Purpose of this policy
The following information is provided to you to inform you of Sodexo Malaysia Sdn. Bhd.’s (“Sodexo MY”) commitments when processing Personal data.
Sodexo MY builds strong, lasting relationships with its customers, partners, and consumers based on mutual trust, making sure that their Personal data is safe and remains confidential, which is an absolute priority for Sodexo MY.
Sodexo MY is committed to complying with all applicable regulatory and legal provisions governing the protection of Personal data.
Sodexo MY enforces a very strict privacy policy to guarantee the protection of the Personal data of those who use its websites, portals, applications, and platforms
Sodexo MY enforces a very strict privacy policy to guarantee the protection of the Personal data of the Users and the people with whom we are in contact:
- Users remain in control of their own data. The data is processed in a transparent, confidential, and secure manner.
- Sodexo MY is committed to a continuing engagement to protect its users’ Personal data in accordance with Personal Data Protection Act 2010.
- Sodexo MY has a data protection officer that you can contact in case you have a question.
Please read this policy carefully to familiarize yourself with the categories of Personal data that are subject to collection and Processing, how we use this Personal data, and with whom we are likely to share it. This policy also describes your rights and how you can get in touch with us to exercise these rights or to ask us any questions you might have concerning the protection of your Personal data.
This policy may be amended, supplemented, or updated, in particular to comply with any legal, regulatory, case law, or technical developments that may arise. However, your Personal data will always be processed in accordance with the policy in force at the time of the data collection, unless a compulsory legal requirement otherwise applies and is enforced retroactively.
Identity and contact details of the Controller
The Controller is:
Sodexo Malaysia Sdn. Bhd.
UOA Business Park
1, Jalan Pengaturcara U1/51A, Seksyen U1
40150 Shah Alam, Selangor, Malaysia.
Entity’s Registration Number: 198801001800 (169157-P)
Tel.: +603-5568 1100
Legal Representative: Abel Ariza
Email address of your DPO: dpo.sg.apac@sodexo.com
Definitions
“Controller”
Sodexo MY which determines the purposes and means of the Processing of your Personal data on the site.
“Personal data”
Any information relating to an identified natural person or one that can be directly or indirectly identified by reference to an identification number or to one or more elements specific to that person.
“Processing”
Any operation or set of operations that is performed on Personal data or on sets of Personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Processor”
Natural or legal person, public authority, agency or other body which processes Personal data on behalf of the Controller.
“us” “we” or “our”
Sodexo MY acting as Controller.
“you” or “Users”
Any site user/visitor or beneficiary of the services of Sodexo MY.
How will your Personal data be collected? Is it mandatory that you or others provide your Personal data?
We may collect your Personal data in the following ways below:
- Collection of your Personal data directly from you, such as when you complete forms on our sites or when we provide services directly to you ; and
- Collection of your Personal data indirectly during your navigation of the site or via our service providers and/or technologies.
- We will collect your Personal data on a mandatory basis where this is required by applicable local laws or where this is necessary for the performance of the services.
If we are unable to collect these mandatory Personal data items, we will not be able to manage your access to the site or to provide you our services.
For which purposes and on which legal basis will your Personal data be collected and processed? What Personal data does Sodexo MY hold?
We may process, use, and disclose your Personal data for certain purposes as detailed below (by no means is this list exhaustive). We will collect and process your Personal data where necessary to provide you an access to the site, or when it is necessary to comply with a legal obligation to which we are subject. We will also collect and process your Personal data for Sodexo MY’s legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms. Where legitimate interests do not apply as a lawful basis for the Processing of Personal data under the applicable data protection laws, prior explicit consent will be alternatively collected if required by law.
To whom will your Personal data be disclosed?
Sodexo MY is part of an international group (“Sodexo Group”) under the brand Sodexo.
There is a possibility that your Personal data will be transferred within or outside of the Sodexo Group.
- Within Sodexo
The security and confidentiality of your Personal data is of great importance to us. This is why we restrict access to your Personal data only to members of our staff only, to the extent it is strictly necessary to process your Personal data or to provide the services necessary for the site. We ensure that the persons authorized to process the Personal data have committed themselves to abide by confidentiality agreements or are under an appropriate statutory obligation of confidentiality.
We have also implemented appropriate safeguards to ensure an adequate level of protection of your Personal data, even if the Personal data is processed by another Sodexo entity that did not collect your Personal data originally.
Sodexo has implemented the Sodexo’s Binding Corporate Rules (BCRs) within Sodexo Group. Therefore, even if the third countries in which Sodexo entities operate are located outside of the European Economic Area, your Personal data is protected in the same way that they would have been by any entity located within the European Economic Area.
- Outside Sodexo
We will not disclose your Personal data to any unauthorized third party. We may, however, share your Personal data with authorized service providers (for example, technical service providers (hosting, maintenance), consultants, etc.) whom we may call upon for the purposes listed above in compliance with the applicable data protection laws.
All third-party service providers to whom we have disclosed and transferred your Personal data have been engaged under a binding confidentiality and data processing agreement with Sodexo MY or the Sodexo Group’s entities, whereby said third party may act only upon the instruction of Sodexo MY or Sodexo Group’s entities.
