Last Updated: 01 September 2025
This Privacy Policy (“Policy”) explains how SOUTH ASIA LINKS LTD. (“Company”, “we”, “us”), incorporated under the Labuan Companies Act 1990, Malaysia, collects, uses, shares, stores, and protects personal information of users (“you”, “Users”) when you access our website, platform, and related services.
By using the website or services, you consent to this Policy and to our Terms & Conditions and AML/CTF Policy.
1) Scope
This Policy applies to information collected through our website and platform (including account creation, KYC/AML verification, support, marketing, and events conducted by us). It does not apply to information collected offline by third parties operating their own sites or services.
2) What We Collect
A. Information you provide (context-dependent):
- Identity & Contact: full legal name, date of birth, nationality, residential address, email, phone.
- Account: username, password, wallet address.
- Verification (KYC/AML): government ID (passport/ID/driver’s license), proof of address, tax ID, visa info, source of funds and wealth (e.g., salary, business income, asset sales, inheritance), employment details, beneficial ownership details (for entities), PEP status, and—where relevant—declarations regarding criminal records subject to applicable law.
- Financial/Payments: payment method details (processed via compliant payment providers); bank/wallet identifiers required to complete transactions.
- Communications: messages to support, survey responses, uploaded files/attachments (e.g., images or screenshots).
B. Information collected automatically
IP address, device and browser characteristics, OS, language, referring/exit pages, timestamps, clickstream data, general location (country/city level), usage logs, interaction events. We also use cookies, pixels, and similar technologies (see “Cookies & Tracking”).
C. Data from third parties / public sources
KYC/AML providers, fraud-prevention databases, public blockchains, publicly available sources, and service vendors supporting our operations.
3) How We Use Your Information
- Provide & operate services: account creation, identity verification, facilitation of tokenization, custodial/non-custodial features, portfolio dashboard, distributions.
- Compliance & security: KYC/AML/CTF, sanctions screening, fraud detection, risk monitoring, lawful requests.
- Communications: service notices, updates, customer support, transactional emails; optional marketing where permitted.
- Improvement & analytics: usage analysis, troubleshooting, product development, site performance.
- Contract & legal obligations: to fulfill agreements with you and meet applicable regulatory requirements.
4) Legal Bases for Processing (GDPR/UK GDPR where applicable)
- Consent (e.g., certain marketing or optional features).
- Performance of a contract (e.g., creating and operating your account, facilitating transactions).
- Legal obligation (e.g., AML/CTF, tax, accounting).
- Legitimate interests (e.g., platform security, fraud prevention, service improvement), balanced against your rights and expectations.
- Vital interests (rare; e.g., preventing harm).
5) Cookies & Tracking
We use cookies/pixels to remember preferences, improve UX, secure sessions, and analyze usage. You can manage cookies in your browser; some features may not function if cookies are disabled. See our Cookies Notice (if separate) for details.
6) Sharing & Disclosures
- We do not sell or rent your personal data. We may share information with:
- Service providers & processors: KYC/AML vendors, hosting/IT, analytics, payment processors, email and support tools—under confidentiality and data-processing terms.
- Affiliates/partners assisting in service delivery, subject to this Policy.
- Regulators, law enforcement, or authorities where required by law or valid legal process.
- Corporate transactions: merger, acquisition, reorganization (data continues to be protected consistent with this Policy).
Links to third-party sites are provided for convenience; their privacy practices are their own—please review their policies directly.
7) International Transfers
Your information may be processed in countries other than your own. Where required, we implement appropriate safeguards (e.g., contractual clauses) to protect your data in cross-border transfers.
8) Data Retention
We retain personal data only as long as necessary for the purposes in this Policy, to meet legal/regulatory requirements (including AML record-keeping), resolve disputes, and enforce agreements. After retention periods, data is securely deleted or anonymized.
9) Security
We use technical and organizational measures—encryption, access controls, network protections, auditing—to safeguard information. You are responsible for maintaining the confidentiality of your account credentials and, where applicable, self-custody wallet keys.
10) Your Rights
Depending on your jurisdiction, you may have rights to:
- Access your data and obtain a copy.
- Rectify inaccurate or incomplete data.
- Erase data (subject to legal/regulatory retention).
- Restrict or object to certain processing.
- Data portability (structured, commonly used format, where applicable).
- Withdraw consent at any time (does not affect prior lawful processing).
- Complain to a data protection authority (e.g., EU/UK/Swiss authorities).
California (CCPA/CPRA) residents may also request:
- Disclosure of categories/specific pieces of personal information collected;
- Deletion of personal information (subject to exceptions);
- To opt out of “sale” or “sharing” of personal information (we do not “sell” personal data as defined by CCPA).
We respond to valid requests within the timelines required by law. To exercise your rights, contact us (see “Contact Us”).
11) Age Requirement
Services are intended for individuals 18+. We do not knowingly collect personal information from persons under 18. If you believe a minor has provided data, contact us and we will take appropriate steps.
12) Automated Decisions & Profiling
If we use automated decision-making (e.g., AML risk scoring), we will ensure it is necessary and proportionate, and—where legally required—provide avenues for review or human intervention.
13) Account Information & Choices
You can review and update certain account details in your profile. If you choose to close your account, we will deactivate or delete it from active systems; some data may be retained as permitted or required by law (e.g., AML, fraud prevention, compliance).
For marketing emails, you can unsubscribe at any time via the link in the message or by contacting us.
14) Changes to this Policy
We may update this Policy from time to time. Updates will appear here with a revised “Last Updated” date. Your continued use after an update indicates acceptance of the revised Policy.
15) Contact Us
SOUTH ASIA LINKS LTD.
Office Suite 1677, Level 16(A)
Main Office Tower, Financial Park Complex Labuan
Jalan Merdeka, 87000, W.P. Labuan, Malaysia
Email: vipdesk@tigerpalace.vip
