Privacy Policy

PRIVACY POLICY
ADVISONOMICS SDN. BHD. (Company No.: 1350910-W)

1 INTERPRETATION

“Advisonomics” means Advisonomics Sdn. Bhd. (Company No.: 1350910-W) “GDPR” means General Data Protection Regulation

“PDPA” means Personal Data Protection Act 2010 of Malaysia

“Platform” means the online platform (accessible including but not limited to website at Advisonomics.my or mobile application) operated by Advisonomics;

2 INTRODUCTION AND APPLICATION

This policy (hereafter referred to as the “Privacy Policy”) outlines how Advisonomics Sdn Bhd (Company No 1350910-W) manages Personal Data which is in our possession or under our control. The phrase “Personal Data” is defined in the Personal Data Protection Act 2010 of Malaysia (“PDPA”), and refers to any information in respect of commercial transactions that relates directly or indirectly to a data subject, who is identified or identifiable from that information or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject.

This policy is designed to assist you in understanding how we collect, use, process and disclose personal information you provide us and to assist you to make informed decisions. We will treat personal data that you provide us according to this Privacy Policy, the PDPA and the GDPR.

By using our services pursuant to your engagement with us, operating any account maintained with us, accessing our online platforms (which is accessible on our website https://advisonomics.my or our mobile application), websites or otherwise providing information to our representatives or communicating with us, you are taken to have agreed to our collection, use, processing and disclosure of your Personal Data in accordance with this Privacy Policy.

This Privacy Policy does not supersede or replace any other terms, consents or agreements you may have previously or separately provided to us regarding your Personal Data and your consent of this Privacy Policy is in addition to any other rights we have under Malaysian law to collect, use, process or disclose your Personal Data.

As a company based in Malaysia, this Privacy Policy shall be governed by, and construed in accordance with, the laws of Malaysia. Without prejudice to your obligations and rights under

any applicable laws, any disputes arising in relation to this Privacy Policy, and/or the documents referred to herein, including any questions regarding their existence, validity or termination, shall be referred to and resolved by arbitration under the AIAC Arbitration Rules. The seat of the arbitration shall be Malaysia, and the arbitration proceedings shall be conducted in English.

This statement will be continuously assessed and updated against new technologies, business practices and our customers’ needs.

3 DATA THAT WE COLLECT

We collect, use, process, transfer and disclose various kinds of information about you and your associated persons (individuals who are connected to or associated with you, not limited to your legal representatives) in accordance with this Privacy Policy.

Personal Data refers to information used to identify or contact a specific person. We collect your contact data (Full Name, Email Address, Postal Address, Phone Number and Employer), financial information (such as your FPX transfer accounts and Net Assets), demographic data (such as Gender, Date of Birth, Zip Code), identification data (ID card, Passport and other information needed to verify your identity) and Usage Data (defined below). This list is not exhaustive, and we collect other information that you may provide us during your interaction with our Website or Mobile Application.

Certain types of personal data, including data about your personal health and racial and ethnic origins, are characterized as Sensitive Personal Data by the PDPA and subject to stricter regulation than other forms of personal data. Before providing it to use, we urge you to carefully consider whether to disclose your Sensitive Personal Data to us. If you do provide Sensitive Personal Data to us, you consent to its use and disclosure for the purposes and in the manner described in this Privacy Policy.

Usage Data refers to information about a user’s online activity that does not, by itself, identify an individual. This may include technical information (your Browser Type, Service Provider, IP Address, GPS Location Data, Operating System and Websites Visited), information about your usage on our platforms, and metadata, which means information related to items you made available through the Website.

We also collect data from your interactions with the Advisonomics App and Team, including your specimen signature, digital signature, occupation, education and income levels, risk index and investment objectives.

We have the right to use any other data provided by you if it is reasonably required to provide the services that you have requested. We also collect any other personal data permitted by or required to comply with any applicable local or foreign laws, rules, acts, regulations, legislation notices, notifications, circulars, license conditions, directions, requests, requirements,

guidelines, directives, demands, guidance or decisions of any national, state or local government, any agency, exchange or regulatory body, law enforcement body, court, central bank or any other authority in Malaysia and globally, whether having the force of law or not. These laws may be amended from time to time, and our internal control and compliance policies will reflect these changes.

