This Privacy Policy explains how Smart Property Solutions Ltd ("SPS") collects, uses, protects, stores and discloses personal information obtained through its website, investor onboarding platform and financial intermediation services.
Smart Property Solutions Ltd ("SPS" or the "Company") is committed to protecting the privacy and confidentiality of personal information entrusted to us by our customers, prospective customers, business partners, website visitors and other stakeholders.
This Privacy Policy explains how SPS collects, uses, stores, protects and discloses personal information in connection with its website, business operations, investor onboarding platform and digital asset brokerage facilitation services.
SPS recognises that protecting personal information is fundamental to maintaining customer confidence and complying with applicable legal and regulatory obligations.
To explain how personal information is collected, processed, protected and retained by SPS while delivering its services.
This Privacy Policy applies to personal information collected through:
This Policy applies to both individual and corporate customers where personal information is processed.
| Term | Definition |
|---|---|
| Company | Smart Property Solutions Ltd (LL14107). |
| Personal Information | Information relating to an identified or identifiable individual. |
| Customer | Includes prospective customers, existing customers, authorised representatives and beneficial owners. |
| Digital Asset | Approved digital assets supported by SPS including Native USDT and Tether Gold (XAUT), where applicable. |
| Wallet | A blockchain wallet approved in accordance with SPS compliance requirements. |
Personal information is processed only for legitimate business, operational, legal and regulatory purposes. SPS does not process personal information for purposes that are incompatible with the purpose for which it was originally collected.
SPS processes personal information only where there is an appropriate legal basis to do so. Depending upon the circumstances, processing may be necessary to fulfil contractual obligations, comply with applicable laws and regulations, protect legitimate business interests, prevent fraud and financial crime, or where consent has been provided by the individual.
| Legal Basis | Examples |
|---|---|
| Contractual Necessity | Providing requested products and services. |
| Legal & Regulatory Obligations | AML, KYC, KYB, sanctions screening and regulatory reporting. |
| Legitimate Business Interests | Fraud prevention, cybersecurity and operational management. |
| Consent | Where consent is required by applicable law. |
Where digital asset related services are provided, SPS may collect information relating to approved blockchain wallets, supported blockchain networks and digital asset transactions for compliance, operational, reconciliation and security purposes.
Wallet information is collected solely to facilitate approved transactions and to comply with applicable legal and regulatory requirements.
To comply with applicable legal and regulatory obligations, SPS may conduct compliance screening before and during the customer relationship. Screening assists SPS in managing financial crime risks and maintaining the integrity of its services.
Customer identity and business verification.
Screening against applicable sanctions lists.
Ongoing monitoring and periodic customer review.
SPS does not sell personal information. Personal information may be disclosed where necessary for legitimate business, legal or regulatory purposes and in accordance with applicable laws and regulations.
Depending on the circumstances, SPS may disclose personal information to the following categories of recipients:
SPS will limit disclosures to information that is reasonably necessary for the relevant purpose and, where appropriate, require recipients to maintain confidentiality and protect the information in accordance with applicable requirements.
SPS takes reasonable and appropriate measures to protect personal information against unauthorised access, disclosure, alteration, loss, misuse or destruction.
The security measures applied by SPS may include appropriate administrative, technical and organisational safeguards, depending on the nature and sensitivity of the information processed.
Access to personal information is restricted to authorised personnel and service providers where access is required for legitimate purposes.
Appropriate safeguards are applied to protect personal information against unauthorised or inappropriate use.
SPS may take appropriate action where a security incident affecting personal information is identified, subject to applicable legal and regulatory requirements.
While SPS takes reasonable measures to protect personal information, no electronic transmission, storage system or online service can be guaranteed to be completely secure.
SPS retains personal information for as long as reasonably necessary to fulfil the purposes for which it was collected, provide relevant services, comply with applicable legal and regulatory requirements, resolve disputes and enforce applicable agreements.
The period for which personal information is retained may vary depending on the nature of the information, the purpose for which it is processed and applicable legal or regulatory obligations.
When personal information is no longer required for the applicable purposes, SPS will take reasonable steps to securely delete, destroy or otherwise dispose of the information, subject to applicable retention requirements.
Subject to applicable laws and regulatory requirements, individuals may have rights in relation to their personal information held by SPS.
These rights may be subject to legal, regulatory, contractual or other applicable restrictions. SPS may require appropriate information to verify the identity of a person making a request before responding.
If you have questions about this Privacy Policy, the handling of your personal information, or wish to exercise any applicable privacy rights, you may contact SPS using the contact details provided below.
Lot 2A, Level 4
Wisma Lazenda
Jalan Kemajuan
87000 Labuan
Malaysia