Privacy Policy

MY E.G. Alternative Payment Services Sdn Bhd (Company No.1188850-D) (“Company”) values privacy and we are committed to protecting all Personal Data (as defined below) kept by us, in accordance with the relevant laws (including the Personal Data Protection Act, 2010 (“PDPA”)). The company is mindful and committed to the protection of your Personal Data and your privacy. By engaging the Company or by interacting or communicating with the Company or using our products and services, you hereby expressly consent to the processing of your Personal Data by and where required disclosed to the Company and the classes of third parties as identified by us in the provision of products and services by the Company to you as outlined. The Company shall have the right to modify, update or amend the terms of this Privacy Notice at any time and from time to time. You hereby agree that you have read, understood and accepted the terms of this Privacy Notice.

This Privacy Notice describes our practices regarding the Personal Data we collect through your download and use of the iPayEasy smartphone and mobile device application (the “App”), your use of or access to the http://www.ipayeasy.com website (together with the App, collectively known as the “Platform”), and all content, products, services and functionality available at or through the aforementioned application and website (together with the Platform, collectively known as the “Services”).

This Privacy Notice explains:

• The type of Personal Data we collect and how we collect it;
• How we use your Personal Data;
• Security of Information;
• Withdrawal Consent
• The parties that we disclose the Personal Data to; and
• The choices we offer, including how to access and update your Personal Data.
  In the event of any conflict between the English and other language version(s), the English version shall prevail.

By engaging the Company or by interacting or communicating with the Company or using our Services, you agree to the terms of this Privacy Notice and you will be deemed to have consented to the collection, use, processing and disclosure of your Personal Data in accordance with this Privacy Notice.

WHAT KIND OF PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

“Personal Data” has the meaning ascribed to it under the Personal Data Protection Act 2010 which includes any information that relates to you or allows someone to identify you, including, for example, your name, address, telephone number, e-mail address, information about your transactions in relation to the Services, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

“Anonymous Information”, means, data that is not associated with or linked to your Personal Data including, aggregated information. Anonymous Information does not, by itself, permit the identification of individual persons.

“Process” has the meaning ascribed to it under the Personal Data Protection Act, 2010.

In order to enable us to provide you these Services we may need to and/or may be required to collect, record, hold, process, use, disclose and store Personal Data and Anonymous Information, including, but not limited to:

Collection of Personal Data

In order for us to provide you with our product and/or Services and to operate in an efficient and effective manner, we may need to collect relevant Personal Data from you either manually or through our Platform. The Personal Data collected by us may be in the form of but it is not limited to name, identity card number, address, bank account details, telephone number, business details or any other information stipulated by the PDPA.

Information you provide to us through your relationship with us, including but not limited to, information provided by you when registering with us, using the Services, when interacting with the merchants, when taking part in customer surveys, competitions and promotions. Examples include:
1. Personal Data from you, such as your first and last name and phone number, when you create an account for our Services, or any other information you directly give us through the Services (including, but not limited to messages that you send through the Services).
2. Information about your interactions with the Services including, your engagement with particular merchants, and the products and services you have purchased.
3. Information you disclose through your interactions with the merchants.
4. Information necessary to complete a transaction through the Services, including your name
5. Information such as files and messages that you store using your iPayEasy Account.

Information collected by technology via the Platform.

For example:

• Information from you, including your web browser type, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, user profiles, and/or a date/time stamp for your visit, and, with respect to your mobile phone, the unique device identifier, better known as the Android ID.

• Information from third party service providers, with your consent, which may include your profile content or other types of personally identifiable information.

• Cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on the Platform. Persistent Cookies can be removed by following web browser’s directions. Please be aware that if you elect not to accept cookies, some parts of our website may not function fully or permit access.

1. Information from corresponding technologies used in connection with mobile phones, including the Android ID, to record date, time, and search and viewing information related to your mobile phone.
2. Information about how you use and interact with the Platform and the Services via third party analytics services such as Google Analytics (https://www.google.com/analytics) or Google AdSense (https://www.google.com/adsense). Such third-party analytics services may use Cookies to gather information such as the pages you visited, your IP address, a date/time stamp for your visit and the sites that redirected you to the Platform.
   

