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Privacy Policy

This policy describes the practices of Luminor Capital (Malaysia) Sdn. Bhd. and its subsidiaries and related affiliates [“we”, “us”, or “our”] regarding the handling personal information of our customer’s or other persons to whom this policy apply [or “you” or “your” or “yours”] in accordance with the Personal Data Protection Act 2010 [Act 709], and Personal Data Protection (Amendment) Act 2024 (“Act”).

Under this policy, the term “Personal Data” means information of a living individual including but not limited to name, background, images, addresses, contact numbers, email addresses, IP addresses, operating systems, browser types, contact details, financial data, creditworthiness information, audio recordings, or other data.

Collection Of Personal Data

You may be asked, may have supplied, and may continue from time to time, to provide any personal data generated or from variety of sources, including but not limited to from your submission of your Personal Data when you apply for any of our products and services; from your relationship with us; from recordings of closed circuit television (CCTV) installed at our premises; from any analysis of the way you use and manage your account/facility with us; from publicly available sources or registries; from government authorities, regulatory authorities and/or law enforcement agencies; from third parties or other sources in respect of which you have given your consent to disclose the Personal Data and/or where not otherwise restricted; from advertising, analytics data, crash data, meetings, events, seminars, conferences, talks, road shows, surveys organised or sponsored by us; and/or from any information that is supplied and/or collected when you visit our websites which include your mobile device or computer’s IP address or from any information that is collected via cookies on some of our websites. For the avoidance of doubt, the product interaction data or crash data collected are not linked to the user’s identity and will not be used for tracking purposes.

Usage Of Personal Data

We may disclose your Personal Data to other subsidiaries within our group. These subsidiaries shall treat your Personal Data as confidential, in accordance with this Privacy Policy and all applicable Data Protection legislation and will process such Personal Data only for the Purposes and within the terms set out herein.

The disclosure of your data may involve the transfer of your Personal Data to places outside of Malaysia, and by providing us your Personal Data you agree to such a transfer where it is required to provide you the services you have requested, and for the performance of any contractual obligations you have with us including for storage purposes.

We may need to disclose your Personal Data to the following parties:

  • Our agents, holding companies, subsidiaries, affiliates and associates
  • Professional advisers, contractors, service providers, debt collection agencies and our other agents with whom we have contractual agreements for some of our functions and services
  • Credit bureau, credit reporting agencies, credit reference agencies, rating agencies, insurers and/or insurance brokers
  • Financial service providers in relation to the products and services that you have with us
  • Any actual or potential participants or assignee or transferee of our rights and/or obligations under any transaction between us and you
  • Any guarantor or security provider for the products and/or services granted by us to you
  • Any authorities or regulators, including foreign regulators for the performance of their functions, or any party as required by any law or any government, quasi-government, administrative, court or tribunal
  • Strategic/business partners with whom we have a relationship with for specific products and services
  • Any person connected to the enforcement or preservation of any of our rights under your agreements with us
  • Any party authorized and/or consented by you.

Use And Disclosure

During the course of our service, we may utilise, process and/or disclose your Personal Data for the following purposes in and/or outside Malaysia (“Permitted Purpose”):

  • To assess and process your applications for our products and/or services
  • To communicate with you including responding to your enquiries and/or complaints and resolving disputes
  • To manage and maintain your accounts/facilities with us
  • To conduct credit checks to assess or verify your credit/financial worthiness and to assist other financial institutions to conduct credit checks
  • To evaluate your financial needs
  • To utilize the same for strategic alliances, cross selling, marketing, and promotions
  • To maintain your credit history for present and future references
  • To detect crime or fraud, and to utilize and disclose the same for investigation, prevention, prosecution and compliance with sanctions
  • To respond to the requirements of a civil or criminal legal process and/or for regulatory compliance purpose and/or as required by law or regulation
  • To collect any debt due or owing and to enforce your obligations to us
  • To utilize and disclose the same for market research and statistical analysis and surveys with the aim of improving our products and services and product development
  • To provide you with the information on our and third-party products and services which may be of interest to you
  • To compare information/data for accuracy of our record, and to verify the same with third parties
  • To utilize the same for research, design and improvement of our products and services, operational and business processes
  • To support our business, financial and risk monitoring, planning and decision making
  • To handle complaints and queries
  • To utilize and disclose the same for audit, compliance and risk management
  • To transfer or assign our rights and duties under any governing terms and conditions between us and yourself
  • To utilize the same for our outsourcing of business and backroom operations
  • To utilize and disclose the same for security reasons
  • To transfer your Personal Data to foreign jurisdictions to enable any cross-border transactions, for the performance of a contract, for the purposes of legal proceedings, upon written request from a foreign regulatory or government authority or body, to protect your vital interest or where it is in the public interest to do so
  • For any other purposes that is required or permitted by any law, regulation, order and/or guidelines

Removal of Personal Data

The consent that you have provided us for the collection, usage and disclosure of your Personal Data shall remain valid until such time it is being withdrawn by you in writing. We allow you the opportunity to remove your Personal Data (save for the information which is necessarily retained by us to comply with legal or regulatory requirements, storage purposes, or if there are valid grounds under the law to do so, such as legal claims etc.) from our database or to request for us to cease processing all or part of your Personal Data by giving a written instruction to our Data Officer. We will require a reasonable amount of time to process such notices. Please note that after deleting your Personal Data, we may not be able to provide the same level of service to you as we will not be aware of your preferences.