4 SOURCES OF INFORMATION

Whether we collect certain types of information and how we process it depends on how you use and access the Website. Some information is collected automatically through use of cookies and similar data collection tools. We collect information about you in the following ways:

From You:

We collect information provided or submitted by you through among others, your dealings and agreements with us, which includes information provided when registering as a user, providing information regarding any account which you may open with us, providing answers to security questions, completing any confirmations, declarations or forms, or through your utilization of any of our services, accessing or viewing our Platform;

We also collect, as applicable, publicly available or publicly accessible information; and such other written, electronic or verbal communications or documents delivered to us prior to and during the course of our contractual or pre-contractual dealings with you.

As the accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data. We intend to keep the Personal Data accurate and up-to-date, and retain the Personal Data no longer than necessary for the above purposes or as required or permitted by any applicable law.

From Our Business Partners and Service Providers:

Third parties that assist us with our business operations also collect information (including Personal Data and Usage Data, as defined above) about you through the Website and share it with us. We may combine the information we collect from you with information from other sources and use the combined information as described in this Privacy Policy.

From Your Interactions:

We automatically collect Usage Data when you interact with the Website or our Application.

Our Website uses cookies to gather information about your computer for our services and to provide statistical information regarding the use of our website. Such information will not be bundled with your Personal Data or used to identify you personally, but rather for us to collect

statistical information about the use of our website. We may also use cookie files to get information about your general internet use, which are downloaded to your computer automatically. They help us improve our Website experience by tracking users’ navigation habits, storing users’ passwords for access to our systems, customizing user experience and helping to detect and prevent fraud.

We also use cookies and other data collection tools, including but not limited to web beacons and server logs, to help improve your experience with the Website. These data collection tools help us remember users and make the services more relevant to them. These data collection tools may also collect information from the device, including the manufacturer, operating system, browser type and the country and time zone in which the computer or device is located.

All browsers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline our cookies. Please note that should you disable cookies on your device, you may be unable to access or have subpar experiences on particular parts of our Website.

5 PURPOSE OF COLLECTING, DISCLOSING AND USING PERSONAL DATA

We may process the information we collect/you provide to us in accordance with the PDPA and GDPR. This information is primarily used to enable us to provide our services to you. In addition, we may use the information for the following purposes:

Carrying out any transactions on your behalf contemplated on the Platform and the services thereto;
Assessing and processing applications, instructions or requests from you, including but not limited to application to fund management companies;
Account opening and operations relating to your account with any of Advisonomics’ associated companies and third-party service providers;
Communicating with you, including providing you with updates on changes to our services;
To verify your identity for the purposes of providing services to you; ● Conducting due diligence checks, screenings or credit checks as may be required by any Applicable Laws or our internal policies and procedures;
For the specific purpose for which it was volunteered or provided to us; ● To detect and protect us or any third parties against negligence, fraud, theft and other illegal activities;
To understand your needs and preferences;
Improving the content, appearance and utility of the Platform;
To manage and develop infrastructure and business operations;
To administer any account which you may open with us and our partners; ● To process payments;
To comply with our internal policies and procedures;
To respond to queries or feedback;
To address or investigate any complaints, claims or disputes;
As permitted by any Applicable Laws, or to comply with any Applicable Laws or any request from any relevant governmental or regulatory authority;
Financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;
Enforcing obligations owed to us;
Seeking professional advice, including legal advice;
Any other reasonable purposes in connection with the provision of our services; ● With your consent, providing you with marketing materials in connection with the services we may provide;
Fulfilling any purpose directly related to the above Purposes; or
Any other purposes that are appropriate or authorized by any Applicable Laws.

With respect to marketing, you may, at any time, withdraw your consent to receive marketing material from us. If you wish to do so, please click on the Unsubscribe option on all marketing materials that we send out. Please note that this will not stop us from sending you important information about your Advisonomics account.

We restrict access to information about you to those employees who need to know the information in order to perform their jobs, such as your financial planners, our tech support team or those who notify you of new products and services. To protect your personal information, we maintain physical, electronic, and procedural safeguards in keeping with industry standards and practices, and we review and adjust these safeguards regularly in response to advances in technology.