Information from third parties or other sources which you have given your consent to disclose information relating to you and/or where not otherwise restricted.

Information collected from you about others in situations where you decide to invite a third party to create an iPayEasy Account.  We will collect your and the third party’s names and email addresses in order to send an email and follow up with the third party. You should ensure that you are authorised to do so and you agree to inform that person who we are, that we may use and disclose that Personal Data and that they may gain access to it should we hold that information.

HOW WE USE YOUR Personal Data

Purposes of Processing

Our company processes your personal data only for specific and limited purposes.

You agree that all personal data collected and/or processed by our company to respond to requests that you make, or to aid us in serving you better, whether or not through technological means, for one or more of the following purposes:

1. To provide the Services;
2. To identify you as a user in our system;
3. To facilitate the creation of and secure your iPayEasy Account on our network;
4. To assess and process your application for our products and services and settlement of funds;
5. To respond to your enquiries and complaints and to generally resolve disputes;
6. To better manage our business and your relationship with us;
7. To conduct research for analytical purposes including but not limited to data mining and analysis of your transactions with us;
8. For audit, compliance and risk management purposes;
9. To conduct anti-money laundering / counter financing of terrorism checks; for crime detection, prevention and prosecution; to comply with any sanction or regulatory requirements;
10. For any other purpose that is required or permitted by any law, regulations, to facilitate the creation of and secure your iPayEasy Account on our network;
11. To promote our Services; or products, services and special offers of third parties whose products and services we think may be of interest to you;
12. To improve and customize the quality of experience when you interact with our Services;
13. To send offers and promotional materials related to our Services and for other marketing purposes;
14. To track user-specific information on what pages users’ access or visit, conduct survey and research for analytical purpose;
15. To improve and customize the quality of experience when you interact with the Platform, and the Services;
16. For our day to day operations and administrative purposes as well as internal monitoring and controls including account management, billing and collection, audits, reporting and investigations;
17. For the purposes of enforcing or defending our legal rights and/or obtaining legal advice;
18. To assist in the prevention, detection or investigation of crime or possible criminal activities or for the administration of justice;
19. For security and internal / external audit purposes;
20. For such other purposes as may be directed or consented to by you; and
21. For all other purposes in relation to or incidental to the above.

Creation of Anonymous Information. We may also anonymize or aggregate your Personal Data by excluding information (such as your name) that make the data personally identifiable to you. This Anonymous Information may be used to personalize the Services, including directing certain advertisements to make them more relevant to you or to analyse request and usage patterns so that we may enhance the content of the Services and improve the Platform navigation or for any related market research purposes, either internally or through third parties.

We reserve the right to satisfy ourselves as to your identity and personal details. In addition, at the time of your application or at any time in the future, you authorise us to perform identity verification and/or credit checks directly or using relevant third parties.

DISCLOSURE OF YOUR Personal Data

Subject to any laws (including regulations, guidelines and/or obligations) applicable to us and our Affiliates (as defined below) (whether in or outside Malaysia), we may disclose your Personal Data as described below and elsewhere in this Privacy Notice:

• Third Party Service Providers. We may share your Personal Data with third party service providers who may be located within or outside Malaysia (a) to provide you with the Services that we offer you through the Platform; (b) to conduct quality assurance testing; (c) to facilitate creation of accounts; (d) to provide technical support; and/or (e) to provide other services to us. These third-party service providers are not required to use your Personal Data other than to provide the Services requested by user.
• Affiliates and Acquisitions. We may share some or all of your Personal Data with our joint ventures partners or other companies under a common control (our “Affiliates”), in which case we will require our Affiliates to honour this Privacy Notice.
• Social Networking Sites (SNS). The Services may, with your consent, automatically post, information on your SNS profile based on your most recent activities (e.g., you used a coupon to purchase tickets to the newest blockbuster movie). See the section on Third Party Websites below for more information. Advertisements, the advertisers (or the company which the advertiser works with, for example, its advertising agency or an advertising network) may determine certain characteristics about you.
• Other Disclosures. Regardless of any choices you make regarding your Personal Data, we may disclose Personal Data if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights or property or users of the Services;  (d) to investigate or assist us in preventing any violation or potential violation of the laws, this Privacy Notice, or the Terms & Conditions; and/or (e) where we may transfer rights and obligations pursuant to our agreement with you.