This third-party service provider and/or other contractors, as the case may be, may be located in countries where data protection laws may not provide a level of protection equivalent to your country. If Sodexo MY or Sodexo group’s entities disclose your Personal data to such recipients, we will establish and/or confirm that, prior to receiving any of your Personal data, they will provide an adequate level of protection for your Personal data, including appropriate technical and organizational security measures. In particular, if the recipients concerned are located in a country that does not provide an adequate level of protection, Sodexo MY or Sodexo group’s entities will also implement other appropriate measures, such as standard contractual clauses, to secure such transfer in compliance with applicable law. If you want to access a copy of the relevant documentation, please send an email to dpo.sg.apac@sodexo.com.
Furthermore, we may share your Personal data (i) if the law or a legal procedure requires us to do so, (ii) in response to a request by public authorities or other officials, or (iii) if we are of the opinion that transferring this data is necessary or appropriate to prevent any physical harm or financial loss, or in respect of an investigation concerning a suspected or proven unlawful activity.
How long will your Personal data be held?
We will store your Personal data only for as long as necessary to fulfill the purposes for which it was collected and processed, as described below. This period may be extended, if applicable, for any amount of time prescribed by any legal or regulatory provisions that may apply.
Finally, please note that we may anonymize your Personal data in such a way that you can no longer be identified and continue to use it for statistical purposes. Data used for statistical purposes is no longer classified as Personal data once it has been duly anonymized.
Sensitive Personal data
As a general rule, we do not collect sensitive Personal data via our site or to provide our services.
“Sensitive Personal data” refers to any information concerning a person’s racial or ethnic origins, political opinions, religious or philosophical beliefs, union membership, health data, or data relating to the sexual life or the sexual orientation of a natural person as well as biometric data (namely, personal data resulting from technical processing relating to the physical, physiological or behavioural characteristics of a person). This definition also includes Personal data relating to criminal convictions and offenses.
In the event that it would be strictly necessary to collect such data to achieve the purpose for which the Processing is performed, we will do so in accordance with local legal requirements for the protection of Personal data and, in particular, with your prior explicit consent.
Personal Information and Children
Our sites and services are provided for adults who have the capacity to conclude a contract under the applicable legislation of the country in which they are located. For the provision of the services, we might process Personal data of children, but it is always done with the consent of their legal guardian.
Your Privacy Rights
It is important that the Personal data we hold about you is accurate and up to date. Where applicable, please keep us informed of your Personal data changes by updating your account on the site.
Sodexo MY is committed to ensuring protection of your privacy rights under applicable laws. You will find below a table summarizing your privacy rights under the applicable data protection law, which applies to all Personal data processed on the site. 
To exercise these rights, you can:
- Use the online webform: This electronic system allows you to log in and see the progress of your request, see and send messages and review your documents securely. This system is provided by OneTrust and after making the request you will be sent details about how to log on.
- You can also raise queries or complaints with the Group Data Protection Officer, by email to dpo.sg.apac@sodexo.com or by post to 8-1, Level 8, Tower 2A, UOA Business Park, 1, Jalan Pengaturcara U1/51A, Seksyen U1, 40150 Shah Alam, Selangor, Malaysia.
No fee usually required:
You will not have to pay a fee to access your Personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal data is not disclosed to any person who has no right to receive it.
For more details, please consult the Data Protection Rights Management Policy (Malaysia).
Third party beneficiary rights
If applicable in your country, you can enforce the third-party beneficiary rights afforded to you by the Sodexo BCRs.
How will my Personal data be protected?
We implement all possible technical and organizational security measures to ensure security and confidentiality in Processing your Personal data.
To this end, we take all necessary precautions, given the nature of the Personal data and the risks related to its Processing, in order to maintain data security and, in particular, to prevent distortion, damage, or unauthorized third-party access (physical protection of the premises, authentication procedures with personal, secured access via identifiers and confidential passwords, a connection log, encryption of certain data, etc.).
In addition, if we contract with Processors for all or part of the Processing of your Personal data, we require a contractual agreement from our service providers to guarantee the security and confidentiality of the Personal data that we transmit to them or that they collect on our behalf, in accordance with the applicable regulations on the protection of Personal data.
We regularly conduct audits to verify the proper operational application of the rules relating to the security of your Personal data.
Nevertheless, you also have a responsibility to ensure the security and confidentiality of your Personal data so we invite you to remain vigilant, especially when using an open system such as the Internet.
Links to other sites/platforms
Occasionally, we provide links to other platforms for practical and informative purposes. These platforms operate independently from our sites and are not under our control. These platforms have their own privacy policies or terms of use, which we strongly advise you to read. We do not accept any liability with regards to the content on these platforms, for the products and services that may be offered there, or for any other use thereof.
Unsubscribing
If you have unsubscribed to certain services via our site and you no longer want to receive emails, please consult the “unsubscribe” page corresponding to the Service you are subscribed to.
How will you be notified if the uses of your Personal data change?
We may update or amend this policy as and when needed. In this case, amendments will only become applicable after a period of 30 business days from the date of the amendment. Please consult this page from time to time if you want to be informed of any possible changes.
If you have any questions or comments with regard to this policy, please do not hesitate to contact us at the following address: dpo.sg.apac@sodexo.com.
Latest update: 31st October 2024