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PRIVACY POLICY

Personal Data Protection Act (PDPA)
Privacy Notice

Personal Data Protection Act (PDPA)

Privacy Policy

 (If you are reading this Privacy Policy on behalf of a body corporate/business enterprise which maintains/maintained contractual relationship with GAT Investment Bank Limited this Privacy Statement is intended to be addressed to, without limitation, the individual officers (e.g. authorised signatories/dealer and company secretary), directors, shareholders, beneficial owners (e.g. sole proprietor and partners), guarantor or obligor of the body corporate/business enterprise (the “Relevant Individuals”) and “you” shall be construed accordingly to mean the Relevant Individuals).

At GAT Investment Bank Limited, Company No. LL17328, we value your privacy and strive to protect your personal information in compliance with the laws of Labuan, Malaysia.

Pursuant thereto, this Privacy Policy is designed to explain and elaborate upon some of our policies and principles pertaining to the privacy of your personal information, all of which we have adopted as a sign of our commitment to respecting, maintaining, protecting, and safeguarding the privacy of your personal information.

GAT Investment Bank will only collect, record, hold, use, disclose and store (i.e. "process") use your personal information in accordance with such laws (including the Personal Data Protection Act 2010 and other applicable data protection or privacy laws / regulations), this Privacy Policy and the privacy terms in your agreement(s) with any GAT Investment Bank entity that you may have contracted with.

This Privacy Policy explains:

  • The type of personal information we collect and how we collect it

  • How we use your personal information

  • The parties that we disclose the personal information to

  • The choices we offer, including how to access and update your personal information

Your privacy matters to us, so please take the time to get to know our practices and if you need further information, please contact our Call Centre representatives at +60 15 4600 0334.

For the purposes of this Privacy Policy, please note that:

  • “GAT Investment Bank” refers to GAT Investment Bank Limited and all its related companies, as defined in section 4 of the Labuan Companies Act 1990 and jointly controlled companies, providing financial and other regulated services, excluding companies, branches, offices and other forms of presence operating outside of Malaysia unless and to the extent otherwise stated.

 

  • “Personal information” refers to any information which relates directly or indirectly to you and/or your transactions with us. This information includes your name, address, occupation, contact details, the details of your account(s), the type of products and/or services subscribed to and such other necessary information regarding yourself and your transaction(s) with us. For the avoidance of doubt, please note that this Privacy Policy is applicable only if you are an individual.

 

What Kind of Personal Information We Collect and How We Collect It

To enable us to deal with your inquiries, open and operate an account/facility for you and/or to generally provide you with our products and services, we may need to and/or may be required to process personal information and financial information about you, including but not limited to:

  • personal information including your particulars, static and moving images and biometrics to establish your identity and background;

  • specimen signatures, as well as digital or electronic signatures as defined under the applicable laws and regulations;

  • personal information to establish your financial standing, employment details, creditworthiness and/or suitability for any of our products/services applied for (if required);

  • personal information that you provide when you apply for any of our products and services, including your views or opinions made known to us via feedback or surveys;

  • information about your risk profile, investments, tax and insurance, investment objectives, knowledge and experience and/or business interests and assets;

  • information relating to your activities, habits, preferences, and interests arising from your use of products and services of GAT Investment Bank, our partners or vendors; and/or

  • other electronic data or information relating to you such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of our products and services or as part of their delivery to you.

We may obtain this information from yourself and from a variety of sources, including but not limited to:

  • through your relationship with us, for example information provided by you in application forms, when you operate your account and use our products or services, when taking part in customer surveys, competitions and promotions, and during financial reviews;

  • through your verbal and written communications with us and/or our authorised agents via SMS, phone or mobile device, email, fax, mail, websites or browsers, social media and/or any other appropriate communication channels;

  • from an analysis of the way you use and manage your account(s)/facility(ies) with us, from the transactions you make and from the payments which are made to/from your account(s)/facility(ies);

  • from third parties connected with you, such as employers, joint account holders, security providers, guarantors and indemnitors, subject to your prior consent;

