At Fasset Labuan Limited (“Fasset”) and Fasset Group we respect your right to privacy. We have put in place security measures for your personal data and information (“Data”) and manage your Data in accordance with data protection regulations applicable to us including the Personal Data Protection Act 2010.
Notice under the Personal Data Protection Act 2010
Other privacy principles or policies could apply depending on how you interact with us, the products or services you may ultimately obtain from us, or the jurisdiction in which we are doing business with you.
- You may have supplied and may continue from time to time, to supply Fasset with your Data in connection with the opening or continuation of Accounts and Wallets, the connection with or continuation of bank accounts or credit cards to your Accounts, or provision of services or compliance with any laws, guidelines or requests issued by regulatory or other authorities. Fasset may also verify or source Data and personal information about you from third party sources (both public and private) such as your employers, regulatory or other authorities, banks and financial institutions, credit reporting agencies, Companies Commission and Insolvency Department as well as from the public domain. Your visit to the Site may be recorded for analysis on the number of visitors to the site and general usage patterns. Some of this information will be collected through the use of "cookies". “Cookies” are small text files that are placed on your computer by websites that you visit, or certain emails you open and other similar technologies. Such technologies are widely used in order to make websites work, or work more efficiently, as well as to provide business and marketing information to the owners of the site, to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP, etc. for the purpose of understanding how visitors use a website. Cookie and similar technologies help us tailor the Site to your personal needs and helps to prevent fraudulent activity and improve security. If you do not wish to receive “cookies”, you can adjust your browser setting so that your device does not accept them. However, we recommend you enable “cookie” acceptance to benefit from all the services and features of the Site.
- Such Data (including sensitive and/or personal 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, biometric information), 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 occupation details, source(s) of income, employer name, income details, job title, job responsibilities, employer’s contact information and address), bank details (such as bank account number(s), credit card details) and other information (such as financial and/or credit references, net worth including assets and liabilities). In addition, Fasset may from time to time request for certain other personal information that may be relevant for Fasset to consider your request for any other products, services or features available on the Site.
- Failure to supply such Data may result in Fasset being unable to open, establish, continue and/or provide Accounts, Wallets, products, services or features or comply with any laws or guidelines issued by regulatory or other authorities.
- It is also the case that Data is collected from (i) you and other sources in the ordinary course of the continuation of your relationship with us, for example, when you connect your bank accounts or credit cards to your Accounts or deposit money or apply for certain services or products or request for increasing transaction limits of your Accounts, (ii) a person acting on behalf of the individual whose Data is provided, and (iii) other sources (for example, information obtained from any bureaus or agencies established or to be established by Bank Negara Malaysia or any of its subsidiaries, the Labuan Financial Services Authority or by any other authorities, any credit reporting agencies, any insolvency department or any debt collection agencies that may be appointed by Fasset, and with any authority or agency in relation to the business we operate). Data may also be generated or combined with other information available to Fasset or Fasset Group.
- The purposes for which Data may be collected, used, processed, transferred and/or disclosed by Fasset and/or Fasset Group include without limitation (the “Purposes”):
a. assessing suitability for products and services and the processing of applications for Accounts, transaction limits on Accounts, products and/or services provided to users;
b. the provision of any Accounts, products and/or services and to approve, manage, administer or effect any transactions requested or authorised by you;
c. for such purposes as may be specifically provided for in any particular service or product offered by us;
d. obtaining or providing credit references and conducting credit checks (including but not limited to checks done upon request for increase in transaction limits on Accounts and during periodic or special credit review which may take place one or more times each year);
e. creating and maintaining Fasset's credit and risk related models and/or any purpose relating to risk management functions;
f. assisting other financial institutions to conduct credit checks, disputes or fraud investigation and collect debts;
g. updating and maintaining your records;
h. ensuring your on-going creditworthiness;
i. designing services or products for our users (including market research and statistical analysis and surveys with the aim of improving our products and services);
j. marketing services or products of Fasset and Fasset Group and/or selected companies (in respect of which Fasset may or may not be remunerated) including but not limited to:
i. financial, insurance, credit card, banking, staking, crypto, digital assets, wealth management and related services and products;
