We, FINEX CAPITAL HOLDING SDN BHD (‘Finex & Co’), respect the privacy of individuals concerning personal data and are committed to protecting the privacy of our agents / estate planners (also known as Finex Estate Planners or “FEPs”), subscribers and their customers (collectively, “Users”). We strive to provide a safe and secure user experience.

This Privacy Policy is formulated in accordance with the Personal Data Protection Act 2010 ("Act"), describing how your information (“Personal Data”) is collected, used, and your choices concerning your Personal Data. For absolute clarity, the terms “we”, “us” and “our” refer to Finex & Co whereas “you” and “your” shall refer to our agents / FEPs or its customers.

Collection of Personal Data

This policy covers the personal data collected through our website and system, used exclusively by our FEPs for will drafting and related estate planning services. Our website servers do not automatically recognize personal details of individual users. The servers also do not record users' email addresses unless the user provides it.

We collect user information during:

• Registration for certain sections of the website
• Participation in activities like contests, forums, and polls
• Use of cookies

When users request pages, the server automatically collects some information, such as the user's IP address, to:

• Help diagnose server issues
• Manage and maintain the website

User-supplied information gathered from registration, surveys, contests, or polls is:

• Used to improve site content
• Utilized for marketing purposes
• Not shared with other organizations for commercial use unless explicitly stated.

Data collected from FEPs may include but is not limited to:

• Name
• Copy of National Registration Identification Card / passport
• Contact details, including mobile phone number, email address, and mailing address
• Tax Identification Number
• Professional and business details related to FEPs registration and training

Data collected from FEPs’ customers may include but is not limited to:

• Name
• National Registration Identification Card number/passport number
• Family and beneficiary details
• Contact information, including phone numbers, email addresses, and mailing addresses
• Information on assets, liabilities, and any related legal documents, such as Insurance Policies, Bank Accounts, Power of Attorney, Birth Certificates, and Death Certificates

How Personal Data is Collected

Personal data is collected from the following sources:

• When FEPs sign up to use Finex & Co’s products and services
• When FEPs submit customer data to our system for will drafting and estate planning purposes
• When attending Finex & Co’s training, seminars, or public talks
• Through direct communication with Finex & Co
• From third-party sources such as regulatory authorities, credit reference agencies, or publicly available information

Purpose of Collecting Personal Data

Personal Data collected through our FEPs is primarily for providing estate planning and will-writing services to clients. This includes, but is not limited to:

• To facilitate the drafting of wills and related estate planning documents based on instructions provided by FEPs and their customers
• For administrative purposes, including billing, financial transactions, accounting, and tax compliance
• To meet legal, regulatory, and statutory requirements
• For communication purposes, including responding to inquiries from FEPs and their customers
• To conduct research and statistical analysis to improve our products and services
• To provide updates on Finex & Co products, services, and legal or procedural changes relevant to estate planning

The information requested by us is necessary; failing which, we will not be able to provide you with the estate planning products, services, and relevant updates or information.

Disclosure of Personal Data

To facilitate the above purposes, we may disclose your personal data within Finex & Co and/or to the following third parties:

• Companies within the Finex & Co Group
• Service providers, consultants, auditors, and advisors who provide services related to the purposes for which the data is collected
• Regulatory authorities and enforcement agencies
• Courts or relevant parties involved in legal proceedings
• Any individual or entity under a duty of confidentiality

Security of Personal Data

Finex & Co is committed to maintaining the security of personal data. We implement appropriate measures to protect data from unauthorized access, use, disclosure, or destruction.

Our websites have security measures in place to protect the loss, misuse and alteration of the information under our control. When a User is asked to provide his/her credit card information, we provide a secure environment through our partners' systems (using industry standard SSL or SET protocols) for this purpose.

For the internet, unfortunately, no data transmission over the internet can be guaranteed as completely secure. While we make every effort to safeguard personal data, we cannot guarantee the security of any information transmitted to us, and individuals share such data at their own risk. Additionally, no method of electronic transmission or storage is entirely secure, so we cannot assure that hackers, cybercriminals, or other unauthorized parties will not bypass our security measures and gain improper access to, steal, or alter your information.

Once we obtain any personal data, we will take reasonable measures to safeguard it from misuse, loss, and unauthorized access, alteration, or disclosure.

A username and password may be necessary to access certain sections of the websites. For your security, we require you to keep this information confidential and update your password regularly (if required).

Nevertheless, Finex & Co will not be responsible for any incidents resulting from unauthorized access to or theft of your personal information or data. We are not responsible for events caused by third parties gaining unauthorized access to or stealing your personal data.

Storage and Retention of Personal Data

Your Personal Data shall be stored either in hard copies in our offices or in servers located in Malaysia. It may be necessary to transfer your Personal Data to third party services providers based/located outside Malaysia. By continuing to use the websites, products and/or services of Finex & Co, you hereby consent to such transfer.

Appropriate contractual safeguards are in place to protect your personal data when it is transferred across broader. We ensure that any third-party service provider to whom we transfer your Personal Data has appropriate contractual safeguards in place to protect your personal data in accordance with equivalent data protection regulations.

Any Personal Data supplied by you will be retained by us as long as necessary for the fulfilment of the Purposes stated in paragraph (3) above or as required to satisfy legal regulatory, accounting requirements or to protect our interests. If you request deletion, we’ll make reasonable efforts to comply, unless legally obligated or for valid reasons. Anonymized or aggregated data derived from your information may be used for statistical or research purposes. When your Personal Data is no longer necessary for the fulfilment of the purposes stated in paragraph (3), we will take reasonable steps to ensure that such data is permanently destroyed or irreversibly anonymized to prevent unauthorized access or use. This includes using secure methods of destruction, such as shredding physical documents and permanently deleting electronic records.

