Privacy Policy
Overview
Simplepay Gateway Sdn. Bhd. (201501030418 (1155742-H)) (hereinafter refered to as “senangPay“, “we“, “us“, or “our“) has developed this Privacy Policy and Notice in accordance with the Personal Data Protection Act 2010 (“PDPA“) and its regulations, guidelines and orders to inform you by notice of how we may collect, retain, process, share, and transfer your Personal Data when you use the services offered and provide by us (“Services“).
This Privacy Policy and Notice applies to the Personal Data provided by you when you visit our websites (“Sites”) or use our Services, but does not apply to your Personal Data provided on other online websites, mobile applications or services that we do not own or control, including websites, mobile applications or services of other users of senangPay’s services.
senangPay has been validated against the external network vulnerability scan requirements of Payment Card Industry Data Security Standard (PCI DSS) and is fully in compliance with PCI DSS level 1 standards.
For the purposes of this Privacy Policy and Notice, please note that:
“Account” refers to an account created on our Sites or to use our Services.
“Device Information” refers to information about the device used to access our Services, which may include but is not limited to device type, model, operating system, browser type, unique device identifiers, IP address, and other diagnostic information.
“Geolocation Information” refers to data that determines your geographic location, which may be derived from your IP address, GPS, Wi-Fi signals, or other technologies.
“Merchant” refers to the party onboarded as a merchant of senangPay to accept credit cards, debit cards, FPX, and other payment methods to receive payments, manage, and analyse the exchange of funds for goods or services between the Users and such Merchant, generate reports, and perform other financial transactions using the Services.
“Participant” refers to any individual or entity involved in a transaction facilitated through our Services.
“Personal Data” refers to the personal data as may be defined under the PDPA.
“Technical Usage Data” refers to data automatically collected when you interact with our platform, including details such as your interactions with the payment gateway, time and date of access, transaction logs, page views, session durations, error logs, and other technical data.
“Users” refers to any individual who accesses, interacts with, or uses our Services, the Sites or any platform and mobile application in relation thereto.
Your acknowledgment and consent
Personal Data provided to senangPay will generally be kept confidential. By visiting our Sites, using our Services, and/or providing us with your Personal Data, you hereby consent and authorise us to collect, retain, process, use, share, transfer and/or disclose your Personal Data in accordance with this Privacy Policy and Notice. You hereby acknowledge that you have read and understood this Privacy Policy and Notice and agree and consent to our use and processing of your Personal Data.
If you have provided or disclosed Personal Data of individual third parties or if you are a corporation whereby you have provided or disclosed Personal Data of individual third parties including but not limited to your directors, individual shareholders, employees, authorised signatories, agents, representative, or otherwise, you hereby represent and warrant to us that you have obtained the consent of such third parties and are entitled to provide their Personal Data to us to be used, processed and/or disclosed in accordance with this Privacy Policy and Notice.
What Types of Personal Data Do We Collect?
We may collect information about you when you visit our Sites or use our Services or when you provide your Personal Data to use or when we receive information from a third party, including the following:
• Registration and Use Information – When you register to use our Services by establishing and maintaining an Account, we will collect Personal Data as necessary. Depending on the Services you choose, we may require you to provide us with your Personal Data including but not limited to your name, NRIC number, age, gender, company name, company number, postal address, telephone number, e-mail address, employment information, and identification information. We may also require you to provide us with additional Personal Data as you use our Services.
• Transaction and Experience Information – When you use our Services, we will collect information about the transactions involving you, as well as other information associated with the transaction such as the amount sent or requested, amount paid for products or services, Merchant information, bank account balance, spending patterns, including information about any funding instruments used to complete the transaction (e.g., credit card or bank account details), Device Information, Technical Usage Data, Geolocation Information etc.
• Participant Information – When you use our Services, we collect Personal Data you provide us with the other Participants.
• Receive Money – When you receive money through our Services, we collect Personal Data such as the name, NRIC number, postal address, telephone number, and financial account information about the Participant who is sending money to you. The extent of Personal Data required about a Participant may vary depending on the Services you are using to receive money.