  • from such other sources in respect of which you have given your consent to them disclosing information relating to you and/or where they are not otherwise restricted;

  • from recordings of Closed-Circuit Television (CCTV) installed at our premises;

  • from the Malaysia Department of Insolvency, other relevant governmental authorities and/or law enforcement agencies to ascertain inter alia your current and past financial standing;

  • from other sources (for example from credit reporting/referencing agencies, including but not limited to CCRIS, FIS and/or any other bureaus or agencies established or to be established by Bank Negara Malaysia or any of its subsidiaries, or by any other authorities and/or from any financial institution);

  • information received from insurance claims or other documents; and/or

  • from any information that is supplied and/or collected when you visit our websites and/or download our mobile device applications which may include your device's IP address or from data that is collected via cookies.

We use cookies for several purposes, including to store your preference for certain types of information or products, further analysis for the purpose of providing products and services to you, to improve our products and/or to personalize our services to you. Cookies are small text files that collect information about users and their visit to the web site or use of the app, such as their Internet protocol (IP) address, how they arrived at the web site (for example, through a search engine or a link from another web site) and how they navigate within the web site or mobile application.

You may adjust settings on your browser and/or mobile device so that you will be notified when you receive a cookie or other similar tracking tools. Please refer to your browser documentation to check if the tracking tools have been enabled on your computer and/or mobile device or to request not to receive cookies or to disable cookies if you do not wish to have information collected via the use of cookies. However, do note that if you enable blocking or disabling of cookies, it may limit certain features and functions in your use of our web or mobile sites.

How We Use Your Personal Information

Other than as stated above, we may use your personal information for one or more of the following purposes:

  • to assess your application(s) /request(s) for our products and services;

  • to verify your financial standing;

  • to conduct credit checks (including but not limited to upon an application for credit and upon periodic or special review of the credit which normally will take place one or more times each year) and obtaining or providing credit references;

  • to manage and maintain your account(s) and facility(ies) with us;

  • to better manage our business and your relationship with us;

  • to better understand your current and future investment needs and your financial situation;

  • to market and to provide you with information on our and selected third parties products, services, offers and/or contests which may be of interest to you (in respect of which we may or may not be remunerated) including but not limited to wealth management and related services and products and services and products offered by our co-branding and partners (the names of such partners will be provided during the application of the relevant services and products, as the case may be) and in this respect, to contact you via  short message service (“SMS”), phone or mobile device, email, fax, mail, websites or browsers, social media or messaging, in person and/or any other appropriate communication channels;

  • to improve our products and services and to test, research, analyse and develop new products/ new features of products and/or services;

  • to study how you use the products and/or services (analysis for promoting products/services);

  • to notify you about benefits and changes to the features of products and services;

  • to administer offers, competitions and promotions;

  • to provide you with products and services provided or administered by our agents, affiliates, service providers, contractors (including sub-contractors), merchant and business partners as part of the facilities and benefits granted by us;

  • to respond to your enquiries and complaints and to generally resolve disputes;

  • to update, consolidate and improve the accuracy of our records;

  • 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 research for analytical purposes including but not limited to data mining and analysis of your transactions with us;

  • to meet the disclosure requirements of any law binding on GAT Investment Bank;

  • to create and maintain credit, behavioural and risk related models for automated credit or suitability scoring and/or any purpose relating to audit, compliance and risk management purposes or functions;

  • to analyse your credit and repayment behaviour scoring as part of a lending process;

  • to assess financial and insurance risks;

  • transfer or assign our rights, interests and obligations under any of your agreements with us;

  • to protect or enforce our rights to recover any debt owing to us;

  • to conduct anti-money laundering checks; for crime detection, investigation, prevention and prosecution;

  • to comply with any sanction or law enforcement requirements;

  • to enforce and/or defend any of our rights; and/or

  • for any other purpose that is required or permitted by any law, regulations, guidelines and/or the order of any court and/or relevant regulatory authorities.

