This Policy is governed by and shall be construed in accordance with the laws of Malaysia.
This Policy is available in English and Bahasa Malaysia, and may be made available in other languages. In the event of inconsistency between the English version and a version of this Policy in another language, the English version shall prevail.
- "Confidential Information" means any information that relates directly or indirectly to a User that is not Personal Data which is provided by the User to IAP and/or include all tangible and intangible information and materials which is disclosed and/or obtained and includes, without limitation, the following, whether or not marked or designated as Confidential Information by the disclosing party:-
- any information which relates to the existing or future research, know-how, development, marketing, financial or business activities of the disclosing party;
- any plan, drawing, report, calculation, specification, instruction, diagram, catalogue, manual and data of the disclosing party;
- any unpatented invention, formula, procedure and method of the disclosing party;
- any patent application, design, copyright, plan, drawings, photographs and trademarks including but not limited to, any pending application and any other proprietary right vested in the disclosing party or in which the disclosing party has an interest of any kind;
- any information concerning the past, existing or future financial, legal, business affairs, operations, administration or strategic plans of the disclosing party and its affiliates;
- any other information or material whether of a business, scientific, financial or any other nature which is of a proprietary, confidential or sensitive nature, is marked or denoted as being confidential or which a reasonable person would consider it to be confidential.
But which does not include any information which is:
- already in possession of or known to the receiving party prior to disclosure by the disclosing party as evidenced by written records and not in breach of any confidentiality obligation;
- in or becomes part of the public domain through no fault or breach by the receiving party or its officers, employees or consultants; or
- required to be disclosed by any law, judicial order, governmental regulation or rule.
- "Data" means Personal Data and Confidential Information.
- "IAP" means IAP Integrated Sdn Bhd which includes its holding company and its related companies.
- "Personal Data" means any personal information that relates directly or indirectly to a User who is an individual, who is identified or identifiable from that information or from that and other information in IAP possession, including any sensitive personal data and expression of opinion about a User.
- "Transactions" means any transaction facilitated through the Website and/or by IAP, including but not limited to the following transactions:
- registration of a User on the Website;
- pledge/subscription/request to invest in a Venture; and
- application to be listed as a Venture on the Website.
"User" shall mean any user of the Website, including:
- any person visiting/browsing the Website;
- an investor;
- an individual or corporation raising funds and is making an application to be a Venture listed on the Website;
- a Venture; and
- a Sponsoring Bank.
As a provider of an investment platform, your Personal Data will be used to fulfill IAP's commitment in providing you with its services and infrastructure to the best of its ability.
Collection of Personal Data
In order to enable IAP to deal with your requests and/or to generally provide you with its services, IAP may need to and/or may be required to collect, record, hold, use, disclose and store your Personal Data. Unless specified otherwise, the provision of the Personal Data is obligatory in order to use the services offered by IAP.
Your Personal Data will be collected primarily from you directly. However, IAP may also source your Personal Data from other third parties such as credit reporting or governmental agencies for the purposes and in the circumstances as stated under "How we use Personal Data".
Types of Personal Data
The types of Personal Data IAP processes include:
How we use Personal Data
- Your personal details such as name, national registration identification number, age, sex, nationality, occupation, contact information and other required information;
- Your credit card details, bank account information and financial information;
- Your profile or password details;
- Your reviews and opinion about IAP services and the Website; and
- Any other information necessary to facilitate any Transaction or your use of the Website.
Other than as stated abovementioned, IAP may use your personal data for one or more of the following purpose and IAP may use and disclose all or any of the relevant portions of your Personal Data in order to:
Disclosure of Personal Data
- Facilitate any Transaction;
- Ascertain your risk tolerance as well as your suitability and eligibility to the Ventures listed on the Website;
- Facilitate communications between you, IAP and Sponsoring Banks;
- Process registration applications on the Website;
- Verify your identity, protect your interest and implement security measures in compliance with the law;
- Administer general record keeping;
- Facilitate marketing, promotional and User administration and management purposes including to provide you with information on marketing campaigns that IAP or IAP's business partners believe would be of interest to you;
- Conduct market analysis and research as well as quality assurance surveys;
- Respond to request for information and services;
- Meet contractual, legal and/or regulatory requirements, or to enforce IAP's legal or contractual rights, including to recover any debt owing by you to IAP (if any); and
- For any internal reporting or risk analysis purposes, for e.g. risk analysis and reporting to the management and board of directors.
As part of IAP's role to provide you the services, IAP will disclose and transfer your Personal Data to Sponsoring Banks, business partners and third party data processors who provide administrative, telecommunications, payment or other services to IAP. The provision of such Personal Data is made to provide you with IAP services/infrastructure and to facilitate Transactions pursuant to your request as well as for the purposes stated under "How we use Personal Data". Such recipients of your Personal Data are contractually prohibited from using Personal Data for any purpose other than for the purpose IAP specifies.
IAP may also disclose your Personal Data to external professional advisors and consultants, rating agencies, companies and/or organisations that assist IAP in providing the services and/or value added services herein, Sponsoring Banks and business partners of IAP, for the purposes of business, operational, legal and regulatory requirements or pursuant to any corporate exercise of/related to IAP. IAP reserves the right to disclose any of your Personal Data or information if IAP/any of the Sponsor Banks are legally compelled to do so to comply with and/or any purposes required by any relevant law, directives, guidelines, orders, rules, regulations and requirements of any governmental or statutory authority or administrative or regulatory or supervisory body.
