Last updated: May 2023
At Halogen Capital Sdn Bhd, we value your privacy and strive to protect your personal information in compliance with the laws of Malaysia.
This Private policy explains:
- The type of Data we collect and how we collect it;
- How we use your Data;
- The parties that we disclose the Data to;
- How we store your Data; and
- How we intend to deliver the rights and protection that you are entitled to, including how to access and update your Data
By providing to us your personal information, you hereby consent to the processing of your personal information in accordance with this Privacy Notice.
If you are acting on behalf of a corporation supplying personal information of the corporation’s directors, shareholders, and/or officers to us, please do ensure that you have obtained their consent and bring this Privacy Notice to the attention of the said directors, shareholders and/or officers whose personal information you are supplying/have been supplied to us.
Please further note that by supplying the personal data to us, the corporation is deemed to have warranted that it has obtained or shall obtain the consent of the aforesaid individuals for the processing of their personal data by us.
Personal Information We Collect
Halogen Capital will process your personal data as listed below which have/has been provided by you to Halogen Capital such as:
- Name, identity card number/passport number, and date of birth;
- Contact details including address, phone number(s), and email address;
- Occupation, income and source of wealth; and d. Any other personal data required for the purpose as set out below.
Halogen Capital may obtain your personal data from a variety of sources, including but not limited to:
- When you sign up to purchase our products and services from us or our business partners;
- When you register your interest with us or our business partners to purchase the products and services;
- From third parties connected with you, such as employers, joint account holders, security providers or guarantors, representatives, other partners in your partnership, or through our corporate customers or corporate security providers where you are a director, shareholder, officer, or authorised signatory;
- When you visit our websites or social networking sites;
- Pursuant to any transaction or inquiry or communication made with or to us or our business partners; and/or
- From third-party sources such as credit reference agencies, fraud prevention agencies, publicly available sources of information, industry/financial related associations, social networks, or other organisations.
Halogen Capital may use your personal information for one or more of the following purposes:
- to establish a relationship between you and Halogen Capital and/or companies related to Halogen Capital, Halogen Capital's service providers, business partners, and vendors;
- to assess your application(s) for our products and services;
- for carrying out your instructions and the provision of products and services to you, whether provided personally or through telephone or electronic means, including processing of receipts and payments;
- for the research and development of products and services for customers’ use;
- to evaluate and monitor provision of services;
- to meet legal and regulatory requirements, which may include disclosure, notification, and record retention requirements;
- for audit and risk management;
- to provide you with information on and/or to market Halogen Capital’s products, services, and offers which may be of interest to you;
- third party cryptocurrency (or virtual or digital asset) service providers/ associate/partners to use this information to screen and process a relevant transaction;
- any subcontractors which any of our service providers, agents, suppliers, delegates or contractors may appoint from time to time to provide them with services in connection with the Platform or the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates
- to respond to your enquiries and complaints;
- to produce data, reports, and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
- to conduct anti-money laundering checks;
- for crime detection, prevention and prosecution;
- for any other purpose that is required or permitted by any law, regulations, standards, guidelines, and/or by relevant regulatory authorities;
- for such other purposes that are incidental or ancillary or in furtherance to the above purposes.
We will ask for your consent before using your personal information for a purpose other than those that are set out in this Privacy Notice and the privacy terms of any of your agreement(s) with Halogen Capital.
Disclosure of Your Personal Information
During the provision of our products and services to you and the management and/or operation of the same, we may disclose your personal information (to the extent necessary) to the following third parties:
- Halogen Capital including the directors, officers and dealer’s representatives;
- companies and/or organisations that act as our agents and/or professional advisers;
- companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions that you have requested;
- companies and/or organisations that assist us in providing value added services that you have requested;
- Halogen Capital's advisers (including but not limited to accountants, auditors, lawyers, financial advisers, consultants or other professional advisers);
- Halogen Capital’s merchants and strategic partners;
- any person notified by you as authorised to give instructions or to use the account(s)/facility(ies) or products or services on your behalf;
- any person intending to settle any moneys outstanding under the facility(ies) granted by us to you subject to your prior authorisation; i. any rating agency or credit reporting agency;
- any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us;
- any third party service provider, agent or contractor who have been appointed by us to provide services to us whether in or outside Malaysia subject to sufficient security controls over the information;
- regulatory bodies such as Bank Negara Malaysia, Securities Commission, Bursa Malaysia Securities Berhad, Bursa Malaysia Derivatives Berhad, clearinghouse and other regulatory bodies which have oversight over us and our activities;
- Credit Bureau established by Bank Negara Malaysia;
- any other parties to whom such disclosure is required by law or regulatory requirement or under a Court order; and/or
- any other parties that we may have business or dealings with, subject at all time to any laws (including regulations, guidelines, and/or obligations) applicable to Halogen Capital (whether in or outside Malaysia).
All parties mentioned in above may, in turn, disclose your personal information to other parties such as companies within their group of companies, their affiliates and Directors, shareholders, employees of such companies and affiliates, their professional advisers, service providers, strategic partners, regulators and other parties on a “need to know basis” who or which may have business or dealings with them.
We will otherwise treat your personal information as private and confidential and will not disclose your information to anyone outside the Halogen Capital except:
- where you have given permission and/or otherwise consented;
- where we are required or permitted to do so by law;
- where required or authorised by any order of the Court;
- where we may transfer rights and obligations under an agreement; and/or 6
- where we are required to meet our obligations to any relevant regulatory authority (e.g. Bank Negara Malaysia, Securities Commission, Bursa Malaysia Securities Berhad) and/or under a contract.
Security of Your Personal Information
Your information is our asset and therefore Halogen Capital places great importance on ensuring the security of your personal information. We regularly review and implement up-to-date technical and organisational security measures when processing your personal information.
Employees of Halogen Capital are trained to handle the personal information securely and with strict confidentiality, failing which they may be subject to disciplinary action.
We also impose compliance with this Privacy Notice on our agents, third party service providers, consultants and professional advisors. This serves to ensure that your personal information is safeguarded from unauthorised or accidental loss, misuse, modification, disclosure or destruction.
Retention of Your Personal Information
Halogen Capital will retain your personal information in compliance with this Privacy Notice and/or the terms and conditions of your agreement(s) with Halogen Capital:
- for the duration of your relationship with us;
- for such period as may be necessary to protect the interests of Halogen Capital and/or our customers notwithstanding that your relationship with us has been terminated;
- where otherwise required by the law; and/or
- where required by Halogen Capital’s relevant policies.
Accessing / Correcting / Updating Your Personal Information
You may request for access to, correction, or deletion of your personal information or limit the processing thereof at any time hereafter. Any inquiries or complaints concerning your personal information may also be channelled to Halogen Capital by submitting such request to Halogen Capital via post, email, or facsimile transmission to the following address:
Halogen Capital Sdn Bhd
Email address: firstname.lastname@example.org
Revisions to the Privacy Notice
Our Privacy Notice may be revised from time to time.
Where the Privacy Notice is revised, revised Privacy Notice will be posted on our website halogen.my and/or communicated to you via any other means of communication deemed suitable by us. If you continue to use our services/products, you shall be deemed to have agreed to accept such changes.