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A Learning Community that Empowers Students to Achieve their Academic and Life Potential.

Personal Data Protection Notice and Privacy Policy

Raffles American School is committed to the protection of personal data and privacy. In line with
Personal Data Protection Act 2010 in Malaysia, this Personal Data Protection Notice and Privacy Policy
explains how we collect and handle personal data. Please note that Raffles American School may amend
this Personal Data Protection Notice and Privacy Policy at any time without prior notice and will
communicate such amendment via our website or by email.

A. Personal data 
1 Type of personal data

Personal data means any information which was collected or provided to Raffles American School for
the purposes stated in this policy.
Personal data may include but not limited to name, contact details, religious belief, medical details,
previous examination results, academic records, information in audio and/or video format (including
voice, video recording, closed-circuit television (“CCTV”) and security recording), images (including
photographs) and location tracking / GPS information.

2 Source of personal data
(i) Student or potential student:
Raffles American School collects personal data directly or indirectly from students, parents, guardians
and / or recruitment agents when students, parents, guardians and / or recruitment agents submit
completed enquiry, application and / or registration forms via various means, including online and
physical hardcopies at public venues, seminars held at schools and / or when students, parents /
guardians and / or recruitment agents visit the school. Personal data may also be collected from
cookies through the use of RAS website.

(ii) Parent / guardian of the student or potential student:
Raffles American School collects personal data directly or indirectly from the child / ward,
recruitment agents when completed enquiry, application and / or registration forms are submitted
via various means, including online and physical hardcopies at public venues, seminars held at
schools and / or when the parent/ guardian, child / ward and / or recruitment agents visit the school.
Personal data may also be collected from cookies through the use of RAS website.

(iii) Client / customer or potential client / customer for RAS products, services, events, conferences,
seminars and / or other marketing activities organised:
Raffles American School collects personal data directly upon the receipt of an interest to be
contacted for such events and marketing activities (including business card collections via fish bowl
method or during previous events organised). Information may also be collected indirectly (for
example, via online directories) or from cookies through the use of RAS website.

(iv) Vendor, supplier or service provider:

Raffles American School collects personal data directly or indirectly from the provider or employer or
credit reference agencies when tendering for projects or as part of the commercial transactions.
Personal data may also be collected from cookies through the use of RAS website.
3 Provision of information

All information requested in the relevant forms is mandatory to be provided unless stated
otherwise. Failing which, we may be unable to process the request and / or provide the relevant
services.

B. Purposes of collecting and processing (including disclosing) personal data
(i) Student or potential student:

Personal data is collected and processed by Raffles American School as required or permitted by law
and for various academic, educational and administrative purposes, including but not limited to:
 to process an application for admission and thereafter to ensure continuous provision of
academic and educational services (including recording the details of studies) and
determining academic achievements;
 to provide ancillary services such as visa application and insurance coverage;
 to administer and communicate tuition fees and other relevant payments;
 to manage the use of school facilities and management of events such as libraries, boarding,
IT facilities, graduations;
 to operate the school in a manner which is physically safe, secure and befitting of health and
safety requirements;
 to conduct internal marketing analysis and analysis of student pattern and choice;
 to comply with Raffles American School’s legal and regulatory obligations in the conduct of
its business;
 to advise products, services, upcoming events, promotions, advertising, marketing and
commercial materials*;
 to ensure that the content from RAS website is presented in the most effective manner; and
 for Raffles American School internal records management.
In particular, religious belief is processed for reporting purposes to the Ministry of Education and any
other relevant authorities. Medical details are processed to assist the students’ studies at Raffles
American School.

(ii) Parent / guardian of student or potential student:
Personal data is collected and processed by Raffles American School as required or permitted by law
and for various academic, educational and administrative purposes, including but not limited to:
 to process the student’s application for admission;
 as an emergency contact;
 to update the progress of the students, tuitions fees and other relevant payments;
 to provide ancillary services to the students such as visa application and insurance coverage;
 to conduct internal marketing analysis and analysis of student pattern and choice;
 to comply with Raffles American School’s legal and regulatory obligations in the conduct of
its business;
 to advise products, services, upcoming events, promotions, advertising, marketing and
commercial materials*;
 to ensure that the content from RAS website is presented in the most effective manner; and
 for Raffles American School internal records management.

