PERSONAL DATA PRIVACY POLICY AND CONSENT
For Service Providers (“TITANS”) and Applicants (“TITANS Applicants”)
Pursuant to sections 7 and 6, respectively, of the Personal Data Protection Act 2010

Last Updated: 01 Sep 2023

1.  Collection of Personal Data

We, VIDOLA Titans Sdn. Bhd. (Company Registration No.: 202201045311 (1491009-K)) and each of our respective related corporations (as the term is defined in the Companies Act 2016), affiliates, and associated companies (hereinafter referred to as the “Company” “we” “our” or “us“) (whether or not controlled by us) respect your privacy and is committed to protecting your personal data. As such, we, as data users (as the term is defined in the Personal Data Protection Act 2010) have or will collect, record, hold, store, use, disclose and/or process (collectively referred to as “Process“) personal information about you in connection with your appointment as a TITAN or prospective appointment with us. In particular, we will Process some, one, or all of the following categories of personal information about you:

• master data: name, age, gender, date of birth, citizenship, marital status, nationality, race, ethnic origin, NRIC / passport details and education details and qualifications;

• contact details: home address, home phone number and mobile number and email address;

• emergency contact details: person and contact information to be contacted in case of an emergency, if provided by the TITAN;

• any such information as we deem necessary or appropriate from time to time in connection with your appointment and/or prospective appointment with us.

We may also Process some or all of the following types of sensitive information about you in connection with your exercise of appointment / prospective appointment with us:

• religious or similar beliefs;
• political opinions;
• health condition; and / or
• the commission of crimes, allegations thereof and / or convictions; (collectively together with (a)-(d) above, “Personal Data“).

To the extent that you disclose to us any personal information and/or personal data (whether or not coming within the definition of Personal Data above) of another individual, we shall assume, without independent verification, that you have obtained such individual’s consent for the disclosure of such information and / or personal data as well as the Processing of the same in accordance with the terms of this notification (“Notification“).

2. Sources of Information

Your Personal Data will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:

1. information provided or submitted by you in the TITANS Application Form(available on our website at https://www.vidolacorp.com), your resume or your curriculum vitae;


2. publicly available or publicly accessible information;


3. websites, telephonic communications, emails, facsimiles;


4. educational records and information provided by your previous educational institutions;


5. information provided by previous employer(s) through employee reference checks;


6. employment agencies (if applicable);


7. background checks;


8. professional and personal reference; and


9. such other written or verbal communications or documents delivered to us prior to and during the course of our contractual or pre-contractual dealings with you.

As the accuracy of your Personal Data depends largely on the information you provide to us, kindly inform us as soon as practicable if there are any errors in your Personal Data or if there have been changes to your Personal Data.

3.  Data Processing

In relation to TITANs of the Company, we will Process the Personal Data that you have provided to us for various purposes, including but not limited to:

1. improve and maintain the VIDOLA application to ensure a high quality of service provided to our customers;


2. assign and coordinate home maintenance service tasks, including scheduling appointments, allocating tasks based on your experience and expertise;


3. monitor and assess the quality of your services, ensuring that our customers receive reliable and proficient home maintenance assistance;


4. communicate with you in respect of service updates, client feedback and any changes to assignments (where necessary) to ensure clear and effective communication between us, you and our customers;


5. performance reviews, evaluations, trainings;


6. workplace safety (i.e., via CCTV recordings) and compliance with health and safety regulators;


7. record-keeping purposes, e.g., maintaining accurate and up-to-date records of your service history and customer feedback and ratings;


8. using your professional information (e.g., skills, certifications and qualifications) for marketing purposes;


9. protection of the Company, our employees or the public against injury, theft, legal liability, fraud, abuse, and other misconduct;


10. facilitate any dispute resolution between you and our customers in respect of the discharge of your services;


11. discharging obligations imposed on the Company under applicable law, regulations, guidelines and/or relevant regulatory authorities; and


12. such other purposes as we deem necessary or appropriate from time to time.

In relation to TITAN Applicants, we will Process your Personal Data with a view of assessing your suitability as a TITAN. This includes, amongst others, assessing your technical capabilities, job experience, physical and mental health as well as conducting background reference checks.

4. Disclosure and Processing

In general, we will not disclose your Personal Data to any third party unless you have notified us in writing that you consent to such disclosure. Therefore, if you envisage that any third parties (e.g., financial institutions) will be contacting us to request for your Personal Data, you should notify us in advance and provide your written consent for us to disclose your Personal Data.