• Affiliate Programme – If you use our Services to add value by inviting other potential merchants, we may collect Personal Data from you about the other party, or from the other party about you to facilitate the request. For example, we may collect name, mobile number or e-mail address of such other party.
• Information that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional feature in the Sites, or request enhanced Services or other elective functionality that is not commonly part of our Services, we may collect additional information from you. We will provide you with a separate notice at the time of collection if the use of that information differs from the uses disclosed in this Privacy Policy and Notice.
• Information about you from third-party sources – We may obtain Personal Data from third-party sources such as Merchants, data providers, and credit bureaus, where permitted by law.
• Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate, engage or interact with us through social media or at events, engage in marketing, promotions and cross selling, contact our customer support teams or respond to our survey(s).
Why do we retain your Personal Data?
We retain your Personal Data to fulfil our legal or regulatory obligations and for our business purposes and to provide our Services to you. We may retain Personal Data for longer periods than required if it is in our legitimate business interests and not prohibited by the applicable laws.
If your Account is closed, we will take reasonable steps to mask your Personal Data and other information but we reserve our ability to retain and access the data for so long as required to comply with applicable laws including for the purposes of resolving disputes, fraud prevention, or meeting regulatory requirements. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy and Notice.
Do we share your Personal Data?
We may share your Personal Data or other information about you with others including with to the following parties in a variety of ways as described in this the Privacy Policy and Notice.
• With other members of the senangPay corporate family: We may share your Personal Data with members of the senangPay family of entities including our holding, subsidiary, related, affiliated, and any future entities.
• With other companies that provide services to us: We may share your Personal Data with third-party service providers that perform services and functions at our direction or on our behalf.
• With the other parties to transactions when you use the Services, such as other Users, Merchants, and their service providers: We may share information about you and your Account with the other parties involved in processing your transactions (including those located outside of Malaysia). This includes the Participants, other Users, such as those you are sending funds to or receiving funds from, as well as the Merchants and their service providers when you use the Services to pay for goods or services. The information may include without limitation:
• Personal Data and Account information;
• Information that are able help other Participants(s) resolve disputes and detect and prevent fraud; and
• Aggregated data and performance analytics.
• With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties (including those located outside of Malaysia) for senangPay’s business purposes or as permitted or required by law, whenever necessary.
• With your consent: We will share your Personal Data and other information with your consent or direction, including if you authorise an Account connected with a third-party account or platform.
Why do we process your Personal Data?
We may process and your Personal Data and any other information collected for the following reasons (the list of which may not be exhaustive):
• To operate the Sites and provide the Services, including to:
- Facilitate the transaction;
- Initiate a payment or send money;
• Authenticate your identity and access to your Account;
• Communicate with you about your Account, the Sites, the Services, or senangPay;
• Create an account connection between your Account and a third-party account or platform;
• Perform credit worthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes;
• Keep your Account and financial information up to date; and/or
• Provide customer support.
• To manage our business needs, such as monitoring, analysing, and improving the Services and the Sites’ performance, and to help Merchants better understand Users and enhance their experiences.
• To help assess and manage risk, prevent abuse of our Sites and Services, and to detect and prevent fraud involving us, our Users, the Participants, our business partners, strategic ventures, Merchants, other individuals, our Sites or our Services.
• To provide personalized Services, market and promote senangPay products and Services on third-party websites and online services as well as the products and services of unaffiliated businesses.
• To uniquely tailor the marketing content and certain Services or Sites experiences to better match your interests on senangPay and other third-party websites.
• To use cookies and other tracking technologies to provide these online Services and/or work with other third-parties such as Merchants, advertising or analytics companies to provide these online services.
• To enhance the security of the Sites and Services and provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services such as advertising, search results, and other personalized content.
• To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with the law, legal process or regulations, law enforcement, regulators, government officials, or other third parties in relation to any subpoena, court order, or other legal process or requirement under Malaysian law or regulation, or the laws and regulations of other jurisdictions that are applicable to senangPay or one of its affiliates, including any such law or credit card rules.
• To prevent physical harm or financial loss.
