This Personal Data and Privacy Policy is prepared pursuant to the Personal Data Protection Act 2010 (the “Act”) [MALAYSIA], and sets out the policies and procedures with regards to Your personal data and Your agreement and express consent to the usage and processing of Your personal data for the purposes set out below.

When You request information, sign up with Us, and/or continue to use Our website, products and/or services, You may be required to provide Us with Personal Data and in doing so You will be treated as having given Us Your express consent and permission where necessary and appropriate, for the disclosures referred to in this Privacy Policy.

1.            Interpretation

1.1          In this Privacy Policy the first person (“We“, “Our“, “Us“, “Ours“) denotes Our website at www.paylater.com.my irrespective of whether access is via a mobile device or mobile-optimized websites, or through utilizing and/or make use of Our mobile applications via Google Play store or iOS Apple App store (“Mobile App”) (the “Our Site”), its parent company Kale Technology Sdn Bhd, any subsidiary(s) or any associated company within the Group, as defined in Companies Act 2016 from time to time (all together as, “KALE”).

1.2`        The second person (“You“, “Your“, “User”) denotes You as Our Site visitors and representatives and employees of You, where as an entity shall include Your subsidiary(s) or any and/or all of its subsidiaries connected to You, Your parent company or to any subsidiary(s) or, any associated company as defined in Companies Act 2016 from time to time or generally if a natural person shall mean the individual,  providing Personal Data and/or any other information, being the subject matter of this Privacy Policy.

1.3         “Personal Data” shall mean and/or may include but is not limited to the following: –

1. Your name;
2. date of birth, passport or identity card number;
3. home address, telephone number, facsimile number or email address;
4. photographs or pictures;
5. gender, marital or family status;
6. race, nationality or national, or ethnic origin;
7. education, employment or occupation, or educational, employment or occupational history, year of service, working experience, employers’ details;
8. source of income or financial circumstances, financial positions, activities or history including but is not limited to Your payment history, account activities, account balances, payment and/or deposit balances etc.;
1. litigation records and criminal history including regulatory offence(s);
10. details and background of family members;
11. details of guarantors and legal representatives;
50. details of bank accounts and specimen signature;
1000. details of Your transactions with Our Site or KALE;  
14. any such other necessary information of You;
15. that are, have been and may be collected, compiled and maintained from time to time with and by Our Site or KALE through amongst others the following manner:-

1. Your access to the Our Site or KALE web server or Our website/ Mobile App;
2. Your application form and/or any other forms as provided by You;
3. transactions between Us and You, its service providers, business partners, affiliates and/or third parties;
4. Credit Reporting Agencies and Credit Bureau Reports, e.g. CTOS (Convergent Technology Operating System Sdn. Bhd.), RAMCI (RAM Credit Information Sdn. Bhd.) etc;
5. Governmental Agencies, Regulatory and/or Statutory Authorities;
6. customer surveys; and
7. publicly available sources.

NOTE: This list is not exhaustive, as the word “include” is used, clauses (a) to (o) do not set out the only information which is Personal Data.

2.          Collection of Personal Data

2.1        Our Site or KALE will from time to time collect, maintain, obtain, use or disclose Your Personal Data when You provide Your Personal Data or someone else with Personal Data whom You have provided Us with the information (3rd Party”), that is information that can identify You or such 3rd Party to Us in any way or manner, including pursuant to any transactions, agreements and/or inquiries made to Us. We will also receive and store Your Personal Data when You enter the Our Site or KALE websites such as IP address, web browser software, and referring website including the URL that You just came from. You represent and warrant that You have obtained the consent of such 3rd Party or are otherwise entitled to provide Us with their Personal Data and to view or change their information. You agree to indemnify Us in the event We suffer any loss or damage as a result of Your failure to comply with the same.

2.2        Please be assured that We will not use Your information for any of the purposes, if You have indicated that You do not wish Us to use Your information in this way when submitting the information or at a later stage.

