Privacy and Policy

1. General

This Privacy Notice describes how SD Guthrie ELAEIS GARDENS Sdn Bhd (referred to as "we," "us," or "our"), operating ELAEIS GARDENS / SD Guthrie ELAEIS GARDENS website at https://www.elaeisgardens.com/ ("Website"), collects, uses, maintains and discloses your Personal Data when you visit our Website, engage with our marketing, or use our services related to accommodation, golf, educational visits, and events in accordance with the legal and regulatory requirements.

Please ensure that you have read and understood this Privacy Notice before accessing our website or providing your personal data to us.

We are committed to protecting your privacy and handling your Personal Data in a transparent manner, in compliance with the Personal Data Protection Act 2010 (“PDPA”) of Malaysia and any other applicable data privacy laws.

2. Information Collection and Categories of Personal Data

Information Collection

We may collect information from you when you access our website, in our existing guest lists, business cards, guest books, and/or any events organised by us, as well as from various other sources, such as our customers, their counterparties and representatives, regulatory authorities, government agencies, and credit reporting agencies.

Categories of Personal Data

The categories of personal data we may collect from you including, but not limited to, your name, identification number (IC), passport number, correspondence address, nationality, telephone number, email address, and location. The aforesaid personal data is not exhaustive and may include other personal data depending on the nature of the business relationship, dealings or transactions between you and us.

Where we collect personal data, we will only do so for purposes of fulfilment of one (1) or more Purposes set out in Purposes and Lawful Basis for Processing of Personal Data Section below. Your refusal to provide us with such personal data may result in us not being able to process and/or disclose your personal data for the Purposes (as defined below).

3. Purposes and Lawful Basis for Processing of Personal Data

Purposes

B. Data We Collect Automatically (Digital Tracking)

The purposes of which your personal data will be collected and processed by us, include, but not limited to the following:

to enable us to provide services to you or vice versa;
to process and manage your bookings;
to carry out background check and Know Your Counterparty (KYC) screening activities, wherever required;
to send you festive messages, promotional messages and special offers;
for purposes of entering into a business relationship with you;
for internal record keeping;
to defend a claim or suit against us in a legal proceeding or potential legal proceeding;
for security and fraud prevention purposes;
for the purposes of statistical analysis of data;
for marketing activities;
for visit to our premises where your image may be captured and recorded via CCTV to ensure safety within premises;
for all other purposes required or permitted by legislative, statutory and regulatory requirements (collectively, “the Purposes”).

Lawful Bases

If you are a citizen or resident in the European Economic Area ("EEA") or the United Kingdom ("UK"), we have set out additional information required by the European Union (“EU”) and UK data protection laws to explain on the “lawful bases” for processing of your personal data.

If you are not a citizen or resident in the EEA or UK, in the case where you provide us with your personal data, you agree and consent to our collection, use and disclosure of your personal data for the purposes set out in this Privacy Notice, where applicable.

In our dealings or interaction with you, we rely on various lawful bases for purposes of processing of your personal data. Please refer to the table below:

We use the collected data for the following purposes:

Processing Activity (Purpose of Processing of Your Personal Data)	Lawful Bases
to enable us to provide services to you or vice versa	contract performance legitimate interest (to enable effective communications and fulfilment of obligations)
to process and manage your bookings	contract performance legitimate interest (to enable effective communications and fulfilment of obligations)
to carry out background check and Know Your Counterparty (KYC) screening activities, where required	legal obligations
to send you festive messages, promotional messages and special offers	consent legitimate interest (to maintain good relationship and keep you updated for news in relation to our latest products or services)
for purposes of entering into a business relationship with you	contract legitimate interest (to enable effective communications with you in relation to the products or services, and to manage our relationship with you)
for internal record keeping	legal obligations (statutory retention period, for example, for employee records and tax records)
to defend a claim or suit against us in a legal proceeding or potential legal proceeding	legal obligations
for security and fraud prevention purposes	llegal obligations
for the purposes of statistical analysis of data	legitimate interest (for running of business, provision of administration and IT services)
for marketing purposes	legitimate interest (to allow us to keep you updated on news of our latest products)
for visit to our premises where your image may be captured and recorded via CCTV to ensure safety within premises	legal obligations (to ensure safety of office or premises legitimate interest (to ensure our visitors are safe)
for all other purposes required or permitted by legislative, statutory and regulatory requirements	legal obligations

4. Direct Marketing Purposes

We may periodically send you newsletters, surveys, offers, and other promotional materials regarding our products and services which we believe that are of interest or useful to you, if you have consented (opted-in) to receive such messages via e-mail or any other electronic channel (where such opt-in is required under your local law).

If you do not wish to receive such communications anymore, you can "opt out" by following the unsubscribe instructions provided in each of our direct marketing e-mails or by contacting us directly (please see Contact Us under Section 13 below). We will then record any objection you make and stop sending promotional communications to you.

