Privacy Policy

Handal Capital Sdn Bhd (“Handal Capital”, “us”, “we”,” our'') is a private limited company that incorporated in Malaysia.

We provide a platform (the “Platform”) via www.flexcash.com.my (the “Website”) for lending and borrowing transactions conducted between our customers. The Platform and Website are owned and operated by Handal Capital.

1.0 General

  • 1.1 Please read this privacy policy carefully as it sets out the basis on which we collect any personal information from you, or that you provide to us and how we use it in the operation of the Platform.
  • 1.2 This privacy policy covers:
    • (a) visitors to our website (“Guests”); and
    • (b) registered users of the Platform.
  • 1.3 A registered user of the Platform may be a:
    • (a) borrower
  • 1.4 Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

2.0 Contacting us

  • 2.1 If you have any complaints or any questions about any aspect of this privacy policy or your information, or to exercise any of your rights as described in this privacy policy or under data protection laws, you can contact us :

3.0 What information do we collect from users of the Website, including Guests?

  • 3.1 You can browse this Website as a Guest without giving us any information, and we won’t know who you are. However, even if you are a Guest, please bear in mind that we may:
    • (a) record, store and use information about the areas of the Website which you visit and at what times.
    • (b) record, store and use information about your activities in using the Website.
    • (c)  collect information about your computer, such as which browser you are using, your network location, your operating system, your IP address, and the type of connection you are using (e.g., broadband, ADSL etc.); and
  • 3.2 We also collect and store data that you submit to us via email, via our optional surveys, and through our contact form and email subscription sign-up form on the Website.
  • 3.3 We collect the information above by using cookies. Please click here to access our Cookie Policy https://www.flexcash.com.my/cookies-policy/ which explains what cookies we use on our website, why we use them and how you can control them.

4.0  What information do we collect from borrowers?

  • 4.1 Additional services are available once you register with us and log in to the Website. In this case, we will know who you are, your activities on the Website and information about your computer may be linked to you on our systems.
  • 4.2 To provide you with such services, we may collect, store, and use information you upload to the Platform.
  • 4.3 The types of information we may request from you are:
    • (a) contact information – including your name, date of birth, address, postcode, and other contact information such as email address and telephone/mobile number and (where applicable) the contact details of your first of kin.
    • (b) the bank account details to make or receive payments on the Platform.
    • (c) your passwords.
    • (d) your financial interests, financial position, or loan repayment performance.
    • (e) answers to questions required by third party credit reference agencies for identification purposes.
    • (f) information about your activities in using the Website; and
    • (g) information from directors/individuals associated with you and/or your business.
  • 4.4 We may retain copies of the following information about you:
    • a) any correspondence you send us, details of your registration history and any materials you post on the Platform
    • (b) passports or other identification evidence that you provide for anti-money laundering and anti-fraud purposes.
    • (c) records of any surveys that you may be asked to complete for research purposes, although you do not have to respond to them.
    • (d) details of transactions you carry out through the Platform and the receipt and disbursement of repayments.
    • (e) details of your visits to the Website and the resources that you access.
    • (f) where explicit consent has been provided, information about your physical or mental health or condition (where necessary and appropriate); and
    • (g) where explicit consent has been provided, information relating to any criminal proceedings in which you have been involved.
  • 4.5  If you give us false or inaccurate information, either directly or through an agent, and we suspect identify fraud, we will record this.
  • 4.6 We may also be provided with information about you from introducers or other referrers,  who collected that information from you directly.

5.0 What information do we collect from introducers and other referrers?

  • 5.1 If you are an introducer or other referrer, we will collect and may retain the following personal information about you, either as a shareholder or in your capacity as a director of the company providing introducer or other referral services:
    • (a) any correspondence you send us, your name, address, email address and contact numbers; and
    • (b) passports or other identification evidence that you provide for anti-money laundering and anti-fraud purposes.

6.0  Information from other sources

In relation to borrowers only we will also check information about you held on to our records and also obtain information from credit reference agencies about you and your financial associates’ credit behaviour and personal credit accounts.  We will also search fraud prevention agencies for information on you and your financial associates and business partners.

7.0 What do we do with the information we collect from users of the Website?

The main reason we use this information is to provide you with both an improved website experience and details about our products and services. Where it is in our legitimate interest to do so, we (or third-party data processors, agents and subcontractors acting on our behalf) may also use the information:

  • (a) to enrich your experience and interaction with the Website by allowing you to store your details so that your preferences are retained when you revisit the Website.
  • (b) to analyse site usage and improve our services.
  • (c) to deliver to you any administrative notices, alerts, and communications relevant to your use of the services; and
  • (d) to contact you from time to time to inform you about new features, to troubleshoot problems, and to protect you against fraud or other criminal activity.