• To report suspected illegal activity or to investigate violations of a user agreement and/or senangPay’s policy.
• To facilitate a purchase, sale, merger, or acquisition involving all or part of senangPay’s business, including the disclosure of Personal Data to relevant companies.
• To support our audit, compliance, and corporate governance functions.
• In connection with shipping and related services for purchases made using a Service.
• To banking partners as required by card association rules for inclusion on their list of terminated Merchants.
• To credit reporting and collection agencies.
• To engage in direct marketing, promotions and cross selling.
How do we use Cookies and Tracking Technologies?
When you visit our Sites, use our Services, or visit a third-party website for which we provide online Services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) for the following reasons:
• To recognise you as a User or Participant and to customise your online experiences, the Services you use, and other online content and advertising;
• To measure the effectiveness of promotions and perform analytics; and
• To mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services.
Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.
What privacy choices are available to you?
You have choices when it comes to the privacy practices and communications described in this Privacy Policy. Many of your choices may be explained at the time you sign up for or use our Services or in the context of your use of the Sites. You may be provided with instructions and prompts within the experiences as you navigate the Services.
Choices relating to the Personal Data we collect
• Personal Data: You may decline to provide Personal Data when it is requested by senangPay, but certain Services or all of the Services may be unavailable to you.
• Location and other device-level information: The device you use to access the Sites or Services may collect information about you, including Geolocation Information and User usage data that senangPay may then collect and use.
Choices Relating to Cookies
• You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you to delete, disable, or block certain cookies and other tracking technologies. You may choose to enable these options but doing so may prevent you from using many of the core features and functions available on a Service or Site.
• You may have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of a Site. For example, you may be asked if you want the Service or Site to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.
How do we protect your Personal Data?
We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorization controls.
While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate, complete, not misleading and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized.
Please note that any transmission of data over the Internet is not completely secure. While we will make every effort to protect your Personal Data, we cannot guarantee the security of data transmitted online. Therefore, any transmission of data is at your own risk.
Direct marketing
You hereby consent for us to use your Personal Data for marketing, promotion, direct marketing and cross selling. We may use your Personal Data to provide you with information about our and third-party services and/or products, which may be related to your interests, unless requested otherwise by you.
We may, in some circumstances, disclose your Personal Data to preferred Merchants and strategic partners. Such disclosure will only occur where you have subscribed for particular products and/or Services that require such disclosure, and/or where your consent has been obtained, subject at all times to any laws (including regulations, guidelines, and/or obligations) applicable to senangPay.
We take reasonable steps to ensure that the third parties we are sharing your Personal Data with also have appropriate privacy and confidentiality obligations.
In addition, you would have been deemed to have given your consent for our continued communication for further information on our products, Services, promotions, and matters relating to the primary purposes below, which we may consider to be interesting to you from time to time.
Your rights to access, limit, correct, and update your Personal Data
Subject to payment of a prescribed fee, you may request for access to your Personal Data, request for deletion, correction or update of your Personal Data, request to limit the processing of your Personal Data and/or make any inquiries or complaints regarding your Personal Data by contacting us at:
- Contact Person: Customer Support Department
- Address: Unit 27-8, Level 8 Boulevard Office, Mid Valley City, Lingkaran Syed Putra, 59200 Kuala Lumpur, Wilayah Persekutuan.
- Tel No.: 03-2771 2707
- WhatsApp No.: 017-8244534 (Text only)
- Fax No.: N/A
- E-mail: [email protected]
senangPay reserves the right to refuse your request for the aforementioned for reasons permitted under the law.
Language
As per Section 7(3) of the PDPA, this Privacy Policy and Notice is issued in both English and Bahasa Malaysia. In the event of any inconsistency, the terms of the English version shall prevail.
Revision of this Privacy Policy
senangPay has the right to modify, update, or amend the terms of this Privacy Policy and Notice from time to time. Where the Privacy Policy and Notice is revised, the revised Privacy Policy and Notice will be posted on our Sites and/or communicated to you via any other means of communication deemed suitable by us. If you continue to use our Services, you shall be deemed to have agreed to accept such changes.
