1.Introduction
Welcome to Asia Digital Bank Ltd. (“ADB”) (“us” “We” or “our”). ADB is a company incorporated under the Labuan Companies Act 1990 and is regulated by the Labuan Financial Services Authority.

AB operates www.asiadb.com (hereinafter referred to as “Service”).

This Privacy Policy is issued to all ADB’s customers pursuant to the requirements of the laws of Malaysia, including but not limited to the Personal Data Protection Act 2010 (“PDPA”), from whom personal data have been and/or may in future be collected.

This Privacy Policy explains:
(a) The types of Personal Data we collect from you and our methods of collection;
(b)Our usage and process of your Personal Data;
(c)Our disclosure of your Personal Data;
(d)Our transfer of your Personal Data;
(e)Our retention of your Personal Data;
(f)Our security measures over your Personal Data;
(g) Your rights to access and correct your Personal Data retained with us; and
(h)Changes to this Privacy Policy.
We use your data to provide and improve our service. By using our service and providing us your personal data, you hereby consent to the collection, usage, processing, disclosure, transfer, retention of your personal data in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Our terms and conditions (“Terms and Conditions”) govern all use of our service and together with the Privacy Policy constitute your agreement with us (“agreement”).

2.Definitions
SERVICE(S) means the www.asiadb.com website operated by ADB.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

SENSITIVE PERSONAL DATA means any personal data consisting of information as to the physical or mental health or condition of you as a Data Subject, your political opinions, your religious beliefs or other beliefs of a similar nature, your commission or alleged commission by you of offence or any other personal data as the Minister of Communications and Multimedia may determine by way of order announcement.

PROCESSING in relation to personal data means collecting, recording, holding or storing the personal data or carrying out any operation or set of operations on the personal data, including –
(a)the organization, adaptation or alteration of personal data;
(b)the retrieval, consultation or use of personal data;
(c)the disclosure of personal data by transmission, transfer, dissemination or otherwise making available; or
(d)the alignment, combination, correction, erasure or destruction of personal data

USAGE DATA is data collected automatically either generated by the use of service or from service infrastructure itself (for example, the duration of a page visit)

COOKIES are small files stored on your device (computer or mobile device). The term “cookies” refers to cookies, pixels, and similar technologies that may be used by ADB. If you do not accept our use of cookies, you may disable cookies on your device or cease accessing and browsing ADB’s website.

DATA PROCESSORS (OR SERVICE PROVIDERS), in relation to personal data, means any person, other than an employee of the Data User, who processes the personal data solely on behalf of the Data User, and does not process that personal data for any of his own purposes.

DATA SUBJECT is an individual who is the subject of the Personal Data.

DATA USER means a person who either alone or jointly or in common with other persons processes any personal data or has control over or authorizes the processing of any personal data, but does not include a Data Processor.

3.Information Collection and Use
We collect several different types of information for various purposes to provide and improve our service to you.

4. Types of Data Collected
(a)Personal Data
While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
0.1.Email address;
0.2. First name and last name;
0.3.Date of Birth;
0.4.Nationality;
0.5. Race;
0.6. Religious Belief;
0.7.Marital status;
0.8. Phone number;
0.9. Address, Country, State, Province, ZIP/Postal code, City; and
0.10. Health status.

Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. We may also use cookies to assist us in fraud prevention.
If you accept cookies, you will be acknowledging that your information is being collected, stored, accessed and used as outlined in this Privacy Policy.

(b)Usage Data
We may also collect information that your browser sends whenever you visit our service or when you access service by or through any device (“Usage Data”).
This Usage Data may include information such as your computer’s IP address, browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access our service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

5.Use of Data
ADB uses the collected data for various purposes:
0.1 to monitor the usage of our service;
0.2 to detect, prevent and address technical issues;
0.3 to fulfil any other legitimate purpose for which you provide it;
0.4 to provide you with news, special offers and general information about other goods, services and promotional events;
0.5 to support any business, technical, administrative or security function required by AB’s operations;
0.6 to conduct credit checks on you;
0.7 to monitor and review your latest financial status and creditworthiness;
0.8 to update our records and ensure their accuracy;
0.9 to design suitable digital banking products for customers including you;
0.10 to ensure our websites including its content are effective and friendly;
0.11 to understand your products and service requirements;
0.12 to comply with the requirements of any applicable law, regulations, policies, guidelines, requirements and etc;
0.13 to support and facilitate our internal audit and risk management purposes;

6.Retention of Your Personal Data
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.