How Email and 'Contact Us' messages are being handled

We may preserve the content of any email or "Contact Us" or other electronic message that we receive. Any Personal Data contained in those messages will only be used or disclosed in ways set out in this Privacy Policy. The message content may be monitored by our service providers or employees for purposes including but not limited to compliance, auditing and maintenance or where email abuse is suspected.

Automatic Collection of Non-Personally Identifiable Data

When you access Finex & Co’s websites or use any of our products or services, we may automatically collect, use, and disclose non-personally identifiable information. This data includes, but is not limited to, details about your internet browser, operating system, domain name of the referring website, number of visits, average time spent on our site, and pages viewed.

We use this non-personally identifiable data to enhance our website's performance, improve our products and services, and optimize content delivery. The data may be shared within Finex & Co or with third parties on an aggregated, anonymized basis. Please note, this data does not identify you personally.

Examples of data we may collect include:

• Device information — such as your hardware model, IP address, other unique device identifiers, operating system version, browser type and settings, such as language and available font settings, and settings of the device you use to access our websites.
• Usage information — such as information about your usage of the websites, products and/or services offered by Finex & Co the time and duration of your usage and other information about your interaction with content offered by Finex & Co, and any information stored using cookies, mobile ad identifiers, and similar technologies that we have set on your device. For detailed information about our use of cookies, web beacons, and other technologies, see Online Tracking and Advertising in paragraph (9) below.
• Location information — such as your computer’s IP address, your mobile device’s global positioning system (GPS) signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain services.

Online Tracking and Advertising

We and any third parties duly appointed/authorized by us to provide content, advertising, or functionality or measure and analyze advertisement performance on our websites (collectively, “Authorized Third Parties”), may use cookies, web beacons, mobile advertising identifiers, and similar technologies to facilitate administration and navigation, to better understand and improve our websites, to enhance your online experience on our websites, to determine and/or improve the advertising shown to you here or within the online sites operated and/or managed by Finex & Co, and to provide you with a customized online experience.

Cookies are small files that are placed on your computer when you visit the websites. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes. For example: Cookies can remember your sign-in credentials so you do not have to enter those credentials each time you visit a website; Cookies can help us and the Authorized Third Parties understand which parts of our websites are the most popular because they help us see which pages and features users access and how much time they spend on the pages. By studying this kind of information, we are better able to adapt our websites and provide you with a better experience; Cookies help us and the Authorized Third Parties understand which advertisements you have seen so that you don’t receive the same advertisement each time you visit our websites.

Most browsers accept cookies automatically but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. If you disable browser cookies or flash cookies, it may interfere with the proper functioning of our websites.

We, along with the Authorized Third Parties, also may use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and third parties use beacons for a variety of purposes, including to analyze the use of the websites and products and/or services offered by Finex & Co and (in conjunction with cookies) to provide content and advertisements that are more relevant to you.

We, along with third parties, may use other kinds of technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and Hypertext Markup Language revision 5 (HTML5) local storage, in connection with our websites. We also may use unique identifiers associated with your device, such as mobile advertising identifiers. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings. For HTML5 local storage, the method for disabling HTML5 will vary depending on your browser. For Flash cookies, information about disabling or deleting information contained in Flash cookies can be found here.

Additional Choices With Respect To Targeted Advertising

As described above, we and the Authorized Third Parties may use cookies and other tracking technologies to facilitate serving relevant advertisements to you. For example, these technologies help us to determine whether you have seen a particular advertisement before, tailor advertisements to you if you have visited our websites before, and avoid sending you duplicate advertisements.

Public Forums

Our websites make information sharing, feedback, forums, and/or message boards available to Users. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your Personal Data. We request that users treat each other with courtesy and mutual respect.

Disclosure of Information

Personal Data held by us will be kept confidential in accordance with this Privacy Policy pursuant to any applicable law that may from time to time be in force. We reserve the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely without further reference to you.

Our websites contain links to other sites that are not operated by Finex & Co. We are not responsible for the privacy practices or the content of such sites. We have established relationships with advertisers and/or business partners but such relationships are generally technical in nature, or content collaborations. If you visit one of these linked websites, you should review the website’s privacy policy, terms and conditions, and other policies. We are not responsible for the policies and practices of third parties. If any advertisers and/or business partners access to any information entered by Users in our database, this fact shall be disclosed to the Users upon initiating the registration process. Users who feel they do not wish their information to be shared by anyone other than the websites may then opt out of completing the registration.

Changes to Privacy Policy

We reserve the right to amend this Privacy Policy from time to time without prior notice. Any changes to the Privacy Policy will be uploaded onto our websites and therefore, we encourage you to check/visit the websites from time to time for any changes on a regular basis.

In the event of conflict between the English and Mandarin versions of the Privacy Policy, the English version of the Privacy Policy shall prevail.

Right of Access to Personal Data

Under the Act, you have the right of access to your Personal Data held by us, which includes the

right to request copies of this data. Additionally, you have the right to request correction of the Personal Data that is inaccurate, incomplete, misleading or not up-to-date. You have the right to request us, as the data user, to stop processing or refrain from starting the processing of your personal data by sending a written notice. This applies if the processing of your personal data is likely to cause significant harm or distress to you or another individual. If you have any questions regarding this Privacy Policy or if you wish to request access to your Personal Data or if you wish to correct your Personal Data or if you wish to withdraw your consent for future marketing communication or if you wish to withdraw your consent for processing of personal data, you may send your request in writing to: Email: admin@finexgroup.my

Consent

Your usage of our website and/or by way of placing your order(s) for our products via online channels, and/or putting any comment and/or feedback and/or entering any online contents through the Company’s online channels including telephonic communication indicates your consent to the use of your personal information data in accordance with this Privacy Policy.