to provide the service you request. Location enable 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 utilize Google Analytics (or similar tool) to help us better serve you through improved products, services, and revisions to the mobile applications. This collected information will not identify you to us. It may, however, let us know anonymously, which services and features you are using the most within the application, as well as device type and hardware features, country and language of download. 

4.3 Cookies
A cookie may be used in the processing of your information. A cookie is a text file placed into the memory of your computer and/or device by our computers. A copy of this text file is sent by your computer and/or device whenever it communicates with our server. We use cookies to identify you. We may also 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, your IP address: 

• the date and time you accessed each page on our web site; 
• (the URL of any webpage from which you accessed our site (the referrer); and
• the web browser that you are using and the pages you accessed. Some web pages may require you to provide a limited amount of personal information in order to enjoy certain services on our websites (system login credentials, email address and contact, etc). These personal information will only be used for its intended purposes only, i.e. to respond to your message or deliver the requested services.

(5) Right to access and correct personal information

You have the right to access and correct your personal information held by us (subject always to certain exemptions). We will make every endeavour to ensure your personal information is accurate and up to date therefore we ask that if there are changes to your information you should notify us directly. 

If you would like to access or correct your personal information, please contact Sunway Customer Service Centre or email your enquiry to the contact details in Item 6 below. 

(6) Limiting the processing of personal information, further enquiries and complaints

If: 

• you would like to obtain further information on how to limit the processing of your personal information; 
• you have any further query; or
• you would like to make a complaint in respect of your personal information, you may contact:

you may contact :-

For information of all other businesses, please submit your enquiry via Group Brand Marketing & Communications at https://www.sunway.com.my/contact-us/

(7) Conflict

In the event of any conflict between this English language Personal Data Protection Notice and its corresponding Bahasa Malaysia Personal Data Protection Notice, the terms in this English language shall prevail. 

This Personal Data Protection Notice was last updated on 24 March 2021.

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