6 DISCLOSURE AND SHARING OF PERSONAL DATA

We may share Personal Data with third parties:

in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets;
if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation or in order to enforce or apply our Website Terms and other agreements, but we will endeavor to minimise such disclosure to only that reasonably necessary and, where possible, to provide you with notice of such disclosure; and/or
to protect the rights, property, or safety of Advisonomics, the Website, our users and any third party we interact with to provide the Website.
In the same manner, if you have given us consent to use your data for a particular purpose you can revoke or vary that consent at any time.

We may also disclose Personal Data to perform services on your behalf through the Advisonomics Platform. We may disclose your Personal Data to any employee / member of our group, including subsidiaries, holding companies and its subsidiaries, or any affiliates in order to perform services requested or functions initiated by users, provided that such subsidiary, holding company and its subsidiary, or affiliate shall adhere to the obligations setforth in this Privacy Policy. In addition, we may disclose Personal Data in order to identify a user in connection with communications sent through our Platform.

With third party service providers performing services on our behalf or through our system, including professional advisers, contractors, service providers, debt collection agencies and our other agents with whom we have contractual agreements, financial service providers in relation to the products and services that you have with us, strategic/business partners with whom we have a relationship with for specific products and services, any person connected to the enforcement or preservation of any of our rights under your agreements with us or any party authorized by you, we share information, including Personal Data, with them to perform the functions for which we engage them (such as hosting and data analyses). We may share information as needed to operate other related services. We will take all reasonable precautions to ensure that data is not shared for any other purpose or with any third party that is not legally mandated to collect said Personal Data, and will take every reasonable effort to ensure that said third parties treat said information confidentially.

We also may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Data as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Data as required to pursue available remedies or limit damages we may sustain.

We may share information about you in an aggregated form, that is, in a statistical or summary form that does not include any personal identifiers, with third parties in order to discover and reveal trends about how users like you interact with our services.

We may transfer information, including your Personal Data, in connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify users before your information is transferred or becomes subject to a different Privacy Policy.

7 TRANSFERRING DATA

As a Malaysian Company, we primarily collect and store personal data in Malaysia. We may transfer, store or process your Personal Data or a group’s aggregated data outside Malaysia. In doing so, we will take every precaution to ensure that data is secure, while complying with the PDPA, GDPR and other applicable data protection and privacy laws.

The security of your Personal Data is important to us. We shall take all appropriate security and organizational measures to prevent unauthorized access to, alteration of, disclosure of, accidental loss, and destruction of personal information under our control. Furthermore, all of the sensitive data we collect is protected by several layers of encryption and several layers of security to prevent unauthorized access.

However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Platform are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of the services are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

8 CUSTOMER RIGHTS

We hold your personal data for as long as the purpose for which it was collected remains and until it is no longer necessary for any other business purpose. We may also retain data from closed accounts to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation and other actions permitted by law. After it is no longer necessary, we dispose of it according to our data retention and deletion policies.

You have the right to access, review and request a copy of the Personal Data held about you by us. You are also entitled to have incorrect Personal Data about you corrected, and you may, in some circumstances, ask us to restrict our processing or delete your Personal Data. You also have the right to change the permissions that you have given us in relation to how we use your Personal Data. You can request that we cease using your data or that we delete all personal data records that we hold relating to you.

The GDPR and PDPA also give you the right to lodge a complaint with a supervisory body in the state where you work, normally live, or where any alleged infringement of data protection laws occurred if you believe that the processing of your Personal Data infringes aforementioned regulations.

9 THIRD PARTY EXCLUSIONS

Our Website and Application may contain links to other websites which are not maintained by us. This Privacy Policy only applies to our websites, mobile applications and other services provided by us. When visiting these third party websites, you should read their privacy policies which will apply to your use of the web sites.

10 VARIATION

Advisonomics reserves the right to add to, amend or vary any of these Privacy Policies at any time in its sole and absolute discretion and any additions, amendments or variations shall take effect and bind you from such date as Advisonomics may prescribe provided that Advisonomics gives prior notice to you by:

(a) posting such change(s) on Advisonomics’ Platform;

(b) electronic mail or letter;

(d) such other means of communication as Advisonomics may determine in its absolute discretion.

If you continue to use our services, operate any account maintained with us, access our Platforms, and/or otherwise provide information to or communicate with us, you are deemed to have agreed to such changes without reservation.

11 QUERIES

Please contact us at operations@advisonomics.my if you have any queries related to this Policy.