Privacy Policy Last updated: 24/02/2024
We, referred to as “Us” or “Our,” are dedicated to safeguarding your Personal Data and privacy in compliance with Malaysia’s Personal Data Protection Act 2010 (PDPA).
This Privacy Policy has been crafted to enlighten you on how we manage, collect, store, and utilize the information you provide in connection with the website Theta Nexaflow (the “Website”).
We pledge to uphold the following principles:
•To ensure transparency in the collection and processing of your Personal Data:
We prioritize ensuring you are always fully informed, enabling you to make educated decisions regarding the use of your Personal Data on our Website or when engaging in trades with a third-party trading platform. To achieve this, we utilize a variety of strategies and methods to provide you with pertinent details on how your Personal Data is processed, ensuring this information is delivered accurately and in a timely manner.
Moreover, if it is necessary for us to provide you with specific information, we will ensure it is delivered at the appropriate time and place.
We are also eager to answer any inquiries you may have and to provide any clarification you need, subject to legal constraints. For this purpose, feel free to reach out to us by sending an email to: [email protected]
•To process your Personal Data exclusively for the purposes outlined in this Policy:
The purposes for which we may process your Personal Data include, among others, making the Website available to you and connecting you with third-party trading platforms (the “Services”), to elevate your experience on the Website, to refine the Services (including the Website), to safeguard Our rights and interests, to execute business and administrative activities that bolster the provision of the Services to the Website users, and/or to comply with any legal and/or regulatory obligations.
Moreover, We will process Personal Data about you to better understand your individual needs and preferences.
• To allocate substantial resources in honoring your rights regarding your Personal Data:
We dedicate significant resources to enable you to exercise your rights as a data subject. Thus, you are welcome to reach out to Us at any time should you wish to review Personal Data about you, have Us amend it, delete it, stop using it for specific purposes or altogether, or transfer it to you or a third party. We will act on your requests in accordance with the law.
•To safeguard Personal Data about you:
While We cannot guarantee absolute security of the Personal Data about you, We assure you that We employ and will continue to employ a comprehensive array of methods and measures aimed at ensuring the Personal Data about you is protected.
Our Comprehensive Privacy Policy
1. The Scope?
This Policy outlines the types of Personal Data the Company collects about individuals, and the methods of its collection, usage, sharing with third parties, protection, processing, etc.
In this Policy, “Personal Data” refers to any information relating to an identified or identifiable individual. An identifiable individual is someone who can be identified, directly or indirectly, in conjunction with additional information that We possess or have access to.
In this Policy, the “processing” of Personal Data pertains to any operation or set of operations performed on Personal Data, including the collection, recording, organization, structuring, storage, modification or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or making available, alignment or combination, restriction, erasure, or destruction of Personal Data.
Our Services are designed for a general audience and are not targeted at children under the age of 18. We do not knowingly collect or request information from anyone under 18 or knowingly permit such individuals to access our Services. If We become aware that we have collected information about a child, We will take reasonable measures to remove such information promptly.
2. When Do We Collect Personal Data About You?
We gather Personal Data about you whenever you utilize the Services, engage with the service channels, and visit the Website. Sometimes, you will provide Us with the Personal Data directly, and in other cases, We will collect the Personal Data by examining and analyzing your interaction with Our Services and/or Our service channels or receive your data from our third-party partners.
3. No Obligation To Provide Personal Data To Theta Nexaflow And Its Implications
You are not required to provide Us with any Personal Data about you. However, in certain situations, not providing such Personal Data will hinder Us from delivering the Services to you, will prevent your use of the Website, and/or may cause the Services and the Website to malfunction.
4. What types of Personal Data do We collect? Personal Data We collect upon each visit to the Website:
This information includes online activity logs, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, software crash reports, and type of browser used, as well as information regarding the device you used. Some of this information may not personally identify you, and therefore may not be considered Personal Data.
Personal Data We receive from you: any Personal Data you provide to Us voluntarily when interacting with a third-party trading platform through Us.
Personal Data You specifically provide for submission to third-party platforms to facilitate trading: This encompasses your full name, phone number, and email address.