(iii) Client / customer or potential client / customer for products, services, events, conferences, seminars
and other marketing activities:
Personal data is collected and processed by Raffles American School as required or permitted by law
and commercial purposes including but not limited to:
 to provide information, products or services that requested from RAS and any incidental
purposes thereto;
 to advise products, services, upcoming events, promotions, advertising, marketing and
commercial materials*;
 to improve the products or services offered by Raffles American School;
 to conduct internal marketing analysis and analysis of consumer pattern and choice;
 to notify about changes to RAS products and services;
 to ensure that the content from RAS website is presented in the most effective manner;
 to comply with Raffles American School’s legal and regulatory obligations in the conduct of
its business; and
 for Raffles American School internal records management.
(iv) Vendor, supplier or service provider:
Personal data is collected and processed by Raffles American School as required or permitted by law
and to give effect to the requested commercial transaction, including but not limited to:
 to administer and give effect to the commercial transaction;
 to process any payments related to the commercial transaction;

 for internal investigations, audit or security purposes;
 to comply with Raffles American School’s legal and regulatory obligations in the conduct of
its business;
 to advise product, services, upcoming events, promotions, advertising, marketing and
commercial materials*;
 to ensure that the content from RAS website is presented in the most effective manner; and
 for Raffles American School’s internal records management.
* Where such consent has been given to Raffles American School. Please contact Raffles American School
to opt-out from receiving such marketing or promotional material at any time.

C. Disclosures and transfers of personal data (within or outside of Malaysia)
1 Entities within Raffles American School and Raffles Education Corporation
Personal data provided to us is processed by entities (within or outside of Malaysia) within Raffles
American School and Raffles Education Coporation (including related companies, subsidiaries,
holding companies, associated companies and outsourcing partners).

Raffles American School will ensure that:
(i) access to personal data is restricted to staff who are contractually required to process such personal
data in accordance with their respective job requirements; and
(ii) only necessary information is released to the relevant employees.

2 Classes of third parties
Personal data may be disclosed or transferred to relevant third parties (within or outside of Malaysia)
as required under law, pursuant to relevant contractual relationship (such as third party service
providers) or for the purposes stated in this policy or directly related to those purposes.
In the event of a potential, proposed or actual sale of business, disposal, acquisition, merger or re-
organisation (“Transaction”), personal data may be required to be disclosed or transferred to a third
party as a result of the Transaction. You hereby acknowledge that such disclosure and transfer may
occur and permit Raffles American School to release the personal data to the other party and its
advisers / representatives.

(i) Student or potential student:
Personal data may be disclosed to the following classes of third parties including but not limited to:
 The Ministry of Education, other relevant government departments / agencies, statutory

authorities and industry regulators;
 Any person to whom we are compelled or required to do so under law or in response to a
competent or government agency;

 Foreign government departments, government agencies or authorities in a foreign
accredited programme;
 Malaysian immigration department (including agencies appointed by Malaysian immigration
department to carry out its services) to obtain or renew tudent visa for the tenure of studies
with Raffles American School;
 Foreign embassies (including agencies appointed by foreign embassies to carry out their
services) if Raffles American School assists in visa application as part of a transfer procedure;
 Parents / guardians;
 Our external counterparts providing external, twinning or other similar educational
programmes ;
 Third parties providing attachment placements or internships;
 Relevant professional or statutory regulatory bodies or accreditation bodies;
 Law enforcement agencies; and
 Third parties appointed by us to provide services to us or on our behalf (such as auditors,
lawyers, company secretary, printing companies, telecommunications companies,
contractors, conference / training / event organiser, other advisers, travel agencies,
recruitment agencies and insurance companies).

