MoneyMatch Transfer Platform

Personal Data Protection Policy

This policy is issued by MMB Transfer Sdn. Bhd. (Company No. RC20003428) together with its affiliate companies (including its parent company, MoneyMatch Sdn Bhd [Malaysia]) (“MoneyMatch”) pursuant to the personal data from you and how we process such data. MoneyMatch deals and manages with Personal Data collected by our users as Data Subjects and such Personal Data shall be managed in accordance with this Privacy Policy together with our Terms and Conditions as stated on our site (https://moneymatch.com.bn/terms-and-conditions).

“Personal Data” refers to the information relating to an identified or an identifiable natural person (hereinafter “Data Subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data an online identifier or to one or more factors specific to the physical, physiological, genetic mental economic cultural or social identity of such a natural person obtained by MoneyMatch (together with all its subsidiaries) whether through the MoneyMatch website and/or mobile application (“MoneyMatch platform”) and/or any other medium to which MoneyMatch deems necessary for the purposes of providing its Services to its users and to be in compliance with all relevant legal and statutory frameworks and regulations.

“Controller" is the natural or legal person, authority, organization or other agency that makes decisions individually or together with other parties regarding the purposes and means for processing Personal Data.

“Processor” is a natural or legal person, authority, organization or other agency that processes Person Data on behalf of the Controller.

“Sub-processor” is the contractual partner of the Processor, engaged to carry out specific processing activities on behalf of the Controller.

“Third Party” means a natural or legal person, public authority, agency or body other that the Data Subject, Controller, Processor, Sub-processor, and persons whom under the direct authority of the Controller Process or Sub-processor, are authorised to process Personal Data.

“Services” in this Privacy Policy shall mean the services to which MoneyMatch provides to its users on the MoneyMatch platform (i.e. MoneyMatch Transfer, MoneyMatch Exchange and any other MoneyMatch products) available on the MoneyMatch website or mobile application.

“Our Users” in this Privacy Policy means the individuals and/or businesses that have registered, approved, used and/or transacted on the MoneyMatch platform which shall be the Data Subjects pursuant to this Privacy Policy.

The terms used in this Privacy Policy such as processing, transfer of data, categories of data, personal data breach and technical and organizational measures shall carry their naturally ascribed meaning to them and including their meanings to them in the applicable data protection laws (including but not limited to the Personal Data Protection Act 2010 and General Data Protection Regulations).

This Privacy Policy shall be the Policy which governs the management of the Personal Data of our users throughout the usage of our MoneyMatch Platform (including our requests for information and/or documents) between MoneyMatch and our users of our platform and serves as a supplement to the Terms and Conditions to the Services provided by MoneyMatch.

You as our users hereby acknowledge, confirm and provide consent to MoneyMatch to collect information from you at various points including but not limited to when :-

  1. Our users registers on our site with information of name, email address telephone number, age, date of birth, gender, citizenship, salary range, occupation, phone numbers, mobile device identification, IP address, geo-location, social web information to connect credentials and account information and all other relevant contact information;
  2. Our users uses MoneyMatch’s Services such as account information, bank account details including transaction history with MoneyMatch;
  3. Our users requests for any further information or quotations (wherever applicable);
  4. Our users submits an email to MoneyMatch;
  5. Our users submits identification documents such as National Identification Cards, Passports, Driving Licenses, Visas and or any Proofs of Identity and Proof of Address;
  6. We conduct necessary checks on our users through any forum and/or media and/or database.

The MoneyMatch Platform enables our users the liberty to change and edit their information.

The MoneyMatch Platform uses cookies to distinguish our users from other users of the MoneyMatch platforms. This helps us to provide our users with a good and seamless experience when you browse on our MoneyMatch platforms and to further allow us to improve our sites.

A cookie is a small file of letters and numbers that we store on your browser or to the hard drive of your computer when you agree to the use of cookies. Cookies contain information that is transferred to your computer’s hard drive.

We may use the following cookies for the following purposes :

  1. Cookies for the operation of the MoneyMatch platform – enabling our users to log in to secure areas of our website;
  2. Cookies to recognise and count the number of visitors and how our visitors are navigating around the MoneyMatch platform when our users are using it – enabling us to improve the way MoneyMatch platform works to simplify what our users are finding for;
  3. Cookies to recognise you when you return to the MoneyMatch Platform – enabling us to personalise our content for you and remembering your preferences;
  4. Cookies to record your visit to the MoneyMatch Platform, the pages our users have visited and the links followed – enabling us to display more relevant information to our users.

Our users can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access to all or parts of our MoneyMatch platform.

MoneyMatch as the Controller and Processor shall be responsible for the assessment whether Personal Data can be processed lawfully and for safeguarding the rights of our users. MoneyMatch shall ensure in its area of responsibility that the necessary legal requirements are met (i.e. collecting all necessary consents from our users) so that MoneyMatch can provide the Services in a way that does not violate any applicable law, regulation or rule.

MoneyMatch shall only process Personal Data only for the purposes of the execution of the Services (save for when documented instructions and/or consent is obtained from our user) in all appropriate ways necessary in order to provide its Services and to not cause MoneyMatch to violate any applicable law, regulation or rule.

