Updated 3 March 2020

 

Below you will find Vanguard Capital Consulting Sdn Bhd’s Privacy Policy. These policies apply to Vanguard Capital Consulting Sdn Bhd and its affiliated companies (collectively “Vanguard Capital” or “Us”).

 

Vanguard Capital understands that your privacy is important to you and is committed to safeguarding the confidentiality and privacy of personal information entrusted to it.

 

This Privacy Policy describes how Vanguard Capital handles and protects your personal information in connection with the provision of its diverse consulting and advisory services in the fields of promoting Investment Programs and/or Other Related Services ("Service") in compliance with the Personal Data Protection Act 2010 (“PDPA”), Malaysia.

 

This policy applies to personal information which is collected and/or used by Vanguard Capital in its capacity defined by the PDPA and is not intended to cover categories of personal data which are not covered by the PDPA.

 

This policy will tell you how information is collected about you, what your information is used for and who your information is shared with. If any information collected can be used to identify you, Vanguard Capital will take reasonable steps to notify you of that collection.

 

This privacy notice tells you how certain organisations collect information about you, what they use the information for and who they share the information with. If any of those organisations collect information that can be used to identify you, it will take reasonable steps to notify you of that collection.

 

How your information is collected from you

Vanguard Capital will collect information about you directly whenever possible. For example, information Vanguard Capital collects about you may be from but not limited to face to face meetings, emails, instant messaging, and phone calls. Most information about you will be collected from this checklist and from the records Vanguard Capital maintains about Services you receive. Vanguard Capital reserves the right to and may verify the personal data you have provided to us with sources as outlined below and others when necessary.

 

• Central Bank of Country of Origin

• Designated Financial Institutions

• Disclosure from Employers

 

Alternatively, if Vanguard Capital has contacted you through email newsletters, you may use the unsubscribe function in that email to notify Vanguard Capital that you do not want to receive further marketing information through email. This function is available in all Vanguard Capital’s newsletters.

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How your information is collected from others

Under certain circumstances, Vanguard Capital will collect information about you from other sources as the PDPA permits. Vanguard Capital will do this only if it’s reasonably necessary to do so, for example, where:

 

• Further information is required about the liability/guarantee you have disclosed to us.

• Vanguard Capital is not able to get hold of you. This requires us to rely on publicly available information to update your contact details.

• Your information is required. To comply with government legislation, financial institution guidelines, and related professional advice.

 

When the law authorises or requires a collection of your information

There are laws that affect organisations that may require us to collect personal information about you.

 

How your information may be used

Vanguard Capital may use information about you for purposes including:

 

• giving you information about Investment Programs and/or Other Related Services;

• assisting you to prepare beforehand to plan ahead of any application;

• promoting to your other related products and services which may be of interest to you, unless you tell us not to;

• to carry out required processing to help you prepare for Investment Programs and/or Other Related Services that you have an interest in;

• performing of administrative and operational tasks;

• preventing or investigating any fraud or crime or any suspected fraud or crime;

• as required by law, regulation or codes binding it; and

• any purpose to which you have consented.

 

What happens if you don’t provide your information

If you don’t provide your information to Vanguard Capital, it may not be possible:

 

• to effectively carry-out our task to help you obtain Services;

• to manage or administer the Services;

• to verify your identity or protect against fraud; or

• to let you know about other related products and/or services which may be of interest to you.

 

What information Vanguard Capital collects about you

• personal data including your name, address, contact numbers, email addresses, credit report and also not limited to job titles; and

• your registration certificates, proof of ownership, and other declarations not limited to and as required.

 

Sharing of your information outside of Malaysia

• Vanguard Capital stores information about you in the cloud including other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country information about you may be held.

• Additionally, your personal information will only be shared to relevant parties to ensure compliance and/or to successfully deliver a Service.

 

Accessing and correcting your Information

At any time you may ask to access and correct information that Vanguard Capital holds about you.

 

In relation to other persons introduced by you

When you introduce to Vanguard Capital other persons such as, but not limited to your accountant, lawyer, customers, and clients for Vanguard Capital to carry out its Service, you will let that other person or organisation know that:

 

• Vanguard Capital may collect information about them as required;

• Vanguard Capital may handle their personal information in accordance with this Policy;

• They may request a copy of this Policy; and

• Gain access to their personal information.

 

CONSENT

By signing this Policy, you consent to:

 

• Vanguard Capital obtaining information about you;

• Vanguard Capital exchanging information about you; and

• Vanguard Capital to verify information about you with relevant parties.

 

Where necessary, I have sought all necessary explanations and/or clarifications from Vanguard Capital before accepting this Policy.

 

To: Vanguard Capital Consulting Sdn Bhd

My agreement to engage Vanguard Capital evidences my understanding and consent to all matters set out in this Policy. By engaging with Vanguard Capital, I confirm acceptance of the terms in this Policy.