Please note that it may be necessary for us to disclose your Personal Data:

1. where required by any regulatory authority of competent jurisdiction, such as the National Institute of Occupational Safety and Health, Department of Occupational Safety and Health, Inland Revenue Board, Department of Statistics Malaysia and other statutory bodies;


2. to JTS Checks Sdn. Bhd. (Company Registration No.: 201501032167 (1157487-M)) and any company appointed by the Company from time to time to conduct background checks;


3. to discharge any legal obligation imposed on us by law;


4. pursuant to an order of a court of competent jurisdiction;


5. to facilitate secure payment transactions for your services;


6. to ensure the smooth functioning of our platforms and systems (such as our website and/or the VIDOLA application);


7. to other third-party service providers that Process Personal Data on behalf of the Company and its affiliates;


8. in the event of a merger, acquisition or sale of our Company and business, your Personal Data may be disclosed to potential or actual buyers or sellers;


9. to our customers and clients to fulfill your contractual obligations of providing home maintenance services, including without limitation to your skills, experiences, expertise and qualifications;


10. to our partners and service providers for the purposes of training, development, TITANs payments system software maintenance, and various other HR-related purposes;


11. if we deem that such disclosure is necessary to prevent or mitigate a serious and imminent threat to your life or health or the life or health of another person.

We only process your Personal Data within Malaysia and your Personal Data will not be transferred to any place outside of Malaysia. Rest assured that if disclosure is necessary, we will only disclose the minimum amount of information which we deem necessary and will take all reasonable steps to ensure that such information is kept confidential. We will not sell, rent or trade your Personal Data.

5. Providing Personal Data

In relation to TITANs, in the event that you elect not to provide categories of Personal Data as listed in clause 1 above, this may adversely affect your ability to enjoy and/or participate in the full benefits and entitlements which we provide to our TITANs.

In relation to TITAN Applicants, if you elect not to provide categories of Personal Data as listed in clause 1 above, this may adversely affect our ability to assess your suitability as a TITAN and our ability to appoint you as our TITAN.

6. Retention of Personal Data

We will retain your Personal Data for the period necessary to fulfill the purposes set out in Clause (3) above in this Notification unless a longer retention period is required or allowed by law. Once you cease to be a TITAN or your Personal Data is no longer necessary for the purposes set out in Clause (3) or we no longer have a legal or business purpose for retaining your Personal Data, we shall take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Notification, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

7. Security Measures

We take your Personal Data very seriously and are committed to protecting your Personal Data. As such, to safeguard your Personal Data from any unauthorised access, collection, theft, use, disclosure or similar risks, we have introduced appropriate administrative, physical and technical measures such as authentication and access controls (such as good password practices, need-to basis for data disclosure for data disclosure, et cetera), encryption of data, data anonymisation, up-to-date antivirus protection, employing firewalls and intrusion detection systems, and conducting periodic assessments of our security measures to identify and address vulnerabilities.

Despite our best efforts, it is important to acknowledge that no security measures are completely secure. Whilst we take reasonable precautions to protect your Personal Data, we cannot guarantee the security of any Personal Data that you transmit to us or that we store. We are not responsible for the unauthorised use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity. We recommend you take steps to protect your own Personal Data, such as using strong and unique passwords, not sharing your login credentials, not recycling your passwords from other websites and being cautious when sharing personal information online.

8. Access to Personal Data, Limiting Processing and Variation

As a TITAN or prospective TITAN whose Personal Data is processed by us, you have the right to request access and/or to correct your Personal Data and/or limit the processing thereof at any time hereafter in line with applicable law and/or any applicable data protection law. We must point out that, in limiting the Processing as requested, the same consequences described in Clause (5) above could apply. If this is the case, we will inform you of the consequences in further detail depending on the specific Personal Data. You are also requested to correct and/or amend your Personal Data to the extent you realise it is incorrect. With respect to all of the above, you may:

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


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


3. 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; and


4. 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 as well as the consequences as mentioned above.

Please address all requests and/or questions and/or concerns which you may have regarding the subject matter and contents of this Notification to [Vidoly] from [Admin Executive]at [info@vidolacorp.com AND 012 9551829].

The Company reserves the right to update and amend this Notification from time to time and you will be notified of any material changes by way of a general notice (“General Notice”). You shall be deemed to have accepted the variation(s) to this Notification if we do not obtain a response from you within fourteen (14) days of our delivery of the (General Notice) to you.