Data Privacy Policy – Malaysia
Last updated December 2024
Milliman, Inc. and its affiliates ("Milliman" or "we") take data privacy very seriously. This Privacy Policy sets out the principles governing Milliman’s and its affiliate in Malaysia (Milliman Malaysia) collection, use, disclosure, transfer (“Processing”) and protection of Personal Data (as defined below) that website visitors, prospective clients, and clients residing within Malaysia (“you”) share with us. Milliman is committed to handling Personal Data in accordance with this Privacy Policy, Malaysia’s Personal Data Protection Act 2010 (PDPA), as amended by the Personal Data Protection (Amendment) Act 2024, and any other applicable data protection and privacy laws.
Milliman, Inc., and its affiliate Milliman advisors SDN BHD, are acting as Data Users (“Data Controllers”) in accordance with the PDPA with respect to the processing of Personal Data described in this Privacy Policy. This means that Milliman, Inc. and Milliman Malaysia are both responsible for compliance with applicable data protection laws.
Collection of Data
Aggregate Data
Like many companies, Milliman monitors the use of its websites by collecting aggregate data. No Personal Data is collected in this process. Typically, Milliman collects data about the number of visitors to the website, to each web page, and the originating domain name of the visitor's Internet Service Provider. This data is used to improve the usability, performance, and effectiveness of Milliman’s website.
Cookies, Third-Party Embedded Content and Do Not Track
For more detailed information describing how Milliman uses cookies and your choices surrounding the use and opt-out of such cookies, including information about third-party embedded content on Milliman’s website and how Milliman responds to Do Not Track signals in browsers, please review our Cookie Policy which can be found here.
Processing of Personal Data
In this Privacy Policy, “Personal Data” means information about a living individual in Malaysia from which the identity of the individual can be ascertained (including information which enables identification by easy reference to, or in combination with other information).
The Personal Data we collect varies depending upon the nature of the services provided and our interactions with you. In the context of the collection of Personal Data through this website, Milliman’s marketing activities and contract administration, we may collect, use, disclose, store, and otherwise process Personal Data of:
- Visitors to our websites (first name, last name, title, company, phone number, location, email address, subject of the request and message given) who request information about products or services from Milliman, for the purpose of the management of the relationship with clients and the administration of the website. Milliman will rely on your consent (Section 6(1) (a) of the PDPA) which you may provide to us via our “Contact us” section.
- Clients’ representatives, officers, agents, and employees, business partners, providers, parties to a contract (name, professional address, title, email, and other professional contact details) for contract administration purposes. The professional contact details of clients’ representatives, their employees, and business partners are also used to activate and maintain client accounts, to fulfill requests or respond to inquiries about Milliman products or services, and to provide offers and information (as permitted by law) about products, services, or events offered by Milliman or that Milliman thinks may be of interest. Milliman will process your Personal Data for the above purposes to fulfill contractual obligations with you (Section 6(2) (a) of the PDPA) or in absence of the above legal basis Milliman may rely on your consent. Furthermore, where permitted by applicable data protection and privacy laws, Milliman may also collect, use, disclose, store, or otherwise process (i) your Personal Data for sending marketing communications; and (ii) professional contact details of its clients’ employees for sending surveys, questionnaires, or organizing contests. Milliman may rely on your consent (Section 6(1)(a) of the PDPA) for the sending of marketing communications when so required by applicable data protection and privacy laws, in which case we will ask your consent prior to the sending of the communication. We may also collect and process limited Personal Data about you from public resources (such as LinkedIn) including your name/surname, email address, telephone number, organization, title/position, profession, and professional interests, to allow us to assess a potential interest in our services and to contact you for marketing purposes.
When we communicate with you regarding the products and services we offer or develop or any other marketing communications, you will be given the opportunity in each communication to unsubscribe and prevent future communications of that sort. If you do not want us to collect this information from our marketing emails, or if you wish to unsubscribe from direct marketing communications from us, you can reach out to us by filling out the data subject request form as available under the section “Rights”. We will cease using your Personal Data for direct marketing purposes once you have requested us to do so.
If you provide us with Personal Data of another individual, it is your duty to make sure that these individuals have consented to or are appropriately informed about the processing of their Personal Data by Milliman.
You should also ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
No automated decision-making is undertaken based on the Personal Data collected from you.
Affiliates and Authorized Third-Party Agents
All Milliman websites, products, and services are provided in cooperation with Milliman, Inc., located in the U.S. Any Personal Data may be shared between Milliman Malaysia and Milliman, Inc., or other entities controlled by or under common control with Milliman, Inc., for purposes of centralization of Milliman’s administrative, contract management, Client Relationship Management (CRM), IT maintenance, marketing, and IT security practices, for the purpose of the website’s management and security, and to provide information about Milliman products, services, or events.
We may also share Personal Data with affiliated entities using the MILLIMAN® mark, in which case we will require those affiliates to comply with this Privacy Policy. Please note that we may be transferring your Personal Data to a country that does not have the same data protection laws as your home country. However, Milliman ensures that itself and its affiliates will process Personal Data in compliance with this Privacy Policy.
Milliman also may share Personal Data with authorized third-party agents or contractors that perform services for Milliman. If Milliman shares Personal Data with a third party, Milliman requires that those third parties agree to process Personal Data based on Milliman’s instructions and in compliance with this Privacy Policy.