2.3        We are interested in Your views, and We value feedback from You and We therefore have set up notice boards, newsgroups, feedback, and email. Such information will be used in accordance with this Privacy Policy. However, We can of course not control and be responsible for other parties’ use of the personal information which You make available to them through this website and We encourage You to be careful about what personal information You disclose in this way, as We will not be liable nor be responsible for the information that You disclose on Our website. Please also note that if You post personal information online that is accessible to the public, You may receive unsolicited messages from other parties in return.

2.4        Information that You will provide to Us, amongst others shall includes the following:

1. You will be asked to provide certain contact information that is necessary for the registering for a User account, including name, address, phone number, email address, job title and department; 
2. You will be asked to provide certain identity information, tax registration and/or related information about Your business, such as Your company name, business type and industry, corporate registration details and information about Your business license;
3. If You are successfully certified by KALE, as a blogger or an influencer, in addition to the information mentioned above, We may also collect Your live stream videos, Your social media account names and profile photos, and posts or comments made by other users of Our Site;
4. In connection with the facilitation of transactions and payments on Our Site, You will be asked to provide certain banking information. This might include bank account numbers, billing and delivery information, credit/debit card numbers, expiration dates and security code and tracking information from cheques or money orders to facilitate the transaction;

2.5        Information that We collect automatically

1. If You contact Us (such as via Our customer services department chat service, telephone or email), We may record a copy of Your correspondence and may ask for additional information to verify Your identity.
2. We will collect contact details and other information of Users from publicly available sources for the purposes of verifying the Users and performing due diligence on the Users.
3. We will collect details of User activities, transactions and interactions on Our Site.
4. From time to time, We may also collect information about the existing and prospective users, including representative contact names, addresses, phone numbers, fax numbers and email addresses.
5. If You visit Our Site, We will automatically collect certain information from Your device. In some countries, this information may be considered as personal information under applicable data protection laws. Specifically, this information may include IP addresses, device type, unique device identification numbers, browser type, broad geographic location (e.g. country or city-level location), browsing patterns and details of how You have interacted with Our Platform and the goods and services available on it. In addition, We gather statistical information about the Platform and visitors to the Platform including, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Collecting this information enables Us to better understand the visitors who come to Our Platform, where they come from, and what content is of interest to them.  We use this information for Our internal analytics purposes and to improve the quality and relevance of Our Platform. Some of this information may be collected using cookies and similar tracking technology, as explained further under the section 3 “Cookies Policy” below.

3.         Cookies Policy

We use the term “cookies” to refer to cookies and other similar technologies covered by the EU Directive on privacy in electronic communications.

1)   What is a cookie?

Cookies are small data files that Your browser places on Your computer or device.  Cookies help Your browser navigate a website and the cookies themselves cannot collect any information stored on Your computer or Your files. When a server uses a web browser to read cookies they can help a website deliver a more user-friendly service. To protect Your privacy, Your browser only gives a website access to the cookies it has already sent to You.

2)   Why do We use cookies?

We use cookies to learn more about the way You interact with Our content and help Us to improve Your experience when visiting Our website. Cookies remember the type of browser You use and which additional browser software You have installed. They also remember Your preferences, such as language and region, which remain as Your default settings when You revisit the website. Cookies also allow You to rate pages and fill in comment forms. In order to provide customized and personalized services, We use cookies on certain pages of Our website. Cookies allow You to enter Your password less frequently during a session. Cookies can also help Us provide information that is targeted to Your interests. Cookies are stored on Your hard drive, not on Our site. You are always free to decline Our cookies if Your browser permits, although in that case You may be required to re-enter Your password more frequently during a session.

3)   How are third party cookies used?

For some of the functions within Our websites We use third party suppliers, for example, when You visit a page with link. These links (and any other content from third party suppliers) may contain third party cookies and You may wish to consult the policies of these third-party websites for information regarding their use of cookies. Further, We may in future contract with several online partners to help manage and optimize Our Internet business and communications. To do this, We use Web beacons and cookies provided on this site. The type of information We collect includes purchases and pages visited. By supplementing Our records, this information helps Us learn things like what pages are most attractive to Our visitors, which of Our products most interest Our visitors, and what kinds of offers Our visitors like to see. We control how that data may and may not be used. If You do not want to help Us learn how to improve Our site, products, offers and marketing strategy, You can “opt-out” of Our ability to analyze such data by sending an email to [email address]

4)         How do I reject and delete cookies?