5. The Objectives for Processing Personal Data and Their Legal Foundations
Theta Nexaflow handles your Personal Data for one or more of the purposes detailed in this section, each backed by the appropriate legal grounds in compliance with Malaysia’s Personal Data Protection Act (PDPA).
Theta Nexaflow will not process your Personal Data unless there is a legitimate legal basis for such actions. The legal bases on which Theta Nexaflow may handle your Personal Data include:
- You have provided consent for the processing of your Personal Data for specific purposes. This applies when you deliberately share your information through the Website, allowing us to submit it to a third-party trading platform.
- Processing is required to serve the legitimate interests pursued by Theta Nexaflow or a third party. For example, this may include enhancing our Services or managing legal claims.
- Processing is necessary to fulfill a legal obligation to which Theta Nexaflow is subject.
If you need further clarification on how processing your Personal Data serves the legitimate interests of Theta Nexaflow or another party, please don't hesitate to contact us via email at any time.
Below, we outline the reasons why we may process your Personal Data, along with the legal justifications for these activities:
| Objective | Legal Foundation | |
| 1 |
To forward your information to third parties at your request for engaging in digital and trading activities. We may gather Personal Data about you to forward it to third parties, should you explicitly request this action. |
You have provided consent for the processing of your Personal Data for one or more specified objectives. |
| 2 |
To address your inquiries, requests, and/or concerns Processing of your Personal Data is necessary to address any inquiries you may have regarding your utilization of our Services. |
Processing is required for the legitimate interests pursued by the Company or a third party. |
| 3 |
To fulfill any legal responsibilities or court and administrative directives We handle your Personal Data to ensure adherence to our diverse legal responsibilities. |
Processing is essential to meet a legal requirement that the Company is obligated to follow. |
| 4 |
To enhance Our Services We may utilize your Personal Data to refine Our Services. This processing includes, among other things, analyzing crash logs or any other malfunction reports related to the Services. |
Processing is essential for the pursuit of legitimate interests by the Company or a third party. |
| 5 |
To prevent fraudulent activities and misuse of Our Services |
Processing is essential for the pursuit of legitimate interests by the Company or a third party. |
| 6 |
To execute and sustain various activities that support the delivery of Our Services Such operations encompass back-office tasks, business development initiatives, strategic planning, oversight processes, and more. |
Processing is required to serve the legitimate interests pursued by the Company or a third party. |
| 7 |
To conduct analyses, including statistical evaluations We apply a variety of analytical techniques, including statistical methods, to inform decisions on a range of matters. |
Processing is required to serve the legitimate interests pursued by the Company or a third party. |
| 8 |
To safeguard Our and third parties' interests, rights, and assets, including the initiation, exercise, or defense of legal claims We may handle your Personal Data to defend Our interests, rights, and assets, or those of third parties, in compliance with any law, regulation, or agreement, including any of Our terms, conditions, and policies. |
Processing is required to serve the legitimate interests pursued by the Company or a third party. |
6. Transfer Of Personal Data To Third Parties
Theta Nexaflow may also disclose your Personal Data to third-party service providers who assist us with storage, hosting, IP address information, user experience analysis, research, and other analytical, technical, and diagnostic services.
Additionally, if you specifically request, we can transmit certain Personal Data about you to third-party trading platforms. In such cases, we will share the information you provide for this purpose with those third parties, and they will handle your Personal Data according to their privacy policies. We may share your Personal Data with several third-party trading platforms.
Theta Nexaflow may also share your Personal Data with its affiliated entities and business partners, who provide resources that enhance and elevate the quality of services and products we offer to our users.
We may disclose your Personal Data to governmental, local, official, and regulatory bodies in Malaysia if such disclosure is necessary to protect our interests, rights, and assets, as well as those of third parties, including the initiation, exercise, or defense of legal claims.
Furthermore, we may release Personal Data about you to potential buyers, investors, or lenders of Theta Nexaflow or any company within our group, or during any similar transaction (such as asset sales), or in connection with any merger, reorganization, consolidation, or bankruptcy of Theta Nexaflow or any related company.
7. Cookies and Third Party Services
We may use certain third-party services, such as analytics providers or advertisement networks on our Website, which may also utilize cookies and similar tracking technologies. The use of such technologies by third parties is subject to their own privacy policies and terms.