Please be assured that we will ask for your consent before using your personal information for a purpose other than those that are set out in this Privacy Policy and in the privacy terms in your agreement(s) with any GAT Investment Bank entities.

Disclosure Of Your Personal Information

As a part of providing you with our products and services and the management and/or operation of the same and/or for any of the purposes as set out in this Privacy Policy in relation to our use of your personal information, you consent and authorise us to disclose information about you and/or your accounts and/or facilities with us (as well as with other entities within the GAT Investment Bank whether in or outside Malaysia) to:

  • other entities within the corporate group of GAT Investment Bank Limited, whether in or outside Malaysia;

  • companies and/or persons that act as our agents, affiliates, service providers, contractors, merchants, business partners, lawyers, auctioneers, valuers and/or professional advisers (including the employees, directors, sub-contractors, service providers, agents and professional advisors of all the aforesaid companies and/or persons);

  • 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;

  • companies and/or organisations that provide services to us in delivering or communicating information about our products and services to you;

  • other banks and/or financial institutions, credit reference agencies, credit reporting agencies registered under the Credit Reporting Agencies Act 2010 or credit bureaus (including those established by Bank Negara Malaysia or any of its subsidiaries), any authority, central depository or depository agent in relation to the securities industry; the police; any other governmental or regulatory and authority or body, Cagamas Berhad and/or Credit Guarantee Corporation Berhad, any insolvency department and our appointed debt recovery agents;

  • any other person under a duty of confidentiality to us (including any entities within the corporate group of GAT Investment Bank Limited) which has undertaken to keep such information confidential;

  • any trustees, beneficiaries, administrators or executors;

  • your advisers (including but not limited to accountants, auditors, lawyers, financial advisers or other professional advisers) where authorised by you;

  • any other 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 third party as a result of any restructuring of facilities granted to you or the sale of debts, or the acquisition or sale of any company by GAT Investment Bank, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us;

  • any guarantors or security providers for the facility(ies) granted by us to you;

  • any person intending to settle any moneys outstanding under the facility(ies) granted by us to you;

  • any rating agency, insurer or insurance broker or direct or indirect provider of credit protection;

  • any financial institutions, merchants, VISA International Services Association, MasterCard International Incorporated and other card associations in relation to any credit card and/or debit card issued to you by us;

  • your intermediaries, correspondent and agent bank, clearing houses, clearing or settlement systems, market counterparties and any company you carry out investment services through us;

  • any law enforcement, government, courts, dispute resolution bodies and regulatory bodies including Bank Negara Malaysia and their appointed personnel or party, and/or

  • any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us, subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to the GAT Investment Bank (whether in or outside Malaysia). The afore-mentioned third parties may in some instances be located outside of Malaysia.

Marketing

There may be instances which we may share non-personally identifiable information about you to third parties, such as advertising identifiers or one-way coding (eg. cryptographic hash) of a common account identifier, such as a contact number or e-mail address, to enable the conduct of targeted advertising.

Additionally, the individual entities within the GAT Investment Bank, our merchants and strategic partners may contact you about products, services and offers, which we believe may be of interest to you or benefit you financially. Please be informed disclosure to other entities within the corporate group of GAT Investment Bank Limited for cross selling purposes shall not be affected if such disclosure is objected to or declined by you. Further, please also be informed that we will only disclose your personal information (which will not include information relating to your affairs or accounts) to third parties such as our merchants and strategic partners for marketing and promotional purposes where your express prior consent has been obtained and subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to the GAT Investment Bank (whether in or outside Malaysia).

You may tell us at any time if you do not wish to receive direct marketing communications from us, from individual entities within the GAT Investment Bank and/or from our merchants and strategic partners by notifying us at the address / telephone number / e-mail address given at the end of this Privacy Policy. Your latest written instructions to us will prevail. In certain instances where marketing communications from us are sent via browser push to your mobile device, you will have to follow certain prescribed steps to discontinue the receipt of marketing communications from us.