In the event that a mandatory law prevents MoneyMatch from complying with the instructions of our users or requires MoneyMatch to process and/or disclose the Personal Data to a Third Party, MoneyMatch shall inform our users of such legal requirement as soon as practicable save and except when MoneyMatch is prohibited by law from informing our users of such processing,

All Personal Data received by MoneyMatch in the course of providing its Services is confidential and shall remain confidential to which MoneyMatch shall not provide or make the Personal Data in any other way available to any Third Party without our users prior consent save and except when MoneyMatch uses the Personal Data for the purposes of providing its Services to which the Sub Processors shall abide by MoneyMatch Privacy Policy together with all non-disclosure requirements of confidential information.

MoneyMatch ensures that persons who have access of our users Personal Data (i.e. employees and agents) are only granted access of the same on a need to know basis all of which are under confidentiality obligations with respect to the Personal Data.

MoneyMatch warrants that it maintains and shall continue to maintain appropriate means of technical and organisational measures to protect Personal Data against accidental loss, destruction, damage, alteration, unauthorised disclosure or access in particular where the processing involves the transmission of data over a network and against all other unlawful form of processing.

Taking into account the state of the art, the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, MoneyMatch warrants that appropriate technical and organisational measures have been implemented to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.

MoneyMatch commits that it had implemented the procedure to control and identify unauthorised or illegal access for use of Personal Data. This includes regular testing, assessment for ensuring the security of the Processing on an ongoing basis while being guided by the requirements of the local jurisdictional regulator (i.e. Brunei Darussalam Central Bank).

In the event MoneyMatch receives a complaint, request, enquiry or communication from our users and/or any regulatory bodies relating to the processing of Personal Data or to MoneyMatch’s compliance with the applicable Data Protection Laws, MoneyMatch shall immediately and in any case no later than 7 working days inform our users providing details of the same to the extent legally permitted.

Unless obliged to do so by all relevant laws and regulations, MoneyMatch shall not respond to any request, complaint, enquiry or communication without the prior consent of our users except to confirm that such requests relating to our users and shall provide our users with full co-operation, information and assistance in relation to it including but not limited to the correction, deletion and blocking of Personal Data.

Taking into account the nature of processing, MoneyMatch ensures that appropriate technical and organisational measures in so far as practicable for the fulfilment of MoneyMatch’s obligation to respond to requests for exercising our users rights. In so far as our users consults us directly with regard to the assertion of our users rights, we shall provide any assistance required to ensure compliance with MoneyMatch’s obligations under all applicable data protection laws including imposing any relevant data protection impact assessments especially with regards to high risk processing.

If there are any actual breaches of Personal Data, MoneyMatch shall notify our users of such breach immediately but in no event later than 5 working days after becoming aware of the Personal Data breach and provide reasonable details pertaining to the subject Person Data breach.

Such Personal Data breach notification shall be sent to our users registered email address and shall include at the time of notification or as soon as possible after notification :-

  1. The description of the nature of the Personal Data breach including where possible, the categories and approximate number of data subject concerned as well as the categories and an estimated number of Personal Data records concerned;
  2. The name and contact details of the personnel dealing with our users data for all relevant inquiries;
  3. The description of the likely consequences of the Personal Data breach; and
  4. The description of the measures taken or proposed to be taken to address the Personal Data breach, including, where appropriate, measures to mitigate its possible adverse effects.

MoneyMatch shall provide all necessary information and assistance in relation to any action to be taken in response to such Personal Data breaches under applicable data protection laws

Unless required by mandatory law, MoneyMatch shall not disclose nor publish any statement, communication, notice, press release or report regarding a Personal Data breach, nor data protection authorities without our users’ prior written consent.

If so required by applicable data protection laws, MoneyMatch shall maintain complete, accurate and up to date records of processing activities carried out on behalf of the Controller according to applicable data protection laws and provide those records upon request to MoneyMatch

Where the performance of the Services involves a transfer of Personal Data outside of the European Economic Area, MoneyMatch will take such steps as may be requires to ensure that adequate protection for such Personal Data in accordance to the applicable data protection laws.

Our users also hereby agree that by registering on MoneyMatch platforms, they have consented to receive direct marketing and/or transactional materials from MoneyMatch (i.e. emails, text messages and in-app notifications) and to accept the same which are specifically personalized to our users.

Should our users at any point in time choose to withdraw their consent to our Privacy Policy and/or to have their accounts deleted on the MoneyMatch platforms, kindly inform us of the same via email at <support@moneymatch.com.bn> wherein we shall endeavour to reply to your queries and requests in not less than 3 working days.

Our users have the right to check whether we hold any Personal Data about them, access any Personal Data about our users and require us to correct and/or amend any inaccuracy and/or errors in personal data we hold of our users.

MoneyMatch reserves the rights to amend this Privacy Policy at any time and notice of such amendment will be informed to our users by their registered email addresses or through any other mode MoneyMatch deems appropriate and suitable. By continuing to use our Sites after the changes come into effect means that you agree to be bound by the revised policy.

If you have any questions, comments and/or requests regarding personal data, please call us at +673 222 2012 or email us at <support@moneymatch.com.bn>.