8.0 What do we do with the information we collect or are provided to borrowers?

Where it is in our legitimate interest to do so, we (or third-party data processors, agents and subcontractors acting on our behalf) may use this information to

  • (a) provide you with details about our products and services.
  • (b) carry out financial and identity checks, fraud prevention checks, regulatory checks, and credit checks, including by using scoring methods.
  • (c) check details on applications for credit and credit related and other facilities.
  • (d) if you do not repay money you have borrowed, to trace your whereabouts and recover debts or enforce a loan agreement.
  • (e) to carry out product development, statistical analysis, and market research.
  • (f) to develop and improve our services and products.
  • (g) to update our records.
  • (h) to advise you about the products and services that we are providing to you in response to a request from you about this.
  • (i) to carry out checks required by applicable regulation or regulatory guidance.
  • (j) to keep you informed about your loan agreements or security documents, as the case may be.
  • (k) to allow you to participate in interactive features of the Website when you choose to do so.
  • (l) to make the Website available to you and to identify the products and services which you may be interested in.
  • (m) for customer service, including answering questions and responding to feedback and complaints; and
  • (n) for any other specific purposes in relation to your activities via the Platform.

In order to provide services and products to you, enter into a contract with you and fulfil our contractual obligations, it may be necessary for us to manage your borrower or lender account with us and update the records we hold about you from time to time.

Where you have given us consent, we shall provide you with information about any new products, services, events, promotions, and other information which we think will be of interest to you. You can withdraw your consent at any time, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences at any time by contacting us via the details given in the “Contacting Us” section above.

9.0  What do we do with the information we collect from introducers and other referrers?

Where it is in our legitimate interest to do so, we (or third-party data processors, agents and subcontractors acting on our behalf) may use this information to:

  • (a) provide you with details about our products and services.
  • (b) carry out financial and identity checks, fraud prevention checks, regulatory checks, and credit checks, including by using scoring methods.
  • (c) carry out product development, statistical analysis, and market research.
  • (d) develop and improve our services and products.
  • (e) to update our records.
  • (f) to carry out checks required by applicable regulation or regulatory guidance.
  • (g) to allow you to participate in interactive features of the Website when you choose to do so.
  • (h) to make the Website available to you and to identify the products and services which you may be interested in.
  • (i) for customer service, including answering questions and responding to feedback and complaints; and
  • (j) for any other specific purposes in relation to your activities via the Platform.

10.0 Who do we share your information with?

  • 10.1 We won’t provide your personal information to other companies for their marketing purposes unless you have given us your consent. However, we may aggregate anonymized information based on your personal information and disclose this to advertisers and other third parties.
  • 10.2 We may disclose your personal information to third parties where it is in our legitimate interest to do so including for the following reasons:
    • (a) we may share your information with analytics and search engine providers that assist us in the improvement and optimisation of our site.
    • (b) We may share your personal information with companies and other third parties performing services on our behalf (for example KYC service providers, credit reference agencies, customer relationship management providers or other service providers) who will only use the information to provide that service. We may also share your personal information with other members of our corporate group, or a purchaser or potential purchaser of our business.
    • (c) we may share alerts and information derived from identity verification checks with third parties for the purpose of anti-money laundering and fraud prevention.
    • (d) We may disclose your personal information on request to the FCA, Financial Ombudsman Service, the police or any other regulator or government authority in order to fulfil our regulatory responsibilities, to help prevent or detect fraud or any other type of crime or for any other reasonable purpose identified by the relevant authority.
  • Where it is necessary for us in order to carry out our obligations arising from any contract entered into with you and to provide services and products to you, we may share your data with staff operating outside the EEA who work for us or for one of our sub-contractors. Your data may be processed by such staff for the fulfilment of your order, the processing of your payment details and the provision of support services.
  • 10.3 Save as set out in this privacy policy, we will not sell or disclose your data to any third party.

11.0 Disclosing information about other individuals

  • 11.1 If you are a joint applicant, or if you have told us of some other financial association that you have with another person (for example financial associates), you represent to us that you are entitled to
    • (a) disclose information about your joint applicant and anyone referred to by you; and
    • (b) authorise us to search, link or record information at the credit reference agencies about you and anyone referred to by you.
  • 11.2 An association will be created by the credit reference agencies between joint applicants and between you and anyone you tell us is financially connected with you. This will link your financial records with that person and those records will be taken into account in all future applications either by you or both of you. This will continue until one of you successfully files a disassociation at the credit reference agencies, i.e., informing them that you are no longer connected financially with a particular individual.

12.0 Your Rights

Access to your information and updating your information

  • 12.1 You have the right to access information which we hold about you. If you so request, we shall provide you with a copy of your personal information which we are processing. For any further copies which you may request, we may charge a reasonable fee based on administrative costs.
  • 12.2 You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another data controller (data portability).
  • 12.3 We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
  • Right to object
  • 12.4 You have the right to object at any time to our processing of your personal information for direct marketing purposes.
  • 12.5 You also have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defence of legal claims.
  • 12.6 In certain circumstances, you have the right to:
    • (a) request the erasure of your personal information erasure (‘right to be forgotten’); and
    • (b) restrict the processing of your personal information to the processing to which you have given your consent or for the establishment, exercise, or defence of legal claims or for the protection of the rights of others.

13.0 Exercising your rights

  • 13.1 You can exercise any of your rights as described in this privacy policy and under data protection laws by contacting us as given in “Contacting us” above.
  • 13.2 Save as described in this privacy policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular, because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
  • 13.3 Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

14.0 Security

  • 14.1 We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
  • 14.2 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.
  • 14.3 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.