We will treat your personal information as private and confidential and will not disclose your information to anyone outside the GAT Investment Bank except:

  • where you have given your express consent as set out in our application form(s) and/or pursuant to your consent and authorisation as contained in this Privacy Policy and/or in the terms and conditions governing the products and services which you have with us;

  • where we are required or permitted to do so by law;

  • where required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over GAT Investment Bank;

  • where we may transfer rights and obligations pursuant to our agreement(s) with you; and/or

  • where we are required to meet our obligations to any relevant regulatory authority (whether in or outside Malaysia).

Security Of Your Personal Information

Information is our asset and therefore GAT Investment Bank 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 GAT Investment Bank are trained to handle the personal information securely and with utmost respect, failing which they may be subject to disciplinary action.

Retention Of Your Personal Information

GAT Investment Bank will retain your personal information in compliance with this Privacy Policy and/or the terms and conditions of your agreement(s) with GAT Investment Bank entities for the duration of your relationship with us, or as necessary to perform our obligations to you or to enforce or defend the interests of GAT Investment Bank and/or its customers as may be deemed necessary, or as required by applicable law and GAT Investment Bank’s policies in relation to data retention.

What If Personal Information Provided by You Is Incomplete?

Where indicated (for example in application forms or account opening forms), it is obligatory to provide your personal information to us to enable us to process your application for our products or services. Should you decline to provide such obligatory personal information, we may not be able to process your application/request or provide you with our products or services. You shall update us on any changes to your personal information recorded with us.

Your Rights to Access and Correct Your Personal Information

We can assist you to access and correct your personal information held by us.

Where you wish to have access to your personal information in GAT Investment Bank’s possession, or where you are of the opinion that such personal information held by us is inaccurate, incomplete, misleading, or not up to date, you may make a request to us via our Data Access Request Form or Data Correction Request Form respectively. These forms are available via contacting enquiries@gat-money.com.

We will use reasonable efforts to comply with your request to access or correct your personal information within 21 days of receiving your duly completed Data Access Request Form/Data Correction Request Form and the relevant processing fee (if any).

Please note that GAT Investment Bank may have to withhold access to your personal information in certain situations, for example when we are unable to confirm your identity or where information requested for is of a confidential commercial nature or in the event, we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.

Please also note that GAT Investment Bank may use its discretion in allowing the corrections requested and/or may require further documentary evidence of the new information to avoid fraud and inaccuracy.

Please ensure your personal information (such as your mailing address(es), e-mail address(es) and telephone number(s)) recorded with us are current, complete, and accurate. Please notify of any change in your personal particulars via the channels made available by us to ensure that all correspondence and/or communication reach you in a timely manner and to enable us to serve you better.

Exercising Choices Over the Disclosure, Retention and Use of Your Personal Information

Subject always to our contractual rights and obligations under relevant laws and regulations, you may exercise your choice in respect of the disclosure, retention and use of your personal information. Should you wish to do so, kindly contact us at the address/telephone number/ fax number/ e-mail address given at the end of this Privacy Policy.

Please take note that certain communications such as statements of account and our websites contain standard information regarding our other products and services that cannot be removed without affecting the delivery/provision of our services and/or products, the operation of your account(s) and/or facility(ies) with us, and/or additional costs to you.

Revisions To Privacy Policy

This Privacy Policy may be revised from time to time. Policy of any such revision will be given on GAT’s website and/or by such other means of communication deemed suitable by GAT Investment Bank.

Contacting GAT Investment Bank About Your Privacy and How We Handle Your Personal Information

Should you have any query in relation to this Privacy Policy or how we handle your personal information, kindly contact Head of Compliance at the following contact points:

 

Telephone no.:  +60 15 4600 0334

Email:               info@gat-money.com

Addressed to:   Head of Compliance

Address :           GAT Investment Bank Limited

Level 10C (2) Main Office Tower,

Financial Park Labuan Complex,

Jalan Merdeka, Labuan 87000, Malaysia

 

Last Updated: 01 July 2023

Privacy Notice
What & How We Collect
How We Use
Disclosure
Marketing
Security
Retention
Incomplete Information
Your Rights
Exercising Choices
Revisions
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