Personal Data Protection and Privacy Policy

1.1 This policy (“Privacy Policy”) describes how Airo Platform (“Airo”) manages Personal Data under the Malaysian Personal Data Protection Act (Section 2 of 2010), and currently refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which we have or are likely to have access to.

1.2 By using our services pursuant to your agreement(s) with us (“Services”), operating any account maintained with us, accessing the online platform operated by us (which is accessible through our platform at Airo Website or through our mobile application) (“Platform”), websites or mobile applications, or otherwise providing information to or communicating with us, you are taken to have agreed to our collection, use, processing and disclosure of your Personal Data in accordance with this Privacy Policy.

1.3 This Privacy Policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other rights which we may have at law to collect, use, process or disclose your Personal Data.

1.4 The words “we”, “us”, “our” or any of their derivatives refer to Airo and its successors and any novatee, assignee, transferee or purchaser of Airo’s rights and/or obligations hereunder and any reference to Airo includes a reference to such successor, novatee, assignee, transferee or purchaser. The words “you”, “your”, “yours” or any of their derivatives refer to the person using our Services, operating any account maintained with us, accessing our Platform, website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).

1.5 This Privacy Policy shall be governed by, and construed in accordance with, the laws of Malaysia. Without prejudice to your rights under any applicable laws, any dispute arising out of or in connection with this Privacy Policy and/or the documents referred to herein, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by the Courts of Malaysia and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the Courts of Malaysia.

Airo Privacy Policy

The use of the Website entails various types of personal data being provided for various purposes. Under the Personal Data Protection Act (No. 2 of 2010) (the PDPA), “personal data”means data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access. The PDPA governs and protects the collection, use, disclose and care of personal data. Organisations will have to comply with the PDPA as well as the common law and other relevant laws that are applied in the specific industry that they belong to, when handling personal data in their possession. By accessing the Website and creating a user account with Airo, Users agree and consent to Airo and assigns collecting, using, disclosing personal data in accordance with the Privacy Policy.

1. COLLECTION OF PERSONAL DATA

1.1 Users may browse the Website anonymously. However, Users will have to create a user account in order to start investing towards a portfolio recommended to them.

1.2 When creating a user account with Airo, Users consent to provide their personal data, including but not limited to:

  • name;
  • email address;
  • mailing address;
  • phone number;
  • personal identification; and
  • bank account information.

1.3 Users may create a user account using personal information as provided for on the Website from time to time. In doing so, Users consent to Airo collecting personal data that may be available through social media networks, including but not limited to Facebook.

1.4 Airo may store such personal data for the purposes provided for in paragraph 2 and if applicable, verify such credentials with the relevant social media network.

1.5 If Users provide Airo with any personal data relating to a third party, Users represent to Airo that they have obtained the consent of the third party to provide Airo with such personal data for the purposes stated in paragraph 2.1.

1.6 Users shall ensure that all personal data submitted to Airo is complete and accurate. Any omission or failure to do so may prevent Airo from fulfilling the purposes stated in paragraph 2.

2. USE OF PERSONAL INFORMATION

2.1 Airo uses personal data for the following purposes: i. to personalise User experience and respond to individual needs; ii. to improve and receive feedback on the Website; iii. to improve customer service and provide support services; iv. to send periodic emails, including but not limited to portfolio performance, news, updates and related information.

3. DISCLOSURE

3.1 Airo may disclose personal data to other third-party service providers in connection with the services provided by Airo on the Website and/or Platform. This is, on condition that the disclosed personal data is kept confidential and not further disclosed.

3.2 Airo may disclose personal data for legal purposes (including but not limited to compliance, enforcement of legal rights and obligations and to obtain legal advice).

3.3 Airo employs security measures to protect personal data. All personal data collected on the Website is transmitted via Secure Socket Layer (SSL) technology and then encrypted into the gateway provider where the database will only be accessible by those authorized with special access rights who are required to keep the personal data confidential.

4. COOKIES

4.1 Cookies are small files that a website or service provider transfers to computer hard drives through a web browser that enables the website or service provider systems to recognize the browser and record certain information.

4.2 Airo uses cookies on the Website to record Users usage patterns and trends and customize User experience. Airo may engage third party service providers to assist in such purposes. However, such third party service providers may not disclose personal data obtained in the course of their engagement to any other parties.

4.3 Users may disable the processing of cookies on their web browsers but this may prevent Users from maximising the services provided by Airo.

5. THIRD-PARTY WEBSITES

5.1 Airo shall not be responsible for the collection, use, disclosure and care of personal data by any third party websites linked to the Website.

6. WITHDRAWAL OF CONSENT

6.1 Users may contact Airo at [email protected] to withdraw their consent to the use of personal data by Airo, following which Airo shall cease to further collect, use and disclose personal data of that User.

6.2 Users should be aware that the withdrawal of consent may prevent them from utilising the services provided by Airo.

7. DELETE ACCOUNT AND DATA

7.1 To delete your account from our records, along with any data associated with the account that Airo is not legally required to maintain, please submit your request to [email protected]

8. CHANGES TO PRIVACY POLICY

8.1 Upon any amendments to the Privacy Policy, Airo shall update the Website (https://www.airo.my) and notify Users if it deems the changes substantial.

9. FEEDBACK

9.1 Users may contact Airo at [email protected] if there are any questions or feedback regarding the Privacy Policy.

10. GOVERNING LAW AND JURISDICTION

10.1 The Privacy Policy shall be governed by and in accordance with the laws of Malaysia

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