ii. reward, loyalty or privileges programmes and related services and products;
iii. services and products offered by Fasset’s co-branding partners (the names of such co-branding partners will be provided during the application of the relevant services and products, as the case may be);
iv. improving and furthering the provision of Accounts, products and/or services by Fasset and Fasset Group to users generally;
v. determining the amount of indebtedness owed to or by you;
k. collection of amounts outstanding from you and those providing security for your obligations or those for whose obligations you provide security;
l. for fraud or crime prevention and investigation, transaction disputes, data analytics, audit and debt collection and in order that services may be processed by Fasset;
m. for conducting risk management activity in order to comply with Financial Crime Regulations, investigating, reporting, preventing or otherwise in relation to breach of confidential information, fraud, money laundering, terrorist financing and criminal activities generally;
n. meeting obligations, requirements or arrangements, whether compulsory or voluntary, of Fasset or Fasset Group to comply with, or in connection with:
i. any law, regulation, judgment, court order, voluntary code, sanctions regime, within or outside Malaysia existing currently and in the future (“Laws”);
ii. 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;
iii. 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, exchange, court, central bank 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 Fasset Group (together the “Authorities” and each an “Authority”) that is assumed by, imposed on or applicable to Fasset or Fasset Group; or
iv. any agreement or treaty between Authorities;
o. complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Fasset Group and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of fraud, money laundering, terrorist financing or other criminal and/or unlawful activities;
p. conducting any action to meet obligations of Fasset or Fasset Group 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, criminal and/or unlawful activities, evasion of economic or trade sanctions and/or any acts or attempts to circumvent or violate any Laws relating to these matters;
q. meeting any obligations of Fasset or Fasset Group to comply with any demand or request from the Authorities;
r. enabling an actual or proposed assignee of Fasset in respect of your relationship with us to evaluate the transaction intended to be the subject of the assignment;
s. for any purpose required by law or regulation;
t. for the purpose of enforcing its legal rights and/or obtaining legal advice and/or any legal process (whether by way of judicial proceedings or any other form of proceedings recognised in law) initiated by or served on, Fasset (whether or not Fasset is a party);
u. for making enquiries or investigations as to whether or not you or person whose Data is collected, used and/or processed by Fasset 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;
v. for all ancillary purposes relating to the provision of products and services and facilities relevant thereto including the provision of computer, telecommunications and technology services;
w. for business planning and decision making or internal operational requirements of Fasset or the Fasset Group (including, without limitation, financial, credit and risk analysis and management, system or product development and planning, reporting, audit and administrative purposes);
x. maintaining Fasset’s and Fasset Group’s overall relationship with you (including, if you have not specifically requested otherwise, marketing or promoting financial services or related products, market research, insurance, audit and administrative purposes);
y. attending to your enquiries and generally to enable resolution of any concern or complaint;
z. for the organization of seminars, talks or events hosted by Fasset, Fasset Group or our respective partners;
aa. for our internal record keeping; and/or
bb. any activity related or incidental to any abovementioned Purposes.
- Data collected and held by Fasset or Fasset Group relating to an individual will be kept confidential but Fasset or Fasset Group may, as necessary, 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) subject at all times to any laws (including regulations, standards, industry code of practice, guidelines, obligations and/or directives from any regulatory authorities) applicable to the concerned entity:
a. Fasset Group (including any officer, employee, consultant, advisor, agent or director);
b. any agent, contractor, sub-contractors, service providers, lawyers, professional advisers, interns or associates of the Fasset Group (including their employees, directors, officers, interns, agents, contractors, service providers and professional advisers);
c. our business alliances or partners who may provide their products or services to us and/or to you and any third party service provider who provides administrative, telecommunications, computer, storage, payment, custodial, liquidity or other services to Fasset in connection with the operation of its business (including their employees, directors, officers, interns, agents, contractors, service providers and professional advisers);
d. any Authorities;
e. any other person under a duty of confidentiality to Fasset including Fasset Group which has undertaken to keep such information confidential or any parties which are necessary in disputes or fraud investigation for the purposes of paragraph 6(l), including card payment network providers;
