Privacy Policy

This section provides specific details of how we treat any personal data you provide us when you visit this website. By using this website you consent to our collection and use of your personal data as described in this Privacy Policy. If we change our Privacy Policy and procedures, we will post those changes on the website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it.
Our website is primarily intended for access from within Malaysia, and we cannot guarantee that the Site or the information thereon complies with laws or regulations of other countries. We want you to understand:

What personal information do we collect about you?

We may collect and use personal information about you, including when you interact with us, register for any e-wallet or mini app, use the respective services to make purchases or otherwise conduct financial transactions (collectively called “Respective Services”), or otherwise visit our website or use the respective Services. The personal information we collect includes:

• your basic personal details, including first and last name, and copies of your personal ID documents;
• contact information (including your address, phone number, email, or other information that permits us to contact you);
• account information;
• registration details;
• financial information and tax identification information;
• transaction details; and
• technical information, including:
• information about the device you use to interact with us, and
• information from your visits to our websites or mobile applications.

How we obtain your personal information

We collect personal information about you when you browse our website, enquire about or register to use any of the Respective Services, sign a contract with us, provide your personal information during the merchant on-boarding process, log into your account to use the Respective Services on our site; or when you communicate with us via e-mail, phone, SMS, or any other electronic means. We also receive personal information about you from other sources, including:

• merchants and other third parties, including those who support the ability to make payments and conduct transactions through Respective Services;
• affiliates;
• suppliers providing services on our behalf; and
• publicly available sources.

We combine information that we have about you from various sources, including the information you have provided to us. Please refer to the section headed “How we use your personal information” for more details.

How we use your personal information

We use the information we collect to operate our business. For example, we may use your personal information for the following purposes:

1. verifying your identity, including during account creation processes;
2. verifying your eligibility as a User of Respective Services;
3. processing, maintaining and managing your registration as a User;
4. contacting you in connection with any communication preferences or requests you have expressed, asking you for feedback about Respective Services or other related products and services, collecting feedback from you and your staff about our products and services and using such feedback to improve our business and/or customize products and services; sending you information about products and services, including for promotional purposes; and contacting you for legal purposes;
5. assessing, detecting, investigating, preventing or remediating fraud, data breaches or other potentially prohibited or illegal activities and otherwise protecting the integrity of our platform;
6. managing our risk, performing creditworthiness and solvency checks on Users, or detecting, investigating, preventing or remediating violations of your agreements with us or any of our applicable policies, industry standards, guidelines, laws and regulations, etc.;
7. making disclosures as may be required by any rules, law or regulation, regulatory authorities, government official or other third party, including any card association or other payment network. Such disclosures may also be made pursuant to any subpoena, court order or other legal process or requirement applicable to us or any Affiliates (including “know your customer”, anti-money laundering, counter-terrorist financing reporting, tax requirements or other commercial disputes);
8. making disclosures to third parties including relevant regulators to prevent any harm or financial loss, to report suspected illegal activity or to establish, exercise, or defend claims or potential claims on behalf of ourselves or our Affiliates;
9. improving our Respective Services;
10. managing our business including to protect Users, prevent harm, fraud or theft to ourselves or others, maintain the security of our products, and protect our rights or property and those of others; and
11. otherwise for everyday business purposes, to comply with law, or in other ways for which we provide specific notice at the time of collection.

With whom do we share your personal information?

We share your personal information to operate and manage our business, including for the purposes indicated under “How we use your personal information”. Thus, for example, we may share your information with:

• Affiliates;
• third parties, including:
• any agent, contractor or third party service provider that we work with in providing Respective Services. For example, we work with third parties to help us with fraud prevention, anti-money laundering checks, credit checking, bill collection, data entry, database management, promotions, marketing, customer service, technology services, products and services alerts and payment extension services or to provide trade financing services;
• banks, card associations, payment networks or acquiring institutions, and others, including those involved in processing of payments and conducting transactions through Respective Services; and
• law enforcement agencies, insurers, government and regulatory authorities or any other organizations to which COD, or any Affiliate or third party service provider, is under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement.

See “How do we store and protect your personal information?” for information on how we keep your personal information secure when sharing it with others.

How do we store and protect your personal information?

We will keep your personal information in accordance with our policies and for as long as it is necessary to provide you with the services or other purposes as set out in this notice. In addition, we may retain your personal information for a longer period if it is necessary to comply with laws and regulations applicable to us.
We use a variety of security measures and technologies designed to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection and privacy laws and regulations.

Use of cookies and web beacons

When you access our website, we may use a small data file to identify you to provide you with a smoother access experience. This helps you save the effort of repeatedly entering registration information or can help determine the security of your account. These data files may be a cookie, flash cookie or other local storage provided by your browser or relevant application (collectively, “cookies”). Please understand that some of our services are available only through the use of cookies. If your browser or browser plug-in permits, you may adjust the extent to which you accept or even refuse cookies from us. However, all of these actions under certain circumstances may affect your ability to securely access the website or use the services provided by us.
Our website may also include some electronic images (called “single-pixel GIF files” or “web beacons”). The use of web beacons can help the website to calculate the number of visiting users or access cookies. We will use web beacons to collect information about your browsing on the website. Examples included the address of the page you visit, the website you were previously visiting, the length of your visit to a page, your browsing environment and display settings, etc.
When you use third party services, we cannot ensure the third party entity will take security measures in accordance with our requirements. If your access is via our website or customer platform, in order to provide you with a more secure access experience and to protect your account security to the greatest extent possible, we may use proprietary network protocols and proxy technology (referred to as a “special network channel” or “network proxy”). The use of a special network channel may help you identify sites known to be high risk and reduce the risk of phishing or account leaks as a result. At the same time, it is beneficial for protecting both you and the third party’s interests and prevents criminals and other third parties from tampering with your service content. Examples include advertising injections resulting from unsafe routers or illegal base stations, illegal content tampering and more.

Third party services and sites

Our website may provide links to other websites and services (including other online merchant sites) for your convenience and information. These services and websites may operate independently from us. Linked services and websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for these websites’ or services content, any use of these services or websites by you, or the privacy practices of these services or websites.

Contact us

If you have questions or requests about the privacy of your personal information, please contact us by email via [email protected]