Privacy Policy

Memori and its related corporations (“Memori”, “the Companies”, “we” or “us”) believe strongly in protecting the privacy of your information. We also believe it is important to inform you about how we will use your personal data, and to give you choices about how those data will be used. Please take a moment to read this Data Protection Policy carefully so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to Memori in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use or disclose your Personal Data.

Memori may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Data Protection Policy as updated from time to time on our website. We encourage you to periodically review this Data Protection Policy to be informed on how Memori is handling and protecting your Personal Data.

1. Personal Data

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Memori collecting, using, disclosing and sharing amongst the Companies your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

Examples of Personal Data that we may collect and process are:

1. Personal particulars, including but not limited to your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, and/or date of birth;
2. Personal opinions made known to us from feedback, responses to surveys, or queries;
3. Transactional data; and
4. Any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.

2. Collection of Personal Data

1. Generally, we collect Personal Data in the following ways:

   1. when you submit any form, including but not limited to application, declaration, proposal or referral forms;
   2. when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
   3. when you interact with our staff, including customer service officers, relationship managers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;
   4. when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
   5. when you use our services provided through online and other technology platforms, such as websites and apps, including when you establish any online accounts with us;
   6. when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
   7. when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
   8. when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;
   9. when you use our electronic services, or interact with us via our websites or use services on our websites;
   10. when we seek information about you and receive your Personal Data in connection with your relationship with us, including for products, insurance policies or job applications, for example, from business partners, public agencies, your ex-employer and the relevant authorities; and/or
   11. when you submit your Personal Data to us for any other reason.

2. When you browse our website, you generally do so anonymously but please see section 5 below on cookies. We do not, at our website, automatically collect Personal Data, including your email address unless you provide such information or log in with your account credentials.

3. If you provide us with any Personal Data relating to a third party (e.g. information on your customers, spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data for the respective purposes.

4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

1. Generally, Memori collects, uses and discloses your Personal Data for the following purposes:

   1. responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
   2. verifying your identity;
   3. managing the administrative and business operations of the Companies and complying with internal policies and procedures;
   4. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
   5. matching any Personal Data held which relates to you for any of the purposes listed herein;
   6. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
   7. preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks;
   8. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
   9. project management;
   10. providing media announcements and responses;
   11. organising promotional events;
   12. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
   13. managing and preparing reports on incidents and accidents;
   14. complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
   15. any other purpose relating to any of the above.
   • These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).

2. If you have provided your Mobile number(s) and have indicated that you consent to receiving marketing or promotional information via your Mobile telephone number(s), then from time to time, Memori may contact you using such Mobile telephone number(s) (including via voice calls, text , fax or other means) with information about our products and services (including discounts and special offers).

3. In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4. Disclosure of Personal Data

Memori will take reasonable steps to protect your Personal Data against unauthorised disclosure.

5. Use of Cookies

1. When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

2. Cookies are small text files stored in your computing or other electronic devices which allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.

3. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

6. Data Security

1. Memori will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites, and any transmission of information to us is made at your own risk

2. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

7. Third-Party Sites

1. Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

8. Contacting Us - Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

1. If you:

   1. have any questions or feedback relating to your Personal Data or our Data Protection Policy;
   2. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
   3. would like to obtain access and make corrections to your Personal Data records,
   • Please contact us at contactus@mirath.io or talk to our staff at any of our branches.

2. Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to Memori on your behalf.

3. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Memori may not be in a position to continue to provide its products or services to you, administer any contractual relationship already in place. This may also result in the termination of any agreements you have with Memori, and your being in breach of your contractual obligations or undertakings. Memori 's legal rights and remedies in such event are expressly reserved.

9. Governing Law

This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Brunei Darussalam.