This Policy, set forth below, is our privacy policy which describes how Kensington Trust Group collects, uses, and discloses certain personal information obtained through our public website at www.kensington-trust.com (“Website”) and other sources.For the purposes of this Policy, “Kensington Trust Group” shall include Kensington Trust Labuan Limited and Kensington Corporate Services (Malaysia) Sdn. Bhd. and their subsidiaries, associate companies and/or related companies as may be incorporated from time to time.


Source of your personal data
Registration is not required for you to use our Website. If you are merely a visitor, we do not collect any personal information about you. However, there may be circumstances in which you choose to register to receive ongoing updates from us or wish to send us an enquiry or feedback.

Your personal data may also be collected from various sources, including information you have provided us in our application form or other means, information from third parties, information in the public domain, social networks, in-person seminars and staff’s personal contacts. We may verify or source personal information about you from third party sources (both public and private) such as world check, credit bureaus or credit reference agencies, Registrar of Companies, Insolvency Department, legal representatives, industry / financial related associations and social networks.


Personal Data Processed by Us
This may include your name, occupation, identity card or passport number, race or ethnic origin, nationality, residential and business addresses, company’s name, telephone and fax numbers, email address, wealth information and any other personal data required for the purposes set out below. In some situation, we may request for a resume or curriculum vitae which include your work experience, academic qualification, professional membership and references.

We do not intentionally collect any sensitive personal data unless legally required to do so, for example recruitment purposes. Sensitive personal data includes but is not limited to personal data consisting of information as to physical or mental health, political opinions, religious or other beliefs of a similar nature and commission or alleged commission of any offence.

Such personal data will remain confidential. We will not share your information for commercial purposes with third parties unless you give us your prior permission to do so or such disclosure is within the ambit of permitted disclosures under the prevailing laws/guidelines. We will take such reasonable steps to protect the confidentiality of your information and to safeguard your privacy.


Information Use and Purpose
Kensington Trust Group collects, processes and retains your personal data that is necessary to perform its functions and activities which may include but not limited to the following:



If you receive a marketing e-mail from Kensington Trust Group, you will be provided with an automated way to opt out (unsubscribe) from that particular communication or from all marketing e-mails sent by us. Please follow the instructions on the e-mail you received.


Disclosure of Information
Kensington Trust Group may share your personal information among companies within the Kensington Trust Group, our Network, third party service providers, agents appointed by us to act on our behalf, banks or financial institutions or other third parties for the purposes set out above. We may also in limited circumstances disclose personal information to regulatory bodies, government agencies, the police, law enforcement bodies, courts and such persons or bodies to whom we are legally required to disclose including the Labuan Financial Services Authority or in relation to any order or judgment of a court. We may also disclose your personal information to our professional advisers and consultants including but not limited to lawyers, accountant, auditors and insurers on a need to know basis for the purposes of providing their services and/or advices to us.

All of these disclosures may involve the transfer of personal information to countries or regions without data protection rules similar to those in effect in your area of residence. By providing your personal information to us, you represent and warrant that you had or have consent to the disclosures described above or are otherwise entitled to provide the information to us.


Security Measures
Kensington Trust Group have in place reasonable commercial standards of technical and organizational security measures to protect the security of your personal information against destruction, misuse, unauthorized access, disclosure or alteration.


Links to Other Web Sites
The privacy practices set forth in this Policy are for our Website only. This Website may contain links to other sites. Kensington Trust Group is not responsible for the privacy practices or the content of such sites. If you link to or otherwise visit any other site, please review the privacy policies posted at that site.

 

Cookies and Passive Tracking
A “cookie” is an element of data that can be sent to your browser. Your browser may then store it on your system based on the preferences you have set on your browser. Cookies gather information about your operating system including, but not limited to, browser type, and Internet Protocol (IP) address. Kensington Trust Group Website uses this information to analyze the traffic on our Website, and better serve you when you return to our Website. It is not our intention to use such information to personally identify a user. You have the option to configure your Internet browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. Further, you have the option to block all cookies. Please note, however, that if you refuse or otherwise block cookies you may not be able to use all of the functionality available on our Website.
 