We will not use cookies to collect personally identifiable information about You. However, should You wish to do so, You can choose to reject or block the cookies or the websites of any third-party suppliers by changing Your browser settings – see the Help function within Your browser for further details. Please note that most browsers automatically accept cookies so if You do not wish cookies to be used You may need to actively delete or block the cookies. You can also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies generally. For information on the use of cookies in mobile phone browsers and for details on how to reject or delete such cookies, please refer to Your mobile phone’s manual. Note, however, that if You reject the use of cookies You will still be able to visit Our websites but some of the functions may not work correctly.

4.           Purpose of Collecting Your Personal Data

4.1        We collect, use and/or process Your Personal Data for the following purposes: –

1. process application(s) submitted by You;
2. verifying Your identity and conducting security, KYC (know-Your-customer) and anti-money laundering diligence and background checks in order to set up User accounts;
3. verifying Your eligibility to register as a User in accordance with Our Terms of Use;
4. setting up / administering User accounts, including providing log-in IDs and developing a profile;
5. communicate with You including responding to Your enquiries and/or complaints and resolving disputes;
6. to notify You about important changes/developments in relation to Our Site;
7. facilitating communication between KALE and You
8. for the purposes of strategic alliances, cross selling, marketing, and promotions, to other units/department/ entities within Us, Our agents and third parties;
1. to comply with regulatory requirements and provide assistance to law enforcement agencies which may include disclosure, notification and record retention requirements;
10. to administer and/or manage products and services and/or any agreement You have with Us including collecting debts and enforcement of Our rights and obligations;
11. to improve and develop Our services and quality assurance to You;
50. assessing and monitoring account security and transaction risks of Users, to prevent, detect or prosecute cases of fraud/crime, money laundering and comply with legal and regulatory obligations;
1000. to maintain Your credit history for present and future reference (if any) and
14. to protect KALE’s interests and other ancillary or related purposes.
15. for internal functions such as research and product development, evaluating the effectiveness of marketing and promotion campaigns, market research, statistical analysis and modelling, reporting, audit and risk management and fraud prevention;
16. any purposes in connection with the transactions and/or agreements entered into or to be entered into by You and/or Your principal/employer;
17. to provide new product & services, to potential new customers and subscriber’s identifications including marketing purposes and/or research purposes; and
18. other purposes which We may reasonably deem fit.

4.2          We, including Our personnel will only have access to use only relevant part of Your Personal Data. We endeavour to keep You informed of the latest marketing and promotional offers that We feel would be useful and beneficial to You. We may share Your personal data with other entities within KALE, Our agents or strategic partners and other third parties (“other entities”) as We deem fit and You may receive marketing communication from Us or from these other entities about products and services that may be of interest to You. If You do not wish for Us to use Your information in any of the abovementioned way for any of the purpose(s), You may write to Us and notify Us that You would like to withdraw Your consent. Your request will be processed at no fees and We will stop the use of Your information for such purposes as soon as it is reasonably possible to do so. However, please note that there are certain Personal Data information that may be necessary for You to provide, which otherwise may result in KALE being unable to provide You with products and/or services.

5.            Disclosure of Personal Data

5.1         For purposes as described herein, We may share with and/or transfer Your Personal Data to:

1. Any person under a duty of confidentiality to KALE or to companies related or affiliated to KALE;
2. Companies related or affiliated to KALE;
3. Any credit bureaus, credit reference agencies, debt-collection agencies and/or other parties that assist with debt recovery functions;
4. Any relevant agents, contractors, third party service providers, professional advisors or brokers, on a need to know basis for the purposes of providing their services/advices to Us;
5. Any banking, financial or other institution with which You have or propose to have dealings with;
6. Parties authorised by You;
7. Enforcement regulatory and governmental agencies as permitted or required by law, and/or any other relevant authority as may be authorized by law to obtain such information
8. Any person by whom KALE is required by applicable legal, governmental or regulatory requirements to make disclosure;
1. Any person or corporation to whom KALE transfers or proposes to transfer any part of its interests, obligations, business and/or operations; and
10. Any other person reasonably requiring the same in order for KALE to carry out the activities set out in the above purposes.