We may also be required to transfer your personal data outside of Malaysia for the purposes and to such third parties stated in this Privacy Notice.

Data shared will be for the purpose as stated in this Privacy Notice, or purposes not stated but directly related to the primary purpose of collection.

THIRD PARTY WEBSITES

When you click on a link or, in case of smartphone and mobile device, through any possible gesture to connect to any other website or location, you will leave the Services and be redirected to another site and another entity may collect Personal Data or Anonymous Information from you. We have no control over, do not review, and cannot be responsible for, these external websites or their content. This Privacy Notice do not apply to these external websites or their content, or to any collection of data after you leave our Services and connect to these external websites.

By using the Services, you will also be able to connect with third party services and/or your SNS. By logging-in to your SNS from our Platform, your SNS will provide us a token that allows them to recognize us when we ask, on your behalf, for access to your account information or to post information on your SNS profile. You will be able to revoke our access to any of your SNS at any time by amending the appropriate settings from within your account settings on your applicable SNS, though such revocation may limit the Services we are able to provide you. In addition, when you engage in certain activities within the Services, those activities may be automatically posted to your SNS profile. You will be able to disable this functionality at any time by logging into your SNS profile and selecting the option to disable this feature.

RETENTION AND SECURITY OF YOUR PERSONAL DATA

iPayEasy place great importance on ensuring the security of your Personal Data and will regularly review and implement up-to-date technical and organizational security measures to safeguard the confidentiality and security of all your Personal Data. This includes contractual agreements with relevant third parties, whereby we shall endeavour to procure them to incorporate our standards as a minimum. Your Personal Data will also be retained in compliance with this Privacy Notice and/or the terms and conditions of your agreements for the duration of your relationship with us, for such period as may be necessary to protect our interests as may be deemed necessary, where otherwise required by the law or relevant regulation.

We also require you to enter a password that you should not disclose to anyone, to access your iPayEasy Account information.

Disclaimer: No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we use reasonable efforts to protect your Personal Data, we cannot guarantee its absolute security. All such transmission of information is carried out at your own risk. To protect your account, always keep your password secure and confidential.

YOUR RIGHTS TO ACCESS AND CORRECT YOUR PERSONAL DATA

• Choices. iPayEasy offer you choices regarding the collection, use, and sharing of your Personal Data. Nevertheless, should you decline to provide any Personal Data that is essential to us to enable us to process your application or request (for example for the registration) or communicate with you, we may not be able to process or proceed with your application or request or provide you with this Service or communicate with you.
• Changes to Personal Data. You may have access to or change your Personal Data in our possession or control through your profile within your iPayEasy Account. Any request of access to correct Personal Data may be subjected to a fee and also to the provisions of the applicable laws. We reserve the right to decline requests that jeopardize the security and privacy of the Personal Data of others as well as requests that are impractical or not made in good faith, To avoid confusion, “access” for the purposes of this provision shall mean notification of such personal data of yours that is processed by or on behalf of iPayEasy and to have a copy of such personal data communicated or conveyed to you in an intelligible form of iPayEasy’s choosing.

WHAT IF PERSONAL DATA PROVIDED BY YOU IS INCOMPLETE?

Where indicated (for example, during first-time sign-in for an iPayEasy Account), it is obligatory to provide your Personal Data to us in order to enable us to process your application for an iPayEasy Account, or for us to provide you with our Services. Should you decline to provide such obligatory Personal Data, we may not be able to process your application and/or provide you with our Services or result in us being unable to communicate with you.

ACCEPTANCE OF THE POLICY

You are given notice that the products and/or Services will only be made available to you upon your accepting and expressly consenting to the terms of this Notice, where such express acceptance and consent shall be evidenced by you clicking or checking or indicating accordingly on the relevant consent portion of the registration forms or such other documents as may be furnished to you, as the case may be.