5. Digital Tracking

When you browse our website, we automatically collect certain information about your device and browsing activity.

Category of Data	Purpose of Collection
Usage Data	IP address, browser type, operating system, pages viewed, time spent on pages, referral source.
Tracking Data	Cookies, tracking pixels, and similar technologies. We use these to enhance your experience, analyse site usage, and support our advertising efforts.
Call Conversion Data	Google Ads Tracking: When you click on one of our Google Ads and call the phone number displayed on our website, we use a Google Forwarding Number (GFN) for dynamic number insertion (DNI). This allows us to track the call duration, time, and which ad/keyword generated the call for conversion reporting. We do not record the conversation itself through this process.

We do not process your personal data via automated decision-making.

6. How We Share and Disclose Your Information

Please be informed that your personal data may be disclosed, disseminated and/or transferred to other companies within our group (including the holding company, subsidiaries, associated, related and affiliated companies as well as their subsidiaries, associated and affiliated companies, both local and international), whether present or future, or to any third party organisations or persons for the purpose of fulfilling our obligations to you in respect of the Purposes and all such other purposes that are related to the Purposes and also in providing integrated services, maintaining and storing records.

Third parties which we believe would need to have access to your information to provide you with the information or services you request from us such as: Service Providers: We share data with vendors who perform services on our behalf, such as web hosting, data analytics (e.g., Google Analytics), marketing and advertising platforms (e.g., Google Ads), and payment processors for booking services.
Affiliates: We may share data within SD Guthrie Berhad group for internal business purposes, such as customer support and technical development.
Legal & Compliance: If required by law, court order, or governmental regulation, or to protect our rights or the safety of others.

7. Third-Party Tracking and Online Advertising (Cookies)

We use cookies and similar technologies for analytics and to run targeted online advertisements.

Google Ads Call Conversion Tracking: As discussed, we use DNI and GFNs to measure the effectiveness of our paid advertisements.
Google Analytics: We use this service to analyse visitor behaviour and understand traffic sources. Google's use of data is governed by the Google Privacy Policy.

You have the right to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of the Website.

8. Security of Your Personal Data and Data Retention

We have put in place a variety of technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing.

We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including for the purpose of satisfying any legal, accounting, or reporting requirements.

9. Your Rights

Your rights to your personal data are as follows:

Right to Access: Request access to your Personal Data.
Right to Correction: Request the correction of your inaccurate or incomplete Personal Data .
Right to Withdraw Consent: Withdraw your consent for us to process your Personal Data, subject to any applicable legal restrictions or contractual conditions.
Right to Erasure: Request to delete personal data that we hold about you.
Right to Object: To object our processing of your personal data (including for direct marketing purposes); and
Right to Portability: To request for transfer of your personal data to you or another entity.

To exercise these rights, you may contact us via the communications channels set out in Section 13.

10. Personal Data of Minors and Other Individuals

Where you have shared or provided us with personal data of any of your family members, spouse, dependent and/or other individuals, you confirm that you have obtained consent from the relevant person for the processing of their personal data in accordance with this Privacy Notice.

In the case where you share or provide us with personal data of minors, you confirm that you have the right to act and consent on their behalf for processing of their personal data in accordance with this Privacy Notice.

Complaint

Where you believe that infringement or misuse of your personal data has occurred, you have the right to lodge a complaint with the data protection authority. However, we would encourage you to contact us before making such complaint to the relevant data protection authority so that we are first given the opportunity to understand and resolve your concerns.

Changes to This Privacy Notice

We may update, revise, vary, amend and/or modify this Privacy Notice from time to time. We encourage you to review this Privacy Notice periodically.

Contact Us

If you have any questions, comments or requests about this Privacy Notice or our data handling practices, please contact us:

Contact Person: Ezzaruddin Abdul Rapar, Manager

Company Name: SD Guthrie ELAEIS GARDENS Sdn Bhd

Email Address: ecogardens@sdguthrie.com

Phone Number: Office: 03-33266222 Business Line: 019-6277258 Fax: 03-3326 6200

Address: SD Guthrie Elaeis Gardens Sdn. Bhd. (21025-P) Golden Hope Academy 42960 Pulau Carey, Selangor

For Malaysia only

Data Protection Officer: Adeline Amanda Jaiyaseelan, Head, Industrial Relations & Compliance

Company Name: SD Guthrie Berhad, Level 10, SD Guthrie Tower, No. 2 Jalan PJU 1A/7, Ara Damansara, 47301 Petaling Jaya, Selangor.

Email Address: DPO@sdguthrie.com

Language

In the event of any inconsistencies between the English version and the Bahasa Malaysia version of this Privacy Notice, the English version shall prevail.