Direct Lending Sdn Bhd and DL Techlab Sdn Bhd (hereinafter referred as “Direct Lending”, “we”, “us” or “our”) is committed to protecting and respecting your privacy.
1. Information collection
1.1. In order to provide a better service to you, we may collect and process the following data about you:
a) information that you provide to us by filling in forms on our site www.directlending.com.my (the “our site”), in person or through other forms of communication. This includes information provided at the time of registering to use our site, applying for loan and related services or requesting further services. We may also ask you for information at other times, for example in processing the loan application, extending or renewal of loan application or other services, in connection with a promotion or when you report a problem with our site;
(b) if you contact us, we may keep a record of that correspondence;
(c) we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
(d) details of transactions you carry out through our site and of the fulfilment of your request;
(e) details of your visits to our site and the resources that you access; and
(f) Personal data that may be obtained from credit reporting agency (whose contact details can be provided upon request) or from the public domain through different channels, e.g. a public register, a public search engine, a public directory or any social networks etc. Device information may be collected from your web browsers.
2. Uses made of the information
2.1. The purposes for which information may be used by us in and outside Malaysia include:
(a) assessing and assisting Financing Providers in assessing the merits and suitability of applicants for loan facilities and related financial services and/or processing and/or approving their applications, renewals and cancellations;
(b) to notify you about important changes and development to the features of the loan facilities;
(c) assisting Financing Providers and other financial institutions to conduct credit checks and to collect debts;
(d) to communicate with you, including responding to your enquiries and/or complaints and resolving disputes, and to improve our services to you;
(e) complying with laws and regulations applicable to us or any of our affiliates in or outside Malaysia;
(f) complying with the internal policies, procedures, measures or arrangements of Direct Lending for the use of data and information and for prevention or detection of money laundering, terrorist financing or other unlawful activities;
(g) comparing data of data subjects or other persons for credit checking, data verification or otherwise producing or verifying data, whether or not for the purpose of taking action against the data subjects;
(h) maintaining a credit history (whether or not there exists any relationship between you and Direct Lending) for present and future reference;
(i) ensuring that content from our site is presented in the most effective manner for you and for your computer;
(j) providing you with alerts, newsletter, education materials or information that you requested or signed up to;
(k) allowing you to participate in interactive features of our service, when you choose to do so;
(l) designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;
(m) legal proceedings, including collecting overdue amounts and seeking professional advices;
(n) researching, designing and launching services or products including seminars/events/forums;
(0) carrying out our obligations arising from any contracts that may be entered into between you and us;
(p) promoting and marketing services and products (please see further details in Clause 2.2 below); or
(q) purposes directly related or incidental to the above.
2.2. We intend to use your data in direct marketing. In this connection, please note that:
(a) your name, contact details (including address, contact number, email address), products and services information, transaction pattern and behaviour, background and demographic data held by us from time to time may be used by us in direct marketing;
(b) the following classes of services, products and subjects may be marketed in direct marketing:
i. credit/loan facilities and other financial services and products provided by us (or our affiliates) and/or third party financial institutions, insurers, securities and investment services providers;
ii. reward, loyalty or privileges programmes, promotional offers and related services; and
iii. invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
2.3. In addition to marketing the above services, products and subjects itself, Direct Lending also intends to provide the data described in paragraph 2.2(a) above to all or any of the persons described in paragraph 2.2(b) above for use by them in marketing those services, products and subjects, and Direct Lending requires your written consent for that purpose.
2.4. Direct Lending intends to receive money or other property or benefit in return for providing the data to the other persons in the manner described in paragraph 2.3.
2.5. We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.
3. Disclosure of your information
3.1. We will keep the personal data we hold confidential but may provide information to:
(a) personnel, agents, advisers, auditors, contractors, Financing Providers, financial institutions, and third party service providers in connection with our operations or services;
(b) credit reporting agencies and, in the event of default, debt collection agencies;
(c) our overseas offices, affiliates, business partners and counterparts (if any);
(d) persons under a duty of confidentiality to us;
(e) persons to whom we are required to make disclosure under applicable laws and regulations in or outside Malaysia;
(f) actual or proposed transferees, participants or sub-participant of our services in or outside Malaysia;
(g) third party financial institutions, insurers, credit card companies, securities, commodities, investment services providers; and external service providers that we may engage for the purposes set out in paragraph 2.2 above, wherever situated.
4.2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
4.3. We use the following cookies:
(a) Strictly necessary cookies. These essential cookies are set throughout our website and are required for the operation of the website to:
i. allow our web server to determine whether the cookies setting on your web browser has been enabled or disabled. This allows us to know whether data can be collected from your web browser;
ii. temporarily allow you to carry information between pages of our website to avoid having to re-enter that information;
iii. temporarily identify your device after you has logged in to a secure page on our website so that our web server can maintain a dialogue with your web browser in order for you to carry out certain activities.
(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(d) Targeting/ advertising cookies. These cookies record your visit to our website, your response to our online advertisements, track the pages you have visited and the website links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests, provide online advertisements or offers on our website or third-party websites which are most likely to interest you and to evaluate the effectiveness of our online marketing and advertising programs. We may also share this information with third parties for this purpose.
4.5. Most web browsers are initially set up to accept cookies. You can choose to ‘not accept’ cookies by changing the settings on your web browser but if you block all cookies, including strictly necessary cookies, you may find that certain features on our Website will not work properly.
4.6. We may use third party web analytic services on the website. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyse how visitors use the website. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the website. These analytic services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.
5.1. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
5.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7. Data transfers
7.1. We may hold your data on servers in Malaysia and any other territories as we see fit from time to time. We may also transfer your data to our overseas offices or to any people listed at Clause 3.1 above, who may be located in or outside of Malaysia.
8. Your consent and rights
8.2. Under the Personal Data Protection Act (the “Act”), individuals have the right:
(a) to check whether we hold personal data about you and to access such data;
(b) to require us to correct as soon as reasonably practicable any data relating to you that is inaccurate;
(c) to ascertain our policies and practices in relation to personal data and the kind of personal data held by us;
(d) to object to the use of your personal data for marketing purposes and we shall not use your personal data for marketing purposes after you communicate your objection to us; and
(e) to request to be informed which items of personal data are routinely disclosed to credit reporting agencies or debt collection agencies, and be provided with further information to enable the making of an access and correction request to the relevant credit reference agency or debt collection agency.
8.3. You may exercise your opt-out right by notifying us if you wish to object to the use of your personal data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to:
Attention: Direct Lending Officer
8.4. In accordance with the terms of the Act, we have the right to and may charge a reasonable fee for processing any data access request.
9. Governing law and jurisdiction
Last updated: 9 September 2016