Jada Platform Sdn Bhd (hereinafter, “the Company”, “our”, “us”, “we”, or “Jada”) is a company licensed by the Securities Commission Malaysia under the Capital Markets and Services Act 2007 (“CMSA”) to carry out regulated activities as a Digital Asset Custodian. In the course of the Company carrying out its activities, the Company may collect, record, hold, store or process your personal data pursuant to the statutory requirements of the Personal Data Protection Act 2010 (“PDPA”).

This Privacy Policy describes the manner in which the Company processes Personal Data (as defined in the PDPA) collected from all individuals who browse, use or access our site at http://www.jadaex.com (the “Site”), and/or individuals who register for an account with us and use our services and/or products (collectively, “Users”, “you”, or “your”). 

If you are a corporate entity or an institution, references to the terms “Users”, “you” and “your” shall also include your employees, representatives, authorised persons and agents. If you provide us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can give consent on his/her behalf to the processing of his/her Personal Data, receive on his/her behalf any privacy notice and give consent to the transfer of his/her Personal Data.

We are committed to ensuring the protection of the privacy and security of your Personal Data. By accessing or using any part of our Site, providing us your Personal Data, engaging our services and/or products, registering your interest with us, entering into a commercial transaction or contract with us, or communicating with us, you acknowledge that you have read, understood and agree to the terms of this Privacy Policy and hereby consent to the processing of your Personal Data in accordance with this Policy. 

The specific nature and extend of Personal Data collected may vary depending on the particular services and/or products requested by you and the purposes for which such data is required; however, the Personal Data generally collected for processing includes, without limitation, the following:

1. Information that may be used to identify an individual, such as name, contact details, NRIC/passport number or other identification number (for business/body corporate(s) business/company registration details), nationality (resident or non-resident), gender, race, etc;
2. Financial data or information relevant to your account with Jada including data relating to your accounts with other financial institutions;
3. Employment information obtained from: i) your employers; ii) credit reporting agencies/bureaus and statutory agencies including the Companies Commission of Malaysia and Bank Negara Malaysia; iii) financial institutions such as banks (for example, that arising from the opening or closing of accounts) and related financial service providers; iv) other sources which you have given your consent to share and disclose personal information relating to you; and v) your professional advisers including your tax and legal consultants;
4. Other Personal Data derived from but not limited to: i) Institutional Information, in the context of institutional customers’ supporting documents such as Constitution, Board Resolutions and Letter of Authorisation, Notice of Registered Office or its equivalent (Form 44), Register of Directors or its equivalent (Form 49), Register of Members or its equivalent; Particulars of Share Allotment or its equivalent (Form 24), Specimen Signature Forms; ii) all responses and information gathered from you during the conduct of a suitability or similar assessments carried out by us before any recommendation of any product or services; iii) trust instrument or legal documentation such as Power of Attorney.

Sensitive information is not collected or requested by us and thus will not be processed unless consent is given pursuant to paragraph 40(1)(a) of the PDPA, and such information is necessary for the performance of legal right or obligation or for protection of the User’s interest pursuant to paragraph 40(1)(b) of the PDPA.

We may obtain your personal data from other sources, including from third parties connected with you (e.g. other Users who transact with you), and from such other sources to which you have given your consent to disclose your data.

We may also collect information about you through technology. Such information may include your web browser type, IP address, operating system, domain name, user profiles, geolocation, cookies, technical support records, third-party analytics services etc.

The collection and processing of your personal data is essential for us to provide our services effectively. If you choose not to provide the required personal data, you may be restricted from participating in certain site-related activities or accessing specific features of our services, and we may be unable to effectively provide our products and/or services to you or process your personal data for the relevant purposes as outlined in this Policy.

The Personal Data provided by you, collected from you, or obtained through other necessary sources for the fulfilment of the relevant purposes at the time of collection, may be processed for the following purposes:

1. To assess your application for our products and services (including risks evaluation and review of your portfolio) and subsequent reviews of your account(s) with us;
2. For management of your account (including risk management and audit) and to facilitate the operational processes in order to provide the services and products applied for or requested by you;
3. To comply with relevant local and foreign legal or regulatory requirements (including AMLA checks, compliance and reporting requirements) or as directed by any regulatory or government authorities/agencies including the Securities Commission of Malaysia and Bank Negara Malaysia or as directed by any professional organisations which we are a member or which has oversight over us;
4. For administrative and operational purposes including the maintenance and updating of our records/database, billing/payment purposes and research reporting;
5. For determination of your indebtedness and debt recovery purposes;
6. To keep you duly notified of new products or services and promotions offered by us or our related or affiliated companies by way of various notices and marketing and promotional materials and emails or phone calls;
7. To attend to queries/concerns and investigations of your complaints; and
8. For such other purposes that is incidental or ancillary to the above purposes.

We may request your assistance in obtaining Personal Data of third parties necessary for the processing of your Personal Data for the aforementioned purposes, and you hereby agree to use your best efforts to provide such assistance when requested.