We reserve the right to take necessary actions if we feel that such removal or cessation would not allow us to provide our products and services or fulfil our obligations in a satisfactory manner. This includes our entitlement to refuse to provide or cease providing any facilities, products or our services to you.

Profiling

We may process some of your data automatically, with the goal of assessing certain personal aspects (profiling). For example, we may use the profiling due to certain legal and regulatory requirements, to combat money laundering, terrorist financing, fraud, assessment of risk and offences that pose a danger to assets.

Enquiries and Complaints

You have the right to object at any time to the processing of your Personal Data for direct marketing purposes, and profiling to the extent related to direct marketing and to the extent permitted under the Malaysian law, and to the processing of your Personal Data for the Permitted Purpose. Any queries, requests, concerns, complaints or exercise of your rights regarding the use of your Personal Data may be raised to:

Customer Success

Tel: +60323801920 / +60323801923

Email: salam@elnuwr.com

In applying for, using or continuing to use our services, including any other contractual relationship which you may have with us, you shall be deemed to have accepted and consented to the terms of this PDP Notice. If you do not consent to the terms herein, kindly contact us at the abovementioned contact details.

Changes To The Privacy Notice

Please note that we may update this Privacy Notice from time to time via posting on our website. You are advised to periodically view our website for any updates or the most current

version of our Privacy Notice. Your continued usage of our services or continued relationship with us shall be deemed as acceptance of any updates, revisions or amendments made to our Privacy Notice.

Where you have requested that we remove or cease the usage of your Personal Data that we have made public and there are valid grounds for such removal or cessation, we will use reasonable and cost-effective steps to inform others that are displaying your Personal Data or providing links to the Personal Data to remove the same.

Consent And Acknowledgement

By providing us with your Personal Data, you hereby consent to the usage, processing and/or disclosure of your Personal Data in accordance with this Privacy Notice. If you are a corporation whereby you have provided/disclosed Personal Data of individual third parties including but not limited to your directors, individual shareholders, employees, authorized signatories, agents, representative or otherwise, you hereby represent and warrant to us that you have the consent of such third parties and are entitled to provide their Personal Data to us to be used, processed and/or disclosed in accordance with this Privacy Notice.

Cookies Policy

As part of the data collection process, we may use Cookies and any other similar technologies to collect your information when you visit or use our website at (website URL)

When you view this Website, we may store some data on your computer in the form of a “cookie” to automatically recognize your personal computer the next time you visit.

The cookies may allow us to tailor our website to better match your interests and/or to store your password to ease you from having to re-enter your password each time you visit our website.

If you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer’s hard drive, block all cookies or to receive a warning before a cookie is stored.

Joint Use and Disclosure to Subsidiaries

We may disclose and jointly use your Personal Data to other subsidiaries within our group strictly for purposes consistent with those communicated to you and consented by you. Our subsidiaries are bound to process and safeguard your Personal Data with strict confidentiality, in accordance to this Privacy Policy and all applicable data protection legislation.

The joint subsidiaries and related corporations of Luminor Capital (Malaysia). Sdn. Bhd. (but are not limited to):

  • Luminor Financial Holdings Limited
  • SA Puncak Management Bhd.
  • El Nuwr Capital Bhd.
  • Luminor Credit Bhd.
  • Luminor Capital Markets Bhd.
  • Luminor Assets Berhad
  • Luminor Finance Ltd.

Restriction Based on Purpose of Use

We are committed to ensuring that the Personal Data collected from you is used only within the necessary scope and strictly for legitimate, clearly defined business, profiling and/or data collection purposes. We will not process, use, and/or disclose your Personal Data beyond the purposes that been communicated and consented to by you, unless such use is required or permitted under applicable laws and regulations, including Personal Data Protection Act 2010 and Amendment Act 2024.

Data Management and Storage

All Personal Data collected from clients is managed and safeguarded exclusively by our Customer Success and Corporate Communications department. Such data is stored in Microsoft Azure Cloud securely and handled with strict confidentiality in accordance with this Privacy Policy.

Policy Review and Amendments

Our Privacy Policy is formulated in accordance with the Personal Data Protection Act 2010, as amended by the Personal Data Protection (Amendment) Act 2024. We reserve the right to review, amend, and/or update this Policy from time to time to ensure compliance with applicable laws and operational requirements. Any amendments shall take effect immediately upon being updated in this Policy.