7.Transfer of Your Personal Data
Your information, including Personal Data, may be transferred to a location outside Malaysia if:
0.1 the Data Subject has given his consent to the transfer;
0.2 the transfer is necessary for the performance of a contract between the Data Subject and the Data User;
0.3 the transfer is necessary for the conclusion or performance of a contract between the Data User and a
third party which –
0.3.1 is entered into at the request of the Data Subject; or
0.3.2 is in the interests of the Data Subject
0.4 the transfer is for the purpose of any legal proceedings or for the purpose of obtaining legal advice or for establishing, exercising or defending legal rights;
0.5 the Data User has reasonable grounds for believing that in all circumstances of the case –
0.5.1 the transfer is for the avoidance or mitigation of adverse action against the Data Subject;
0.5.2 it is not practicable to obtain the consent in writing of the Data Subject to that transfer; and
0.5.3 if it was practicable to obtain such consent, the Data Subject would have given his consent;
0.6 the Data User has taken all reasonable precautions and exercised all due diligence to ensure that the personal data will not in that place be place is Malaysia, would be a contravention of the PDPA;
0.7 the transfer is necessary in order to protect the vital interests of the Data Subject; or
0.8 the transfer is necessary as being in the public interest in circumstances as determined by the Minister.
If you are located outside Malaysia and choose to provide information to us, please note that we transfer the data, including Personal Data, to Malaysia and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
ADB will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

 8.Disclosure of Your Personal Data
At all times, subject to any laws (including regulations, guidelines and/or obligations) applicable to us, we may disclose personal information and data which we collect, or those which you have provide to us, to the following parties:
0.1 Disclosure for Law Enforcement.
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law  or in response to valid requests by public authorities.
0.20 other cases. We may disclose your information also:
0.2.1to our subsidiaries and affiliates;
0.2.2to contractors, service providers, and other third parties we use to support our business. For illustration purposes, “third parties” may include:
0.2.2.1any of our agent, auditors, investment service providers or business partners who assist us in processing, administering, fulfilling transactions or providing services to you on our behalf in connection with the performance of the Services;
0.2.2.2 our external professional advisors and consultants who provide services to us, for the purposes of our business, operational, legal and regulatory requirements;
0.2.2.3 a counterparty to a transaction that is entered into on your behalf;
0.2.2.4 any interested party that requests reasonable information, where you have defaulted in the performance of your obligations under an agreement with us or entered by us on your behalf; and/or
0.2.2.5 any legal, regulatory, governmental, tax, law enforcement or other authorities as required
0.2.3 to fulfil the purpose for which you provide it;
0.2.4 for any other purpose disclosed by us when you provide the information;
0.2.5 with your consent in any other cases;
0.2.6 if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

9.Security of Your Personal Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. However, ADB will exercise all reasonable precautions to ensure that all personal data processed by us is handled with strictest security and confidentiality as required by the applicable laws and regulations.

10.Hyperlinks
Our mobile app (where applicable) and websites may, from time to time, contain links to and from the websites of third parties that are not operated by us. If you click into a link to any of these mobile apps (where applicable) or websites, you will be directed to that third party’s site.
Please note that these mobile apps (where applicable) and websites have their own privacy policies. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services and any Personal Data made available by you on such sites will not have the benefit of this Privacy Policy and will be subject to the relevant third party’s privacy policy (if they have such a policy) Please check these policies before you submit any Personal Data to these mobile apps (where applicable) and websites.
For example, the outlined Privacy Policy has been created using PolicyMaker.io, a free web application for generating high-quality legal documents. PolicyMaker’s online free privacy policy generator is an easy-to-use tool for creating privacy policy template for a website, blog, online store or app.

11.Children’s Privacy
Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).
We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

12.Your Rights to Access and Correct Your Personal Data
You have the right to access and correct your data by contacting and notifying us. This includes requiring us to update or correct or insert or remove any data relating to you which is inaccurate or no longer accurate. You may make your request by contacting us via email as follows:

Asia Digital Bank Ltd
To: Personal Data Protection Department
Email:

13.Language
In the event there are inconsistencies or conflict arising between the English and Chinese versions of the Privacy Policy, the English version shall prevail.

14.Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our webpage and mobile app (where applicable).
We will let you know via email and/or a prominent notice on our service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this webpage and on our mobile app (where applicable).

15.Contact Us
If you have any questions about this Privacy Policy, please contact us by email: info@asiadb.com.

TO: ASIA DIGITAL BANK LTD (“ADB”)

RE: PERSONAL DATA PROTECTION ACT 2010 (PDPA) CUSTOMER CONSENT FORM

I hereby confirm that I have read, agree and understood the terms of the Privacy Policy stated in www.asiadb.com pursuant to the Personal Data Protection Act 2010 (“PDPA”) and consent to the processing of my Personal Data as well as my Sensitive Personal Data in accordance with the Privacy Policy.
Further to the above, I hereby agree to comply with all reasonable requests of ADB to enable ADB to comply with its obligation under the PDPA or other applicable laws, regulations and/or guidelines.
In addition, I further confirm that all Personal Data (including Sensitive Personal Data) that I have provided are all true, up-to-date and accurate. Should there be any changes to any of my Personal Data, I shall notify ADB immediately.

Signature:

Full Name:

National Identity Card Number /Passport Number:

Email Address:

Date: