Updated as at / Dikemaskini pada: August 1, 2024
FG WALLET
PRIVACY POLICY
(Version 1.0)
FG Wallet is a mobile application owned and operated by BIB LIMITED (Company No.: LL16963).
Any reference to “BIB”, “we”, “us” or “our” shall be a reference to BIB LIMITED (Company No.: LL16963), our shareholders, directors, employees, managers, consultants, representatives, agents, partners and/or our data processors and any of our group of companies including our respective subsidiaries, affiliates, associates and other related companies which BIB has direct or indirect interest in (as applicable).
This privacy policy (“Privacy Policy”) serves as a notice made pursuant to the Act (as defined below) and it is applicable to you throughout the course of our Engagement (as defined below). This Privacy Policy explains the manner in which BIB records, stores, processes, discloses, transfers and otherwise uses Personal Data collected during our Engagement as well as the rights available to you as a Data Subject, on the handling of Personal Data. You are advised to read and understand this Privacy Policy (and any revisions thereof) thoroughly and carefully.
By accessing and/or using the FG Wallet, you are deemed to have read, accepted and signified your agreement to this Privacy Policy without any limitation or qualification and you have agreed to our processing of your Personal Data in accordance with this Privacy Policy. If you do not accept this Privacy Policy, not agreeable to our processing of your Personal Data or you wish to retract your agreement to this Policy, please immediately cease your access to and/or use of the FG Wallet.
Any reference to “you” and “your” in this Privacy Policy refers to the Data Subject (as applicable). If you are an entity, references to “you” and “your” shall also include your shareholders, directors, employees, managers, officers, representatives, agents and partners, respectively.
A. DEFINITIONS
For the purpose of this Privacy Policy, the following terms shall, unless the context otherwise requires, have the meanings as defined below:
“Act” |
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means the Personal Data Protection Act, 2010, the applicable regulations, guidelines, orders and any statutory amendments or re-enactments made pursuant thereto; |
“Data Subject” |
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refers to any party who is the subject of the Personal Data which shall include but is not limited to our Users, exchanges/issuers of digital assets available/accessible through our FG Wallet, our service providers, agents, and/or other parties (whose Personal Data is processed by us as part of the provision of the FG Wallet); |
“Engagement” |
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means your access to and/or use of the FG Wallet for functionalities and/or services as BIB may make available on the FG Wallet; |
“Personal Data” |
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means any information collected by BIB, which relates directly or indirectly to a Data Subject that is identified or identifiable from that information. The categories/types of Personal Data collected depend on the purpose for the collection; |
“Privacy Policy” |
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means this privacy policy including any revision(s) thereof subject to the terms hereunder; and |
“User(s)” |
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means any individual, company and/or any other form of entity which accesses and/or uses the FG Wallet and/or engages with BIB via the FG Wallet in any manner. |
B. COLLECTION OF PERSONAL DATA
1. Please be informed that we may collect your Personal Data from time to time in the course of our Engagement in order to accordingly carry out and fulfil our Engagement.
2. As a User, your Personal Data may be collected by us at any point in the course of the following acts:
(a) when you enter into an Engagement via the FG Wallet (including but not limited to the act of accessing the FG Wallet, using the functionalities as made available on the FG Wallet and/or interacting with us); and
(b) when you visit the FG Wallet, via cookies, web beacons and/or other similar technologies which we utilise to provide you with a better service, assist with our analytics for the FG Wallet and/or to increase the general efficacy of our operations. Upon your access to and/or use of the FG Wallet, our servers and/or equivalent technological equipment may record your Personal Data (which includes browser type, other visited webpages and/or any other related information).
3. The collection, recording, storage, disclosure, transfer, transmission or otherwise usage of the Personal Data shall constitute an act of us “processing” your Personal Data.
C. TYPE OF PERSONAL DATA WHICH MAY BE COLLECTED
4. Where appropriate and necessary, the type of Personal Data which we may collect during our Engagement includes (but is not limited to) your:
(a) full name (legal or otherwise);
(b) correspondence address;
(c) contact number;
(d) email address;
(e) any such information as may be required to render any technical support which you may request (to the extent the same is within our scope of technical support); and
(f) any details of your location which is made available to us through your internet protocol (IP) address.