A cookie is a small text file placed on your device when you visit or interact with the Website. These cookies allow us to collect information about you and your interactions, helping to improve your user experience by remembering your preferences, customizing content, and providing offers or services relevant to you.
Cookies may also be used to generate statistical insights and conduct analytics.
Some cookies are session-based, meaning they are deleted when you close your browser. Others are persistent cookies, which remain on your device for a set period and help the Website recognize you during future visits.
Types of cookies:
We may use the following types of cookies, categorized by their purpose:
| Type of Cookie | Purpose | Additional Information |
| Strictly Necessary Cookies |
These cookies are required to enable core Website functionality and access to secure areas. They support delivery of requested content, services, and features. For example, these cookies allow smooth page navigation, secure logins, and access to saved settings or previously visited pages. |
These cookies may collect identifiers such as username or last login timestamp, and they expire once the browser session ends. |
| Functionality Cookies | These cookies recognize returning users, storing preferences and language selections to provide a more personalized experience. | Functionality cookies may remain active after the session ends and will persist until their configured expiration date. |
| Performance Cookies | These cookies collect anonymized usage data and statistics that help us monitor the Website’s performance and optimize its functionality. |
These cookies do not identify users directly and vary in duration—some expire upon session end, while others persist longer. |
Blocking and Removing Cookies
You can manage your cookie preferences by adjusting your browser settings to block or delete some or all cookies. Below are helpful resources for popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
Please note that blocking cookies may impact your experience and functionality of certain features on the Website.
ONLINE TRACKING NOTICE
AT THIS TIME, THETA NEXAFLOW DOES NOT RESPOND TO DO-NOT-TRACK SIGNALS.
8. Retention Of Personal Data About You
Theta Nexaflow retains your Personal Data only for as long as necessary to achieve the purposes outlined in this Privacy Policy or to meet any legal, regulatory, or operational requirements under applicable Malaysian or international laws.
Your data may be shared with third-party trading partners for up to 12 months, with the possibility of renewal for another 12 months upon your continued consent.
We perform regular data reviews to determine whether retention is still necessary. Personal Data that is no longer required is securely deleted or anonymized.
9. Transfers of Personal Data To A Third Country Or An International Organization
Your Personal Data may be transferred outside your country of residence, including to jurisdictions that may not offer the same level of data protection. In such cases, Theta Nexaflow applies appropriate safeguards to ensure your data remains secure and your rights are upheld.
For individuals located in the European Economic Area (EEA), any such transfers are made in accordance with the General Data Protection Regulation (GDPR), including, but not limited to:
- Transfers to countries recognized by the European Commission as offering adequate data protection (Article 45(3) GDPR).
- Transfers based on binding agreements between public bodies (Article 46(2)(a) GDPR).
- Transfers in compliance with EU-approved Standard Contractual Clauses (SCCs) (Article 46(2)(c) GDPR). Learn more at:
EU Commission SCCs.
For more information about the safeguards used, please contact us via email: [email protected]
10. Protection Of Your Personal Data
We take your data security seriously. Theta Nexaflow has implemented technical and organizational measures to safeguard your Personal Data from accidental or unlawful loss, misuse, unauthorized access, disclosure, alteration, or destruction.
However, while we take precautions, no system or transmission over the internet can be 100% secure. We cannot guarantee the complete security of your Personal Data during transmission to our systems and disclaim liability for any breach that occurs due to factors beyond our control.
In some instances, we may be required to disclose your Personal Data to government agencies or regulatory bodies, as permitted or mandated by Malaysian or international laws. Once disclosed, we may not control how these authorities handle your information.
11. Links to Third-Party Websites
The Website may contain links to websites and applications operated by third parties. Theta Nexaflow does not control, endorse, or assume responsibility for these external properties or their data practices.
If you choose to interact with third-party websites or applications, we strongly recommend that you review their privacy policies and data collection practices before sharing any Personal Data.
13. Your Rights Regarding Your Personal Data
You have the right to request confirmation about whether Theta Nexaflow is processing your Personal Data, to review such data, to correct any inaccuracies, and to request the deletion of data no longer required by us. You may also limit your consent to specific types of processing.
