T&Cs – Personal Data Management


In this set of terms and conditions, “we”, “us”, “our”, “company” or “NL” means Novel Leap Sdn Bhd. “You”, “your” or “yours” means the persons to whom this set of terms and conditions apply.

Protection of your personal data is important to us. NL has safeguards in place to protect your personal data stored with us. The terms and conditions set herein describes how we may collect, use and manage your personal data.

Types of Personal Data We Collect

“Personal data” is data that can be used to identify a unique person. Following are some types of such personal data:

  1. personal details such as name, date of birth, contact numbers, identity card/passport details residential/mailing addresses;
  2. specimen signature(s)/images and/or thumbprints;
  3. employment details such as occupation, directorships and other positions held, employment history, salary;
  4. personal opinions shared with us through feedback or surveys;
  5. electronic data such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of our services and products or as part of their delivery to you.

How We Use Your Personal Data

We may use your personal data for our business purposes, such as:

  1. developing and providing financial services and products (whether made available by us or through us), including but not limited to:
    1. executing investments, commercial transactions and requests;
    2. carrying out research and statistical analysis;
    3. analytics for the purposes of developing or improving our services and products;
  2. assessing and processing your applications or requests;
  3. communicating with you, including providing you with updates on changes to our services and products (whether made available by us or through us);
  4. managing our infrastructure, business operations and complying with internal policies and procedures;
  5. responding to queries or feedback;
  6. addressing or investigating any complaints or disputes;
  7. verifying your identity for the purposes of providing our services and products;
  8. conducting screenings or due diligence checks as may be required under applicable law or regulation;
  9. complying with all applicable laws and regulations from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
  10. monitoring services and products provided by or made available through us;
  11. enforcing obligations owed to us;
  12. in connection with performance of our duties and obligations when seeking consultancy or professional advice, including legal advice; and/or
  13. administering benefits or entitlements in connection with our business relationship with you.

In addition to the above purposes, we may also use personal data for purposes set out in the terms and conditions that govern our relationship with you.

Use of Personal Data for Marketing Purposes

We may use your personal data to recommend you services or products, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, we will comply with the Personal Data Protection Act of Malaysia (PDPA) and other applicable data protection and privacy laws.

In respect of sending telemarketing messages to your telephone number via short message service, telephone calls (voice or video), facsimile and other mobile messaging services, please be assured that we shall only do so if:

  1. you have provided your clear and unambiguous consent in writing or other recorded form for us to do so;
  2. you have not indicated to us in our ongoing relationship that you do not wish to receive telemarketing messages sent to your telephone number and you have not registered that number with the No Call Registry System (NCRS).

Disclosure and Sharing of Personal Data

We may from time to time and in compliance with all applicable laws on data privacy, disclose your personal data to any personnel of NL or to third parties, whether located in Malaysia or elsewhere, to carry out the purposes set out above. When we disclose your personal data to such parties, we will require them to ensure that any personal data disclosed to them are kept confidential and secure.

An example of such sharing would be for the purposes of providing or offering services or products that might be of interest to you based on your collected information or other data relating to your interactions with NL, our partners or vendors.

For more information about the third parties with whom we share your personal data, you may, where appropriate, wish to refer to the agreement(s) and/or terms and conditions that govern our relationship with you or as our customer.

We wish to emphasise that NL does not sell personal data to any third parties, and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our customer or any applicable law.

We may transfer, store, process and/or deal with your personal data outside Malaysia. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.

Cookies and Related Technologies

Our websites and mobile applications use cookies. A cookie is a small text file placed on your computer or mobile device when you visit a website or use a mobile application. Cookies collect information about users and their visit to the website or use of the mobile application, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or mobile applications. We use cookies and other technologies to facilitate your internet sessions and use of our mobile applications, offer you services and/or products according to your preferred settings, track use of our websites and mobile applications and to compile statistics about activities carried out on our websites and/or through our mobile applications.

A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the website.

You have the choice to set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, do note that when you enable blocking of cookies and pixel tags, it may limit certain features and functions in your use of our websites or applications.

Other Websites

Our websites may contain links to other websites which are not maintained by NL. This privacy policy only applies to the websites of NL. When visiting these third-party websites, you should read their privacy policies which will apply to your use of the websites.

Retention of Personal Data

Your personal data is retained for as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.

Access and Correction

You may request access or make corrections to your personal data held by NL. NL may charge a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you. We may also take a reasonable period of at least 7 business days after receiving your correction request to process and update the change.

There are also other data protection and privacy laws that provides relevant individuals with additional rights including the right to obtain information on how NL processes your personal data, receive certain information provided in an electronic format and/or request that these be transmitted to a third party, withdraw consent to the processing of your personal data, request for your information to be erased, object or restrict the use or processing of your information in some circumstances. These will be subject to ongoing obligations imposed on the company pursuant to any applicable law or regulation, and/or the company’s legitimate reason or entitlement to continue processing your information, and/or to refuse that request.

Where a request is made to withdraw consent, we will inform you of the likely consequences of withdrawing consent and the timeframe to effect the withdrawal. Such requests will be processed within a reasonable timeframe, taking ten business days or more depending on the complexity of the request. In some cases, not providing the personal data, or withdrawing consent to the use, processing, or disclosure of the personal data, may adversely affect NL’s ability to continue our business relationship with you.

Amendments and Updates of NL’s Privacy Policy

We may amend this policy from time to time to ensure that this policy is consistent with any developments to the way NL uses your personal data or any changes to the laws and regulations applicable to NL. We will make available the updated policy on our website (https://prestige.novelleap.com/investor). All communications and dealings with us shall be subject to the latest version of this policy in force at the time.