5. Where Personal Data is provided by you to us, you are responsible for the accuracy and completeness of all such Personal Data (which accuracy we have assumed), and that none of such Personal Data is misleading or out-of-date. Should there be any changes/updates to your Personal Data, you will promptly update us in writing in the manner indicated in this Privacy Policy.
6. In the case where Personal Data of another Data Subject is provided by you (e.g. Personal Data related to your family members, child or spouse), you confirm that you have explained or will explain to them the processing of their Personal Data in accordance with this Privacy Policy and you represent and warrant the accuracy, truthfulness and completeness of their Personal Data.
D. PROCESSING OF PERSONAL DATA
7. The purposes for which we may use your Personal Data include amongst others the following and such purposes may be carried out by any means or methods as we deem fit, subject to the laws of the relevant jurisdictions:
(a) completing the cryptocurrency transactions (as may be permissible on the FG Wallet) in response to the instructions you provide via the FG Wallet;
(b) for the internal operation and administration of the FG Wallet, including but not limited to data analysis, market research, traffic measurement and analysis;
(c) processing, facilitating, dealing with, arranging, administering, managing our Engagement with you;
(d) responding, addressing or attending to your queries and/or requests and to take actions related to such queries and/or requests;
(e) complying with any requirements or obligations of the laws of the relevant jurisdictions (to the extent such compliance falls within our set of obligation);
(f) adhering to any rulings, guidelines and orders imposed by any regulatory body;
(g) sharing your Personal Data for purposes of seeking legal and/or financial advice (including for purposes of preparing such legal documentation);
(h) sharing any of your Personal Data with our accountants or auditors for our internal audit and reporting purposes;
(i) detecting, investigating and preventing any fraudulent or illegal activity, omission or conduct;
(j) upgrading, improving, modifying or revamping the FG Wallet and/or its functionalities;
(k) for our storage, hosting back-up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside of Malaysia; and/or
(l) any other purposes as we may deem fit for purposes of your Engagement with us.
8. We will only process your Personal Data in accordance with the Act as well as this Privacy Policy.
E. DISCLOSURE OR TRANSFER OF PERSONAL DATA
9. Subject to the laws of the relevant jurisdictions, BIB may disclose your Personal Data to the following persons under any of the circumstances set out below:
(a) our shareholders, directors, employees, consultants, staff, subsidiary companies (local or foreign), related entities (local or foreign), independent contractors, service providers, business associates, agents and any other party who assists BIB in the processing of the Personal Data and the management of the operation and maintenance, in support of the FG Wallet;
(b) our subsidiaries, affiliates, associates and other related companies which BIB has direct or indirect interest in as deemed necessary by BIB for the purposes of the FG Wallet;
(c) if required to do by operation of law or by regulatory or compliance bodies in order to identify risks or threats relating to fraud, money laundering, terrorism financing and/or any other illegal or criminal activities;
(d) auditors, accountants and/or solicitors in the preparation of documents of BIB for statutory filing purposes or any other document required to be submitted to adhere to the statutory or regulatory compliance owed by BIB to governmental authorities or compliance bodies;
(e) to the extent permitted by any relevant laws, any third parties (including financial advisers / legal advisers / professional advisers) carrying out due diligence review in connection with any proposed merger, acquisition, sale, reorganisation, joint venture or any other corporate activity related to BIB or any of its subsidiaries, related or associated companies;
(f) any third-party data processor or authorised verification body;
(g) data centres and/or servers, storage facilities and/or records managements companies located within or outside of Malaysia for purpose of storing your Personal Data;
(h) government agencies, law enforcement agents, courts, tribunals, regulatory / professional bodies, if required to do so in satisfaction of any applicable law, regulation, order or judgment; and/or
(i) any other person which requires your Personal Data in order to operate and maintain BIB’s business and/or the FG Wallet and to carry out and complete the Engagement.
10. We will take reasonable measures to procure compliance with this Privacy Policy by any foreign entities handling your Personal Data to adequately protect the confidentiality and privacy of your Personal Data. Except as indicated in this Privacy Policy, it is our strict policy that we must not sell, rent, transfer or disclose any of your Personal Data to any third party without your consent.