Any transfers of Personal Data are subject to appropriate safeguards using contractual or other means to provide a similarly adequate level of protection in compliance with the PDPA.
Other Disclosures
Milliman may also disclose Personal Data and other related information in response to subpoenas, court orders, or other lawful requests by public authorities, and to meet national security or law enforcement requirements. Milliman may collect and share Personal Data in order to investigate or take action regarding illegal activities, suspected fraud, violations of Milliman's Terms of Use, or as otherwise required by law or regulation.
Security
Milliman stores Personal Data on a secure server that is password protected and shielded from unauthorized access by a firewall. Milliman has in place security policies that are intended to ensure the security and integrity of all Personal Data. Milliman has appropriate technical and organisational measures in place to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data held or processed by Milliman. If Milliman forwards Personal Data to any third party, Milliman requires that those third parties have appropriate technical and organisational measures in place to comply with this Privacy Policy and applicable laws.
Data Retention
Milliman retains Personal Data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or not prohibited by law. Milliman will delete your Personal Data once the purpose of the collection and processing of such Personal Data has been fulfilled and the adequate duration for documentation and backup storage of such Personal Data has lapsed. If you have unsubscribed from receiving marketing information from us, we will continue to maintain your Personal Data for any other purpose for which we still have legal grounds for processing such Personal Data (such as for the purposes of complying with a legal obligation or when the processing is necessary for the purpose of our legitimate interest). In certain cases, if no other legal grounds exist, we will maintain limited Personal Data (such as your email address) about you on record, so as to be able to ensure for the future that such marketing communications are no longer sent to you.
Children
Milliman’s websites, products, and services are not directed to children, and Milliman does not knowingly collect Personal Data from children. If a parent or legal guardian becomes aware that his or her child has provided Milliman with Personal Data without their consent, the parent or legal guardian should contact us by filling out the data subject request form as available under the section “Rights”, and we will take steps to delete any such Personal Data.
Third-party Links
Milliman’s website may contain links to websites hosted and operated by companies other than us (“Third-Party Websites”) to which you can export (part of) your Personal Data.
We do not disclose your Personal Data to these Third-Party Websites without your explicit consent. Note that any information you disclose to Third-Party Websites is no longer under our control and no longer subject to this Data Privacy Policy.
You should review the privacy policy practices of any such Third-Party Website to understand how that Third-Party Website collects and uses your Personal Data should you have decided to disclose your Personal Data to them. We are not responsible for the content or performance of these Third-Party Websites. We are in no way responsible or liable for the manner in which a Third-Party Website treats any Personal Data that you choose to provide to such a Third-Party Website and use of Third-Party Websites is strictly at your own risk.
Policy Updates
Milliman may change its Privacy Policy from time to time. Milliman therefore asks all persons concerned to check it occasionally to ensure that they are aware of the most recent version.
Rights
Depending on the applicable law, you have a number of rights under the PDPA or such other applicable data protection and privacy laws in relation to your Personal Data, including:
- The right of access (Section 30 of the PDPA): You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to (including by obtaining a copy of) such Personal Data and the manner in which, and the purposes for which we process your Personal Data, so that you can verify its accuracy and the lawfulness of the processing.
- The right to rectification (Section 34 of the PDPA): You have the right to obtain from us the rectification of inaccurate Personal Data concerning you, and the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
- The right to erasure (Section 35 of the PDPA): You have the right to obtain from us the erasure of your Personal Data without undue delay where (a) your Personal Data is no longer necessary for the purpose for which it was collected/processed; (b) you wish to withdraw your consent to processing (except where we have another legal ground for the processing that we may rely on); (c) where processing is based on our legitimate interests and there are no overriding legitimate grounds for processing; (d) where your Personal Data has been unlawfully processed.
- The right to withdraw consent (Section 38 of the PDPA): You are entitled to withdraw your consent at any time if such processing is based on consent, provided that the withdrawal of such consent must not affect the lawfulness of any processing taken place prior to such withdrawal. Furthermore, you are also entitled to request us to refrain from further processing if such processing is based on the legitimate interest of Milliman.
- The right to restriction of processing ( Section 42 of the PDPA):You have the right to restrict Processing of your Personal Data where the processing of Personal Data is causing or is likely to cause substantial damage or substantial distress to him or to another person and the damage or distress is or would be unwarranted, However, this right will not applicable if the processing is carried out on the basis of your consent or where the processing necessary such as for performance of contractual obligations.
- The right to appeal (Section 42 of the PDPA): You have the right to appeal to the competent data protection authority in Malaysia as established under the PDPA.
You can exercise any of your rights as stated above, by filling out the data subject request form available here. For such requests, Milliman uses the Data Subject Access Request platform of the service provider One Trust. One Trust acts as Milliman’s data processor. We will endeavour to respond to any such request as soon as possible, and in any event within 21 days or as prescribed under the applicable laws. We will endeavour to respond to any such request as soon as possible, and in any event within the legal deadline.
How to Contact Us
If you have any questions, complaints, or feedback relating to your Personal Data or about this Privacy Policy, please contact us at [email protected].
Please note that if your Personal Data has been provided to us by a third party (e.g., your employer), you should contact that organization or individual to make such queries, complaints, and access and correction requests to Milliman on your behalf.
This Privacy Policy shall be governed in all respects by the laws of Malaysia.