Processing of Personal Data
You hereby acknowledge and agree that your Personal Data may be transferred to another country due to some aspects of IAP's data processing activities. The jurisdictions in which the Personal Data or information is processed may or may not have laws to regulate the privacy of personal data, however, whenever your Personal Data is transferred by IAP, IAP will use its best endeavor to ensure that your Personal Data is processed in accordance with the terms and conditions of this Policy.
Usage tracking and Log Files
IAP's web server automatically collects information on your domain type, browser used and your IP address for statistical purposes only, which will be used to improve the content of the Website and not sold to other organizations for any purpose.
As with most other websites, IAP collects and uses the data contained in log files. The information in the log files include your IP (internet protocol) address, your ISP (internet service provider), the browser you used to visit the Website, your screen resolutions and number of colors, the time you visited the Website and which pages you have visited throughout the Website.
Third Party Contents
The Website also contains links to other websites, including that of Sponsoring Banks. IAP is not responsible for the privacy practices of such other websites. IAP encourages you to be aware when you are leaving the Website, and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected on this Website and by IAP.
IAP has carried out appropriate measures in ensuring the security of your Personal Data. IAP constantly reviews the measures to safeguard and secure your Personal Data. Despite IAP's best level efforts to protect your Personal Data, IAP is not in the position to guarantee that your Personal Data and information will be secured at all times. As a result, IAP offers no warranties or representations with regard to the security of the Personal Data.
IAP does not collect Personal Data of minors as the services by IAP are not directed at minors.
You may exercise your right to choose in respect of:
- the disclosure of your Personal Data;
- the type of Personal Data; and
- the use of your Personal Data.
However, in the event that you choose not to provide IAP with certain information, IAP may not be able to provide you with some of the services available on the Website.
IAP will respect your request to stop sending you direct marketing materials. In order to ensure that your request is recorded and attended, your contact details will not be deleted but will instead be included in a list of Users who do not wish to receive direct marketing materials in the system maintained by IAP.
How to Access or Correct Your Personal Data
Whenever there is a change in your Personal Data held by us, kindly update IAP. IAP can assist you to correct and update your Personal Data. In relation to any of your Personal Data held by IAP, you are entitled to make request to:
- Access your Personal Data; and
- Make changes to your Personal Data.
If you have any questions or doubts about this Policy, or if you wish to access or make changes to your Personal Data held by IAP, please contact:
|Head, Information Services & Operation
Suites 2-4, Level 2, Tower Block, Menara Milenium,
Jalan Damanlela, Pusat Damanlela, Pusat Bandar Damansara, 50490 Kuala Lumpur
Please note that IAP may use our discretion in allowing the access or corrections requested and/or may require further documentary evidence of the new information to avoid fraud and inaccuracy. You can also assist IAP to keep your Personal Data (for e.g.: your current mailing address) up to date to enable IAP to serve you better.
Kindly note that IAP at its sole discretion may impose the fee of up to the maximum amount as stated belowmentioned for all request for access to Personal Data according to the Personal Data Protection (Fees) Regulations 2013, which are currently as follows:
- Personal Data access request with a copy RM10
- Personal Data access request without a copy RM2
- Personal Data access request for sensitive personal data with a copy RM30
- Personal Data access request for sensitive personal data without a copy RM5
The nature of the services provided by IAP and role of IAP to facilitate Transactions may require Users to provide IAP and/or other Users with Confidential Information. As such, all Users, in providing and receiving Confidential Information to and through IAP (whether through the Website or otherwise) shall agree to mutual obligations of confidentiality with regard to the Confidential Information and to the terms and conditions in this Policy governing such confidentiality.
In relation to the provision of your Confidential Information, you acknowledge and agree that:
Users who are also recipients of Data
- your Confidential Information may be provided to other Users for the purposes of the Transactions including for evaluation, analysis and matters related thereto;
- there are mutual obligations of strict confidence by the Users and recipient of that Confidential Information; and
- while IAP will use its best endeavours to maintain the confidentiality of your Confidential Information it receives, IAP has no control over the management and usage of the same by the recipients once such Confidential Information is provided through the Website and/or to such other Users. IAP shall not be liable for any breach of confidentiality by any User of the Website in relation to your Confidential Information.
In relation to the Confidential Information you have been provided with or were obtained by you, you agree and acknowledge that:
- the Confidential Information is provided or has been obtained under an obligation of strict confidence to IAP and/or the disclosing party of the Confidential Information;
- the Confidential Information may comprise trade secrets of the disclosing party of the Confidential Information and related entities of the disclosing party of the Confidential Information;
- you must not disclose any Confidential Information to any person other than to your directors, shareholders, agents and employees, and only to the extent necessary for the conduct of the Transaction;
- you must not after the end of the Transaction use any part of the Confidential Information;
- you must use your best endeavours to cause all of your directors, shareholders, agents and employees who receive or have access to Confidential Information to observe all of your obligations and undertakings contained in this Policy; and
- you must implement proper systems and procedures as may be necessary to maintain the confidentiality of the Confidential Information.
By using this Website and/or receiving Data from IAP or through the Website, you agree to process all Data received in accordance with the terms and conditions of this Policy.
Changes to the Policy
Please note that IAP may make changes to this Policy from time to time. Any changes to this Policy will be posted on the Website or such other means of communication deemed suitable by IAP. This is to ensure that you are always informed of the way IAP collects, maintains and uses your Data. The changes made to the Policy are effective upon the posting of the revised Policy on the Website. Your use of the Website after the revision/changes constitutes your acceptance of the revised Policy then in effect.
Date: 16 December 2015