(ii) Parent/guardian of student or potential student:
Personal data may be disclosed to third parties including but not limited to:
 The Ministry of Education, other relevant government departments / agencies, statutory

authorities and industry regulators;
 Any person to whom we are compelled or required to do so under law or in response to a
competent or government agency;
 Foreign government departments, government agencies or authorities in a foreign
accredited programme;
 Malaysian immigration department (including agencies appointed by Malaysian immigration
department to carry out its services) if the student is required to obtain or renew his / her
student visa for his / her tenure of studies with Raffles American School;
 Foreign embassies (including agencies appointed by foreign embassies to carry out their
services) if Raffles American School assists the student in his / her visa application as part of
his/her transfer procedure;
 Our external counterparts providing external, twinning or other similar educational

programmes;
 Law enforcement agencies; and
 Third parties appointed by us to provide services to us or on our behalf (such as auditors,
lawyers, company secretary, printing companies, telecommunications companies,
contractors, conference / training / event organiser, other advisers travel agencies,
recruitment agencies and insurance companies).

(iii) Client / customer or potential client / customer for products, services, events, conferences, seminars
and other marketing activities organised by RAS:
Personal data may be disclosed to the classes of third parties including but not limited to:
 Third parties appointed by us to provide services to us or on our behalf (such as auditors,
lawyers, company secretary, printing companies, contractors, conference / training / event
organiser and other advisers);
 Law enforcement agencies;
 Government departments / agencies, statutory authorities and industry regulators; and
 Any person to whom we are compelled or required to do so under law or in response to a
competent or government agency.
(iv) Vendor, supplier, tenant or service provider:
Personal data may be disclosed to the classes of third parties including but not limited to:

 Third parties appointed by us to provide services to us or on our behalf (such as auditors,
lawyers, company secretary, printing companies, contractors, conference / training / event
organiser, other advisers);
 Law enforcement agencies;
 Government departments / agencies, statutory authorities and industry regulators; and
 Any person to whom we are compelled or required to do so under law or in response to a
competent or government agency.

D. Websites
1 Links to other sites

Links to other sites are provided for convenience and information. These sites may have their own
privacy statements in place, which we recommend you to review if you visit any linked websites.
Raffles American School shall not be responsible for the content or any use of the linked websites.
2 Location enabled products or applications
Location enabled products or applications transmit user location information to us. We do not use

the information sent or provided other than to provide the service requested. Location enabled
features are opt-in and users have control over such participation and can turn these services off at
any time or uninstall them.
Some mobile applications will utilize Google Analytics (or similar tool) to help us better serve
customers through improved products, services, and revisions to the mobile applications. This
collected information will not identify users to us. It may, however, let us know anonymously, which
services and features used the most within the application, as well as device type and hardware
features, country and language of download.
3 Cookies

A cookie may be used in the processing of information. A cookie is a text file placed into the memory
of a user’s computer and / or device by our computers. A copy of this text file is sent by user
computer and / or device whenever it communicates with our server. We use cookies for
identification. We may also collect the following information during visits to our website and/or the
fully qualified domain name from user access, or alternatively IP address:
(i) the date and time of access on each page on our web site;
(ii) the URL of any webpage accessed to our site (the referrer); and
(iii) the web browser used and the pages accessed.
Some web pages may require user to provide a limited amount of personal data in order to enjoy certain
services on our websites (system login credentials, email address and contact, etc). This personal data
will only be used for its intended purposes only, i.e. to respond to a message or deliver the requested
services.

E. Right to access and correct personal data/ Limiting the processing of personal data, further
enquiries and complaints

You have the right to access and correct your personal data held by us (subject always to certain
exceptions under the law). We will make every endeavour to ensure your personal data is accurate
and up to date therefore we ask that if there are changes to your information you should notify us
directly.
If you would like to access your personal data, obtain further information on how to limit the
processing of your personal data or make a complaint in respect of your personal data or any other
query, please contact Raffles American School at:
Tel : : +6 07 5098750
Email : inquiry@rasraptors.com
The English version of this Personal Data Protection Notice and Privacy Policy shall prevail in the event of
any conflict with the Bahasa Malaysia version.

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