The Company views your personal data and privacy seriously. This Notice is issued pursuant to the requirements of the Personal Data Protection Act 2010.

Individuals may have supplied and may continue from time to time, supply FSCL with their personal data and information (“data”) in connection with the services/business or compliance with any laws, guidelines or requests issued by regulatory or other authorities. The Company may also verify or source personal information about you from third party sources (both public and private) such as Companies Commission and Insolvency Department. Your visit to our public website may be recorded for analysis on the number of visitors to the site and general usage patterns. Some of this information will be gathered through the use of “cookies”.

Such data may include information concerning your personal details (such as name, age, gender, identity card number, passport number, date of birth, education, race, ethnic origin, nationality, citizenship), contact details (such as address, email, phone numbers), family information (such as marital status, name of spouse or child or immediate family), occupation details (such as employer name, income range, job title, job responsibilities and employer’s contact information and address. In addition, the Company may from time to time request for certain other personal information that may be relevant for the Company in conducting its money services business as required by the regulator.

Failure to supply such data may result in the Company being unable to establish, continue or provide the money services business, services or facilities or comply with any laws or guidelines issued by regulatory or other authorities.

It is also the case that data are collected from:

1. customers and other sources in the ordinary course of the continuation of the business/services;

2. a person acting on behalf of the individual whose data are provided; and

3. other sources (for example, information obtained from any bureaus or agencies established or to be established by Bank Negara Malaysia or Labuan Financial Services Authority and any of its subsidiaries, or by any other authorities.

The purposes for which data may be used and/or processed are as follows:

1. Applications and the processing of applications for investment;

2. Updating customers’ records;

3. Designing financial services or related products for customers’ use;

4. Marketing services of the Company including but not limited to:

5. Financial services; and

6. Reward, loyalty or privileges programmes and related services.

7. For fraud or crime prevention, audit and in order that services may be processed by the Company;

8. For investigating, reporting, preventing or otherwise in relation to breach of financial services/business secrecy/confidential information, fraud, money laundering, terrorist financing and criminal activities generally;

9. Meeting obligations, requirements or arrangements, whether compulsory or voluntary, of the Company or any of its branches to comply with, or in connection with;

   1. any law, regulation, judgment, court order, voluntary code, sanctions regime, within or outside Malaysia existing currently and in the future (“Laws”);

   2. any guidelines, guidance or requests given or issued by  any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Malaysia existing currently and in the future and any international guidance, internal policies or procedures;

   3. any present or future contractual or other commitment with local or foreign legal, regulatory, judicial, administrative, public or law enforcement body, or governmental, tax, revenue, monetary, securities or futures exchange, court, central Company or other authorities, or self-regulatory or industry bodies or associations of financial service providers or any of their agents with jurisdiction over all or any part of the Company (together the “Authorities” and each an “Authority”) that is assumed by, imposed on or applicable to the Company or any of its branches; or

   4. any agreement or treaty between Authorities;

10. Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Company and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;

11. Conducting any action to meet obligations of the Company to comply with Laws or international guidance or regulatory requests relating to or in connection with the detection, investigation and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/or any acts or attempts to circumvent or violate any Laws relating to these matters;

12. Meeting any obligations of the Company to comply with any demand or request from the Authorities;

13. Enabling an actual or proposed assignee of the Company, or participant or sub-participant of the Company’s rights in respect of the customer to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation;

14. Market research and statistical analysis and surveys with the aim of improving our products and services;

15. For any purpose required by law or regulation;

16. For the purpose of enforcing its legal rights and/or obtaining legal advice;

17. To support the Company’s business, financial and risk monitoring, planning and decision making;

18. For making enquiries or investigations as to whether or not the customer or person whose data is collected, used and/or processed by the Company is actually a sanctioned person, or is otherwise howsoever related to, or associated with, a sanctioned person or entity; and also for the reporting or the taking of any remedial or preventive action in relation thereto;