If you are a resident of the European Economic Area (EEA), please review this section:
You are entitled to exercise the following rights concerning your Personal Data. To do so, please send your request to:
[email protected]
Right of Access
You may request confirmation about whether Theta Nexaflow is processing your Personal Data. If so, you are entitled to access the data along with the following information: (1) purpose of processing; (2) categories of data involved; (3) recipients or third parties to whom your data is or will be disclosed, particularly those outside the EEA; (4) estimated duration of storage, or if unknown, the criteria used to determine it; (5) the right to request rectification or erasure of your Personal Data or to restrict or object to its processing; (6) the right to lodge a complaint with a supervisory authority; (7) source of the data, if not collected from you; (8) use of automated decision-making or profiling; (9) safeguards for cross-border data transfers.
A digital copy of the data may be provided. A reasonable fee may apply for multiple or excessive requests. Your access request must not infringe the rights of others.
Right to Rectification
You can request that Theta Nexaflow correct inaccurate Personal Data or complete incomplete data concerning you, including by providing a supplementary statement.
Right to Erasure (Right to be Forgotten)
You may request deletion of your Personal Data under the following grounds: (a) data is no longer necessary for its original purpose; (b) you withdraw consent and no other legal basis applies; (c) you object to processing based on legitimate interest and there are no overriding interests; (d) you object to processing for direct marketing; (e) data has been processed unlawfully; (f) deletion is necessary to comply with legal obligations.
This right does not apply if the processing is necessary for legal compliance or for the establishment, exercise, or defense of legal claims.
Right to Restrict Processing
You may request restriction of processing where: (a) you dispute data accuracy (for a period of verification); (b) processing is unlawful but you oppose deletion; (c) we no longer need the data, but you require it for legal purposes; (d) you object to processing pending verification of overriding interests; (e) data is processed for direct marketing purposes.
When restricted, we may store your data but will not process it further without your consent, except for legal claims or public interest obligations.
Right to Data Portability
You may receive your Personal Data in a structured, commonly used, and machine-readable format, and request transfer to another entity if processing is based on consent or contract and is performed by automated means.
Where technically feasible, you may request that we transfer the data directly to another controller. This right does not override the rights of others.
Right to Withdraw Consent
You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before it was withdrawn.
Right to Object
You may object to processing of your Personal Data based on legitimate interests, including profiling, unless we demonstrate compelling legitimate grounds that override your interests. You may also object to processing for direct marketing purposes at any time.
You may object to the processing of your Personal Data at any time, particularly if the processing is based on the legitimate interests of Theta Nexaflow or a third party, including profiling based on such interests. Once you object, we will stop processing your data unless we demonstrate compelling legal grounds that override your rights and freedoms or are necessary for legal claims.
Additionally, you may object at any time to the processing of your Personal Data for direct marketing purposes, including related profiling.
Right to Lodge a Complaint with a Supervisory Authority
If you are a resident of the European Union, you have the right to lodge a complaint with a data protection authority in your country concerning the processing of your Personal Data.
Please note that some of the rights described above may be limited under applicable European Union or Malaysian law.
We will respond to your request concerning your rights under this Section 13 within one (1) month of receipt. In cases where the request is complex or numerous, this timeframe may be extended by up to two (2) additional months. You will be notified of any such extension within one (1) month of your request, along with the reason for the delay.
Exercising your rights is generally free of charge. However, if your request is manifestly unfounded or excessive, in particular due to its repetitive nature, we may:
(a) charge a reasonable administrative fee; or
(b) refuse to comply with the request.
Theta Nexaflow may request additional information from you if necessary to confirm your identity before processing your request, especially in cases where we have reasonable doubts regarding the identity of the individual making the request.
14. Updates to This Policy
We reserve the right to update or modify this Privacy Policy from time to time. When changes are made, we will update the "Last Modified" date at the top of the Policy and post the revised version on the Website.
For any material changes, we will take reasonable steps to inform you, such as via email (if available) or through a notice on the Website.
Unless otherwise specified, any changes will take effect immediately upon being published on our Website. We encourage you to regularly review this Policy to stay informed about how we are protecting your data.