By so indicating your acceptance of the term of this Privacy Notice, you shall be deemed to have expressly consented to the processing of your personal data by us or any of its authorized agents, employees, partners and/or contractors for purposes as outlined.

You hereby agree and accept that by registering and/or continuing to use the Products and/or Services, you authorize and consent to your personal data being processed by and where required, disclosed to classes of third parties as identified by us for the purposes of our company providing the products and/or Services to you. For the avoidance of doubt, you also hereby explicitly consent to us processing any sensitive personal data relevant such purposes.

WITHDRAWAL OF CONSENT

iPayEasy shall take all necessary measures to give effect to your withdrawal of consent, to the extent that such withdrawal does not conflict with any of iPayEasy’s other legal obligations. Please note that as a result of your withdrawal of consent, we may not be able to process your application/request or provide you with our products or services or result in us being unable to communicate with you.

If you do not wish to have your personal data shared with any other party, or if you do not wish to be solicited for products or services offered by iPayEasy or any other parties including third parties, kindly inform us in writing at the communication information.

You shall, upon written request, be granted access to all personal data held or stored or processed by iPayEasy. To avoid confusion, “access” for the purposes of this provision shall mean notification of such personal data of yours that is processed by or on behalf of iPayEasy and to have a copy of such personal data communicated or conveyed to you in an intelligible form of iPayEasy’s choosing.

ADDITIONAL MATTERS RELATING TO PERSONAL DATA

• Incomplete Personal Data

Where indicated (for example in application forms or account opening forms), it is obligatory to provide your Personal Data to us to enable us to process your application for our products or services. Should you decline to provide such obligatory Personal Data, we may not be able to process your application/request or provide you with our products or services or result in us being unable to communicate with you.

• Your right to access and update your Personal Data

You have a right to access your Personal Data. To avoid confusion, “access” for the purposes of this provision shall mean notification of such personal data of yours that is processed by or on behalf of iPayEasy and to have a copy of such personal data communicated or conveyed to you in an intelligible form of iPayEasy’s choosing. Please contact customer support through http://www.ipayeasy.com, if you wish to have access to your Personal Data. iPayEasy will take steps to verify your identity before fulfilling your request.

If there are any changes to your personal data or if you believe that the personal data we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your personal data. iPayEasy may use its discretion in allowing the corrections requested and/or may require further documentary evidence of the new information to avoid fraud and inaccuracy.

• Transfer of Your Personal Data Outside Malaysia

It may be necessary for us to transfer your personal data outside Malaysia if any of our service providers or strategic partners who are involved in providing part of a services are located in countries outside Malaysia. You consent to us transferring your Personal Data outside Malaysia in the instances whereby it is necessary to fulfil the execution of the service/products that you signed up for.

We shall take necessary steps to ensure that any such partners are contractually bound not to use your Personal Data for any reason other than to provide the Products and/or Services they are contracted by us, to safeguard your Personal Data.

REVISIONS TO PRIVACY NOTICE

iPayEasy may review and update this Privacy Notice from time to time to reflect changes in the laws, in our business practices, procedures and structure, and the community’s changing privacy expectations. The latest version of the Privacy Notice will be made available on the Platform.

Where we consider, at our sole discretion, that the revisions made on the Privacy Notice are substantive, notice of such revisions will be provided on the Platform or by such other means of communication deemed suitable by us, for example, by sending you an SMS to the updated mobile number you provided to us. Please note that at all times you are responsible for updating your Personal Data and to provide us with your most current mobile number. In the event that the last mobile number that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the SMS containing such notice will nonetheless constitute effective notice of the changes described in the notice.

If you do not agree to the changes in our use of your Personal Data, you must notify us immediately and deactivate your iPayEasy Account with us. Continued use of our Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. We also encourage you to periodically review this notice to understand how it affects you if there are any changes to this Privacy Notice.

Should you have any query in relation to this Privacy Notice or how we handle your Personal Data, kindly contact customercare@iPayEasy.com