F. RETENTION AND DESTRUCTION OF YOUR PERSONAL DATA
11. We will retain your Personal Data for as long as any of the purposes indicated in this Privacy Policy subsists notwithstanding the cessation of your Engagement with us. Thereafter, we will delete from or keep anonymous your Personal Data in our records and system, unless otherwise required to be retained for legal, regulatory, tax or accounting requirements.
12. Notwithstanding the representations made in this Privacy Policy, you acknowledge that transmissions over the internet (e.g. emails/webmails/data transmission) are not secured unless they have been encrypted. As internet communications may be routed through different countries before being delivered, we cannot guarantee a risk-free transmission and do not accept responsibility for any unauthorised access or interception or loss of Personal Data that is beyond our reasonable control.
G. SECURITY OF YOUR PERSONAL DATA
13. In order to ensure that adequate protection and measures are in place to protect your Personal Data, we will use our reasonable endeavours to utilise appropriate software, hardware, programming systems and/or servers and other information technology equipment which we deem suitable and fit for the purpose of storing and securing your Personal Data.
14. Against compliance with the Act, we endeavour to take reasonable and practical measures to mitigate and reduce the risks of unauthorised exposure, destruction, accidental loss, damage and alteration, to your Personal Data by restricting the access of any unidentified or unauthorised third parties to your Personal Data. We may from time to time implement and improve our technical, electronic and procedural security measures to safeguard your Personal Data.
15. The FG Wallet may contain links to external websites. BIB is not responsible for the veracity of such websites and does not substantiate or endorse the content, information, services or any other details contained or featured on such external websites. You are advised to read the terms of use and/or privacy policy of such third-party website(s) before accessing or using these websites.
H. YOUR RIGHTS TO ACCESS YOUR PERSONAL DATA
16. To the extent permitted under the Act and applicable laws, you have the right to request for access to or request for a copy of, your Personal Data for purposes of checking, correcting or updating such Personal Data.
17. Access to your Personal Data or correction of such data can be effected and processed by reaching out to us (i) via the customer support feature on the FG Wallet; or (ii) at our contact details below.
18. Upon receipt of a request for correction of Personal Data from you, we reserve the right to reject and demand that you resubmit your request if such correction cannot be effected due to insufficient information or such correction cannot be verified against the documents requested (as the case may be). Any request for correction of your Personal Data can only be processed and/or carried out by BIB to the extent that BIB has access and/or abilities to correct such Personal Data.
19. Please be informed that, subject to any legal restrictions and/or contractual conditions, you have the right to withdraw your consent to our processing of your Personal Data with reasonable notice by sending an email to us at our contact details below, indicating your intention to withdraw your consent. Please however note that, upon such withdrawal of your consent, we might not be able to continue to serve you and we will construe the withdrawal of consent as your intention to discontinue our Engagement.
I. REFUSAL TO PROVIDE YOUR PERSONAL DATA
20. During the course of our Engagement, it may be obligatory or voluntary for you to provide and for us to collect and process your Personal Data. If the provision of Personal Data is mandatory and you fail, refuse or are unwilling to provide your Personal Data and/or provide your consent to this Privacy Policy, we may not or will not (as the case may be) be able to enter into an Engagement with you.
J. UPDATES TO OUR PRIVACY POLICY
21. BIB reserves the right to review, amend, replace, update or vary any parts of this Privacy Policy from time to time. The most updated version of this Privacy Policy (by indication of the effective date stated therein) will be published on the FG Wallet and once effective, shall prevail over any previous versions. You are advised to check the FG Wallet periodically for the most updated Privacy Policy. Your continued use of the FG Wallet after the effective date of any updated Privacy Policy shall constitute your agreement to such updated Privacy Policy.
K. TRANSLATION
22. This Privacy Policy is prepared and issued in both the English and Malay language in accordance with the Act. In the event of any inconsistency or discrepancy between the versions, the English version shall prevail.
L. OUR CONTACT DETAILS
23. If you have any queries or concerns relating to this Privacy Policy or if you wish to have access to or correct your Personal Data or make a complaint, you may contact us at:
Address |
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The Villa, Lot U0965, Jalan Jumidar Buyong, 87000 FT Labuan, Malaysia. |
Attention of |
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Legal Department |
Email Address |
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