Social Media Platforms
You may wish to participate in the various blogs, forums, wikis and other social media platforms hosted by Kensington Trust Group (“Social Media Platforms") which we make available to you. The main aim of these Social Media Platforms is to facilitate and allow you to share content. However, we cannot be held responsible if you share personal information on Social Media Platforms that is subsequently used, misused or otherwise appropriated by another user.


Kensington Trust Group may also provide links to other social media platforms maintained on separate servers by individuals or organizations over which we has no control. We make no representations or warranties regarding the accuracy or any other aspect of the information located on such servers.

A link to a third party’s website should not be construed as an endorsement by either Kensington Trust Group or that third party of the other or its products and services. We make no representations or warranties regarding how user data is stored or used on third-party servers. We recommend you to review the privacy policy of each third-party site linked from our Website to determine their use of your personal data.


Access and Correction
You may contact us in writing using the contact details below to request for access to your personal data that we retain about you, request for access to your personal data retained by us to be corrected/updated and/or withdraw your consent to the processing/use of your personal data by us. If you wish to limit our right to process your personal data, please contact us at the contact details below. If you do not wish to receive future updates from us, you may unsubscribe it at any time.

You have the right in deciding the information you wish to provide. However, there may be circumstances where it is obligatory to provide certain personal data. Failure or refusal to provide the relevant personal data or wish to limit the processing of your personal data may render us unable to provide the services requested by you or your organisation or carry out the purposes set out below. Also, the extent in which we can comply with your request without affecting our mutual rights and obligations in relation to the transaction, depend on the stage of the transaction. If such rights or obligations are impacted for, we may not be able to stop processing your personal data.


Retention
Kensington Trust Group will keep your personal data for the duration of time necessary to carry out the purpose for which your personal data was collected and also for the other purposes set out in this Policy, including handling enquiries, audit, complaints or legal proceedings and marketing purposes. We will also abide by legal, tax and other regulatory and industry requirements/guidelines for keeping records including our retention of record policy.


Consent
If you are a firm, partnership, joint venture, unincorporated body, corporation or other body corporate, the giving of this Notice addressed to such firm, partnership, joint venture, unincorporated body, corporation or other body corporate shall be deemed as notice given to all your partners, directors, office-bearers, shareholders and/or employees, as the case may be, whose data are collected and/or processed by us for the purposes as stated above. In this regard, you warrant that you have obtained the consent of all such individuals to the provision of their personal data to us for the purposes set out above and for disclosure to such parties as set out above and you undertake to notify all such individuals, (which expression shall include all such existing and new partners, directors, office-bearers, shareholders and/or employees, as the case may be, from time to time) of this Policy.

This Policy shall also apply to the usage, processing and disclosure of the personal data of any other individual who is not our client but whose personal data is required to be collected by us for the purposes or incidental to the provision of services and solutions by us to our clients, whether the client concerned is another individual, company, business entity or organisation. In this regard, you confirm and warrant that you have obtained the consent of such individuals to the provision of such personal data to us for the purposes set out above and for disclosure to such parties as stipulated above and you undertake to notify such individuals of this Policy.

By providing your personal data to us and/or continuing to use our services, you are deemed to consent to the statements and terms in this Policy and the collection, use, access, disclosure, storage and processing of personal data as described in this Policy.


Changes to our Policy
Kensington Trust Group may modify or amend this Policy from time to time at our discretion. Please check this page periodically to be informed about how we are protecting your information. We also display the effective date of this Policy at the bottom of this page.


Questions or Comments
If you have any inquiries, complaints or concerns regarding your privacy or if you need assistance accessing, correcting or updating your personal information, please contact:

Ms Emily Liew
Kensington Gardens,
No. U1317, Lot 7616,
Jalan Jumidar Buyong,
87000 Labuan F.T.,
Malaysia

Tel: +60(87) 411 929
email: info@kensington-trust.com


Kensington Trust Group
10 February 2014


IMPORTANT: By providing your personal data to us and/or continuing to use our services, you are deemed to consent to the statements and terms in this Policy and the collection, use, access, disclosure, storage and processing of personal data as described in this Policy.