19. For all ancillary purposes relating to the provision of facilities including the provision of computer, telecommunications and technology services;

20. For internal operational requirements of the Company (including, without limitation, risk management, system or product development and planning, audit and administrative purposes); and/or

21. Purposes relating thereto.

Data held by the Company will be kept confidential but the Company may provide or disclose such information to the following parties (whether within or outside Malaysia) for the purposes set out in Paragraph 6 (who may also subsequently process, transfer and disclose such data for the purposes set out in Paragraph 6):

1. Any FSCL offices;

2. Any agent, contractor, sub-contractors, service providers, lawyers, auctioneers, valuers or associates of the Company (including their employees, directors, officers, agents, contractors, service providers and professional advisers);

3. Any third-party service provider who provides administrative, telecommunications, computer, payment or securities clearing or other services to the Company in connection with the operation of its business (including their employees, directors and officers);

4. Any Authorities;

5. Any other person under a duty of confidentiality to the Company including any FSCL offices which has undertaken to keep such information confidential;

6. Any persons acting on behalf of an individual whose data are provided, payment recipients, beneficiaries, account nominees, intermediary, and correspondent and agent;

7. Any person to whom the Company or any of its offices is under an obligation or required or expected to make disclosure for the purposes of any guidelines set out, or in connection with Paragraph 6;

8. Third party reward, loyalty, co-branding and privileges programme providers;

9. Any bureaus or agencies established or to be established by Bank Negara Malaysia (including the Central Credit Reference Information System – “CCRIS”) or any of its subsidiaries, or by any other regulatory authorities.

Under and in accordance with the provisions of the PDPA and the Code of Practice approved and issued under the PDPA, any individual may:-

1. Check whether the Company holds data about him/her and of access to such data;

2. Request the Company to correct any data relating to him/her which is inaccurate; and

3. Request clarification on the Company’s policies and practices in relation to data and to be informed of the kind of personal data held by the Company;

In accordance with the terms of the PDPA, the Company has the right to charge a fee for the processing of any data access request.

The individual can request for access to data or correction of data or for information regarding policies and practices and kinds of data held by mail to the address below or by visiting the Company’s office to complete the data access form.

If you have any queries or complaints relating to this Notice or otherwise relating to misuse or suspected misuse of your personal information, you may send us a message via email.

The Company reserves the right to amend this Notice at any time and will place notice of such amendments on the Company’s website or the Company’s offices or via any other mode the Company views suitable.

Nothing in this Notice shall limit the rights of customers or the Company under the Personal Data Protection Act 2010.

Where the customer is a partnership (that is not registered under the Limited Liability Partnerships Act 2012) or other unincorporated body of persons, the giving of this Notice addressed to the partnership or the unincorporated body of persons shall be deemed as notice given to all the partners or office-bearers (as the case may be) of such customer whose data are collected and/or processed by the Company for the purposes as stated herein. In this regard, the customer warrants that the customer has obtained the consent of all such individuals to the provision of their data to the Company for the foregoing purposes and for disclosure to such parties as stipulated above and the customer undertakes to extend a copy of this Notice to all such individuals, which expression shall include all such existing and new partners or office-bearers (as the case may be) of the customer from time to time.

Aside from customers, this Notice shall also apply (as the context shall require) in relation to the usage, processing and disclosure of the data of any other individual who is not a customer but whose data is required to be collected by the Company by reason of, or incidental to, the provision of any services and/or facilities by the Company to its customers, whether the customer concerned is another individual(s) or is a company, business entity or organisation. In this regard, the customer confirms and warrants that the customer has obtained the consent of such individuals to the provision of such data to the Company for the foregoing purposes and for disclosure to such parties as stipulated above.

Your continued usage of the services and/or facilities is deemed consent for the Company to collect, process and store the data in accordance with the above. Failure to consent to the above may result in the Company being unable to open, establish, continue or provide the services or facilities to you.