5.2          In addition, the collected Personal Data will (occasionally) be transferred to selected third-parties, however these third parties will not use Your personal information for any other purposes than what We have agreed with them. We respect Your personal information and therefore, We will request these third parties to implement adequate levels of protection in order to safeguard Your personal information and We will take steps to ensure that Your privacy rights continue to be protected if We transfer Your information in this way.

5.3          Your Personal Data may also be transferred to, stored in, and processed in a jurisdiction other than Malaysia. You understand and expressly consent that Your Personal Data may be transferred outside of Malaysia to those third parties.

5.4          We may also share Your Personal Data where required by law or where disclosure is necessary to comply with applicable laws, legal processes, or queries from the relevant authorities.

6.           Right to Access and Amend/Correct Personal Data

6.1          KALE is committed to ensure that the Personal Data that We hold is accurate, complete, not misleading and up-to-date.

6.2         If You would like to review or change the details You have supplied Us with, You may, request to access, amend or make any correction to Your Personal Data by submitting a request in writing to KALE to the address stated below. Your personal data will be stored with us for certain years which is required by the law for auditing purpose.

6.3         Notwithstanding that access is granted to You or any correction / updating of Your Personal Data is performed, this Privacy Policy shall remain valid and effective at all times.

7.         Security

7.1         The security of Your Personal Data is Our paramount consideration. KALE keeps, protects and processes Your Personal Data in a secure manner by maintaining physical, electronic and procedural safeguards in compliance with the law, and KALE will, as far as practicable, aim to prevent any unauthorized and/or unlawful/unauthorized access, improper processing of, and the accidental loss, destruction or damage to Your Personal Data. We have implemented technology and policies with the objective of protecting Your privacy and will update these measures as new technology becomes available, as appropriate.

7.2         Our websites may have links to other websites or You are referred to Our website through a link from another website. Please note that We are not responsible for the privacy policies and practices of other websites. Such content is subject to their terms of use and any additional guidelines and privacy information provided in relation to that use on their website, and We recommend that You check the policy of each website You visit to better understand Your rights and obligations especially when You are submitting any type of content on those third-party website. Please contact the owner or operator of such website if You have any concerns or questions.

8.            Changes to this policy

8.1          KALE reserves the right to amend this Privacy Policy from time to time. KALE may modify or update this Privacy Policy to reflect any changes to its privacy practices.

8.2          Any updated version of this Privacy Policy is available on www.paylater.com.my. We encourage You to check Our website on a regular basis in relation to this Privacy Policy, for any updates or changes.

8.3          If We make any substantial changes to this Privacy Policy in terms of the way in which We use Your Personal Data, We will post these changes on this page, on Our website and will do Our best to notify You of any significant change(s).

8.4          In accordance with Section 7(3) of the PDPA, this Privacy Policy is issued in both English and Bahasa Malaysia. In the event of any inconsistencies or conflict of the terms between the English version and the Bahasa Malaysia version, the English version shall prevail.

8.5          We trust that You have read, understand, consent and agree to the terms above mentioned with respect to Our processing of Your personal information and/or data, when You use Our website, products or services.

8.6          If You do not consent and/or require any further clarification to the above, please do not hesitate to contact Us at the below mentioned contact details.

9.            Contact

Any queries, complaints and/or request to delete Your Personal Data or if You require any further information / assistance, You may write a request to KALE or contact Us via email, facsimile, telephone and/or post to the address as below: –

Kale Technology Sdn. Bhd.

Level 2, Tower 1, Avenue 5

Bangsar South City

59200 Kuala Lumpur

Tel      : +60 18-208 5455

Email  : enquiry@paylater.com.my