f. any persons acting on behalf of an individual whose Data is provided, fiat currency or Asset recipients, beneficiaries, Account nominees, intermediary, correspondent and agent banks, liquidity providers, clearing or settlement systems, market counterparties, exchanges, companies in which you have an interest in digital assets (where such digital assets are issued and/or held by Fasset or Fasset Group) or a person making any transfer into your Account whether of fiat currency or Asset;
g. any person to whom Fasset or Fasset Group 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(m), (n), (o), (p) & (q);
h. any actual or proposed assignee of Fasset or transferee of Fasset’s rights in respect of your Account and/or relationship with us;
i. any party acquiring interest in, or assuming risk in, or in connection with, the Accounts, products and/or services provided by Fasset and/or Fasset Group;
j. any third party who provides services to you;
k. third party financial institutions, insurers, credit card companies, exchanges, liquidity providers, or banks;
l. third party reward, loyalty, co-branding and privileges programme providers;
m. co-branding partners of Fasset or Fasset Group (the name of such co-branding partners will be provided during the application of the relevant services and products, as the case may be);
n. external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that Fasset engages for the purposes set out in paragraph 6(j);
o. other financial institutions, credit reference agencies, credit reporting agencies, any authority in relation to the crypto currency and/or digital assets industry; the police; any other governmental or regulatory authority or body, any insolvency department and in the event of default, to debt collection agencies;
p. any present or prospective security or liquidity providers for the products and services; and/or
q. any persons authorized by you
wherever located, including in jurisdictions which do not have data protection laws that provide the same level of protection as Malaysia. Whether it is processed in Malaysia or overseas, in accordance with data protection legislation, your Data will be protected by a strict code of secrecy and security which Fasset Group, its staff and third parties are subject to. You understand that Fasset or any of the recipients will be obliged to disclose Data if legally compelled to do so by any Laws.
- In connection with 7(o) above, in the event of any default in payment where the amount in default is not fully paid on or before the due date, the individual is liable to have his/her/its Data shared with, disclosed to and/or retained by the credit reporting agency.
- If you hold and/or operate an Account on behalf of another person (individual or entity), Fasset may also disclose to such other person(s) on behalf of whom you hold and/or operate the Account, Data provided to Fasset in relation to the Account, irrespective of whether such person(s) are the authorised signatories and if they are, irrespective of their signing authority under the Account or any services provided under the Account.
- Fasset takes security measures in line with the data protection regulations applicable to us including the Personal Data Protection Act 2010. Fasset has security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to data. We take reasonable steps to ensure your Data is protected from misuse or loss, and unauthorized access, modification or disclosure. In particular, to ensure the security of your Data, the cloud solution that we use to store your Data complies with industry standard access controls.
- Fasset may use, analyse and assess Data held about you and your Account, including the nature of your transactions and/or the counterparties you deal with, to give you and/or your counterparties, information about products and services from Fasset Group and those of selected third parties which Fasset thinks may interest you and/or your counterparties via telephone, mobile phone, emails, electronic media, posts, push notifications, SMS or other means. Fasset may pass this information to Fasset Group so that it may do the same unless you have specifically requested otherwise regarding such disclosure for purposes of cross-selling to you or your counterparties.
- You may:
a. check whether Fasset holds Data about you and request for a copy of such Data held by us;
b. request Fasset to correct any Data relating to you which is inaccurate;
c. request clarification on Fasset's policies and practices in relation to Data and to be informed of the kind of Data held by Fasset.
- You can request for information on your Data, access to your Data and correction of your Data held by Fasset. This request should be made by writing to us at firstname.lastname@example.org. You will be asked to complete a Data access/correction form and a fee is chargeable for processing such request in accordance with the terms of the Personal Data Protection Act 2010.
- If you do not want us to further disclose your Data to Fasset Group or the said third parties for the purposes of cross-selling and/or if you do not want to be contacted by us or the said third parties for the sale or promotion of any products or services, you may write to us at email@example.com with a specific request to that effect. Further, to unsubscribe from our marketing mailing list you may click on the “unsubscribe” link at the end of the e-mail communication received. Your request to be removed from our marketing mailing list may take up to 30 days to be effective. Please note that in order to keep you updated on important messages, Fasset will still send you selected communication even though you may have unsubscribed.
- If you visit any link on the Site to any third party website or app, you agree to and shall comply with the separate and independent privacy policies of such third party websites and/or apps. You understand and acknowledge that Fasset is not responsible for the content or activities of such third party websites or apps.