We shall process your Personal Data in compliance with the PDPA, including all applicable regulations, guidelines, and lawful directives, as well as in accordance with this Privacy Policy and any other privacy provisions set forth in agreements or terms of use between you and Jada.

We do not and will not sell, trade, or rent your Personal Data to any other parties. In the course of performing any activities, services, products, features and/or resources rendered in our Site, we may disclose your Personal Data (to the extent where necessary) to the following parties:

1. Our directors, managers, officers and authorised representatives for purposes relating to your application and subscription to our products and services;
2. Any related, affiliated, holding or subsidiaries companies within Jada Group, including those established in the future to facilitate and support the provision of services to you. Jada Group means Jada, its affiliates, subsidiaries, associated entities and any of its offices (together or individually) and “member of the Jada Group” has the same meaning; 
3. Any companies and/or organisations that act as third-party service providers or strategic partners or agents whether in or outside Malaysia who perform certain tasks on our behalf or where disclosure of your Personal Data to them is necessary in order for us to deliver our commitment or obligations to you including but not limited to identity verification, fraud detection and prevention, credit verification, security threat detection, payment processing, information technology and transaction monitoring (subject to adequate security and data protection controls put in place and/or them providing confidentiality undertakings);
4. Regulatory or government authorities such as the Securities Commission of Malaysia, Bank Negara Malaysia, Bursa Malaysia, Inland Revenue Bureau, the Monetary Authority of Singapore and other regulatory (in Malaysia or elsewhere) or any professional organisation of which we are a member or which has oversight over us;
5. As required or authorised by or under any law or by Order of Court or other legal process or regulatory directive issued by a law enforcement agency;
6. Our auditors, legal advisers, tax and other professional advisers; and
7. Parties authorised by you (for example, your authorised person or authorised agent).

Please note that we may anonymise or aggregate your personal data by removing identifiable elements (such as your name) to create data that no longer identifies you individually (“Anonymous Information”). Such Anonymous Information may be used to analyse user behaviour and usage trends, enhance the performance and usability of our website, improve our services, or for internal or third-party market research and reporting purposes. We may also share such Anonymous Information, devoid of any identifiers linking it to you, with our business partners, trusted affiliates, or advertisers, whether located within or outside of Malaysia, for the purposes described above.

Please take note that your Personal Data may be stored or processed to or in locations or systems in jurisdictions outside Malaysia (where necessary to facilitate the provision of our services and products to you) subject to those jurisdictions having similar data protection laws in place and/or our securing reciprocal confidentiality undertakings. Please be assured that we will take all necessary practical steps including but not limited to incorporating reasonable security measures into any equipment in which your Personal Data is stored, to protect your Personal Data from any loss, misuse or unauthorised access or disclosure.

Use of Cookies

We may set and use cookies and other similar technologies on our Site. We do this to help us track your website usage and remember your preferences, to distinguish you from other Users of our Site, to provide you a better experience when you browse our Site, and to improve the Site’s performance and usefulness. The use of cookies and similar technologies is standard across websites and applications through which information is collected about a User’s online activities.

A cookie is a small data file that websites place on your hard drive when you visit a site. A cookie file can contain information such as a user ID that tracks the pages users have visited within that site. The cookies on this are primarily used to recognize that a user has visited the website previously and to track user traffic patterns. We do not correlate this information with data about individual users, nor do we share this information or sell it to any third party.

If you visit our Site when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of cookies and other similar technologies as described herein.

Managing Cookies

If you prefer not to receive cookies through the Site, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. If you want to remove previously stored cookies, you can manually delete the cookies at any time. You can also refuse all cookies by turning these off in your browser.

If you decide to block or turn off all cookies, please be aware that you may not be able to access or use all or parts of the functions on our Sites.

Cookie Expiration

The cookies will remain on a User’s computer after the browser is closed. Until removed, the cookies will become active when the website reopens. Cookies can be deleted by the User, at any time, and will not collect any information when the User is not accessing the Site.

Pursuant to the Credit Reporting Agencies Act 2010, you hereby give your consent to us to obtain and/or disclose any Credit Information relating to you from and/or to our appointed service provider or any source deemed appropriate to verify your credit history as we and/or our appointed service provider or any source deemed appropriate may deem fit under any applicable law, regulation, maintain following purposes (but not limited to): Opening of account, Credit evaluation, Credit/account review, Credit/account monitoring, Debt recovery purposes, Scoring Solutions, Legal documentation and/or action consented to a contract or facility granted. This consent shall remain in full force and effect so long as you maintain any account with us.

You may request for access to your Personal Data and be able to correct that part of your Personal Data which is inaccurate, incomplete, misleading or not up-to-date except where compliance with such a request to access or correction may be refused under the PDPA or other applicable laws or regulations and we may charge a prescribed fee for attending to any written request to access your Personal Data.

Save as aforesaid, you remain responsible for informing us of any changes or updates to your Personal Data provided to us.

Any such requests or inquiries with respect to this matter may be addressed to:

Data Protection Officer

Email address: support@jadaex.com

Jada Platform Sdn Bhd reserves its right to amend or update this Privacy Policy at any time and shall notify you of any such amendments or updates through appropriate means.