Privacy Policy

1. Introduction

Silent Aurora Financial Services Sdn Bhd ("we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website silent-aurora.com, use our services, or interact with us in any capacity.

This policy is designed to comply with the Personal Data Protection Act 2010 (PDPA) of Malaysia and other applicable privacy laws. By using our services, you consent to the data practices described in this policy.

2. Information We Collect

2.1 Personal Information

We may collect the following types of personal information:

• Identity Information: Full name, NRIC number, passport number, date of birth, nationality
• Contact Information: Address, phone number, email address
• Financial Information: Income details, employment information, investment objectives, risk tolerance, financial statements
• Transaction Information: Investment transactions, payment information, account balances
• Technical Information: IP address, browser type, device information, cookies, usage data

2.2 Sensitive Personal Data

We may collect sensitive personal data including:

• Bank account and credit card information
• Investment and financial portfolio details
• Health information (where relevant for insurance products)
• Information about family members (for estate planning purposes)

2.3 How We Collect Information

• Directly from you: Application forms, consultations, phone calls, emails
• From third parties: Credit bureaus, fund managers, regulatory bodies
• Automatically: Website usage, cookies, analytics tools
• Public sources: Regulatory filings, public records

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Primary Purposes

• Providing financial advisory and investment services
• Processing investment transactions and maintaining accounts
• Conducting suitability assessments and risk profiling
• Preparing financial plans and investment recommendations
• Communicating with you about your investments and market updates

3.2 Secondary Purposes

• Complying with legal and regulatory requirements
• Preventing fraud and ensuring security
• Improving our services and website functionality
• Marketing relevant financial products and services (with consent)
• Research and analytics for business improvement

3.3 Legal Basis for Processing

We process your personal data based on:

• Consent: Where you have given explicit consent
• Contract: To fulfill our contractual obligations to you
• Legal Obligation: To comply with Malaysian laws and regulations
• Legitimate Interest: For fraud prevention and business operations

4. Information Sharing and Disclosure

We may share your personal information with:

4.1 Service Providers

• Fund management companies and investment platforms
• Banks and financial institutions
• Insurance companies and underwriters
• Technology service providers and cloud storage providers
• Professional service providers (auditors, lawyers)

4.2 Regulatory Bodies

• Securities Commission Malaysia (SC)
• Bank Negara Malaysia (BNM)
• Malaysian Anti-Corruption Commission (MACC)
• Other regulatory authorities as required by law

4.3 Business Transfers

In the event of a merger, acquisition, or sale of business assets, your personal information may be transferred to the acquiring entity, subject to appropriate safeguards.

4.4 Data Protection Requirements

All third parties who receive your personal information are contractually obligated to:

• Maintain confidentiality and security of your data
• Use the information only for specified purposes
• Comply with applicable data protection laws
• Return or destroy data when no longer needed

5. Data Security

We implement comprehensive security measures to protect your personal information:

5.1 Technical Safeguards

• SSL/TLS encryption for all data transmissions
• Advanced firewall and intrusion detection systems
• Regular security audits and vulnerability assessments
• Secure data centers with 24/7 monitoring
• Multi-factor authentication for account access

5.2 Administrative Safeguards

• Access controls limiting data access to authorized personnel only
• Regular employee training on data protection
• Confidentiality agreements for all staff and contractors
• Incident response procedures for data breaches
• Regular review and updating of security policies

5.3 Physical Safeguards

• Secured office premises with access controls
• Locked filing cabinets for physical documents
• Secure disposal of documents containing personal information
• Visitor access controls and monitoring

6. Your Rights Under PDPA

Under the Personal Data Protection Act 2010, you have the following rights:

6.1 Right to Access

You have the right to request access to your personal data that we hold, including information about how we process it.

6.2 Right to Correction

You can request correction of any inaccurate or incomplete personal data we hold about you.

6.3 Right to Withdraw Consent

Where processing is based on consent, you can withdraw your consent at any time, though this may affect our ability to provide certain services.

6.4 Right to Limit Processing

You can request that we limit the processing of your personal data in certain circumstances.

6.5 Right to Data Portability

You can request that we transfer your personal data to another service provider in a structured, commonly used format.

6.6 How to Exercise Your Rights

To exercise any of these rights, please contact us using the details provided in Section 11. We will respond to your request within 21 days as required by the PDPA.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy and as required by law:

7.1 Retention Periods

• Client Records: 7 years after account closure or last transaction
• Transaction Records: 7 years from transaction date
• Communication Records: 7 years from date of communication
• Marketing Consent: Until consent is withdrawn
• Website Analytics: 26 months

7.2 Secure Disposal

When personal information is no longer needed, we securely dispose of it using appropriate methods including:

• Secure deletion of electronic files
• Shredding of physical documents
• Degaussing of magnetic media
• Physical destruction of storage devices

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience:

8.1 Types of Cookies

• Essential Cookies: Required for website functionality
• Performance Cookies: Help us understand how visitors use our site
• Functional Cookies: Remember your preferences and choices
• Marketing Cookies: Used to deliver relevant advertisements

8.2 Cookie Management

You can control cookies through:

• Our cookie preference center
• Your browser settings
• Third-party opt-out tools

For detailed information about our cookie practices, please refer to our Cookie Policy.

9. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately so we can take appropriate action.

10. International Data Transfers

In some cases, we may transfer your personal information outside of Malaysia to:

• International fund managers and investment platforms
• Global technology service providers
• Overseas regulatory bodies (for compliance purposes)

When we transfer personal information internationally, we ensure adequate protection through:

• Adequacy decisions from relevant authorities
• Standard contractual clauses
• Binding corporate rules
• Industry codes of conduct

11. Contact Information

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Post the updated policy on our website
• Update the "Last Updated" date
• Notify you via email or other appropriate means
• Obtain consent for material changes where required by law

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Complaints and Disputes

If you have concerns about how we handle your personal information, you can:

13.1 Internal Complaint Process

1. Contact our Data Protection Officer using the details above
2. We will acknowledge your complaint within 5 working days
3. We will investigate and respond within 21 days
4. If unsatisfied, you can escalate to our senior management

13.2 External Complaints

If you are not satisfied with our response, you may lodge a complaint with:

• Personal Data Protection Department
  Ministry of Communications and Multimedia Malaysia
  Email: [email protected]
  Phone: +60 3-8000 8000