1.2 GLYD prepaid Mastercard (“Card”) is a reloadable prepaid card promoted by Paysol Sdn. Bhd. (Company No.: 201901024728 / 1334057X) and the card is issued by Instapay Technology Sdn. Bhd. (Company No.: 201701019495 (1233660-A)) (“Instapay”).
Paysol Sdn. Bhd. 23A-16, Q Sentral, Jalan StesenSentral 50470 Kuala Lumpur Malaysia Email:.connect@InstaPaytech.com
2.3 Our Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from children under 18. In the case we discover that a child under 18 has provided us with personal information, we will immediately delete the records from our database. If you are a parent or guardian and become aware that your child has provided us with personal information, please contact us so that we will be able to take necessary action.
3. YOUR RIGHTS
- Right to access your Personal Data. This enables you to receive a copy of the Personal Data we hold about you.
- Right to correct your Personal Data. This enables you to have any inaccurate, incomplete, misleading or not up-to-date Personal Data we hold about you corrected.
- Right to withdraw your consent. This enable you to withdraw your consent given to us to process your Personal Data. If you withdraw your consent, we will cease to process your Personal Data but we may not be able to provide you with access to the certain functionalities of our Site and/or App, or use of our Services.
3.2 If you wish to exercise your rights above, please:
- address your request in writing to us in accordance with paragraph 1.4 above;
- provide us with sufficient information, or we may request for further information, for us to verify your identity as our security measures to ensure that Personal Data is not disclosed to any person who has no right to receive it; and
- specify the right which you wish to exercise and identify the relevant Personal Data for this purpose.
3.3 We will endeavour to respond to all legitimate requests within 21 days from the date we receive your request unless your request is particularly complex or you have made multiple requests, in which case we will notify you should we require additional time to fulfil your request. Typically, you will not have to pay a fee to access or correct your Personal Data but we reserve the right to charge a fee pursuant to our rights under the PDPA. If we have reasons to refuse your requests as permitted under the PDPA, we will notify you of such reasons accordingly.
4. COLLECTION OF DATA
1. Personal Data that you provide directly to us. When you use the Site, App, Card and/or Services, your Personal Data may be collected by us through your voluntary submission. We may collect and hold Personal Data about you, that is, information that can identify you, including but not limited to your full name, postal and email address, other contact details, identification details, payment details, and other information relevant to us in providing you with our Services, which we receive from you through our Site, App, Card, customer service centre, social media sites, walk-in or distribution channels and other distribution channels. When you provide Personal Data to us, you are responsible for ensuring that such information is accurate, complete, not misleading and up-to-date.
You acknowledge and agree that in order for Paysol and/or Instapay to provide you with the services, benefits, offers and privileges related to the Card(s), to manage the Customer Account or Card(s), to facilitate the use of the Card(s) and the processing of any transaction effected or to be effected through the use of the Card(s), the sharing, transfer, retrieval, updating and processing of your Personal Data as well as the creation of member profiles and user accounts and updating of personal details may occur between Paysol and Instapay and between their subsidiaries, associates, related corporations, affiliates, licensees, assignees, proposed assignees, agents, vendors, service providers, merchants, strategic partners, commercial partners, third party contractors, any regulatory authorities (including BNM and such other authorities or bodies having jurisdiction over the Card(s)), payment network operators, and any other parties engaged by Paysol and/or Instapay to enable or assist Paysol and/or Instapay in the provision of services to you or to exercise or enforce Paysol’ s or Instapay’s rights hereunder and/or any other party whomsoever as Paysol or Instapay may deem relevant or necessary, within and beyond Malaysia.
2. Personal data from third party sources. We may also collect certain of your Personal Data from third party sources, for example, from credit reporting agencies, social media sites, our affiliates, analytics providers, advertisers, data brokers, and identity verification and compliance service providers.
5. CONSENT AND WITHDRAWAL
2. You hereby give consent to Paysol that your Personal Data collected by Paysol and/or provided to Instapay may be used and/or disclosed in accordance with the privacy policies published in the official websites of Paysol and Instapay.
3. You may, by notice in writing to us, withdraw your consent to processing your Personal Data and we will cease to process your Personal Data, destroy or delete the information, or remove the means by which the data can be associated with you within 21 days from the receipt of your notice, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect our interests.
4. You may decline to provide us with your Personal Data. If you choose not to provide any Personal Data whenever required by us, this may limit your ability to use certain features of the Site, App, Card and/or Services, or we might not be able to adequately deliver our Services to you.
6. USE OF DATA
1. Our primary objective in collecting and using Personal Data is to provide, facilitate, maintain, personalise and/or improve our Site, App, Card and/or Services. Below are the more detailed examples of relevant purposes for which we may collect and use your Personal Data (collectively, “Purposes”):
- to provide you with products and/or services which you have subscribed for and to notify you about important changes or developments to the features;
- to verify your identity or background, including screening against third party databases or other sources, for the purposes of our Know Your Customer process;
- to enable the sharing, transfer, retrieval, updating and processing of your Personal Data as well as creation of member profile and user accounts between our related corporations, affiliates subsidiaries, associates and business partners, where applicable, to enable you to receive and enjoy the services, benefits and privileges related to our Services;
- to fulfil our transactions with you and your transactions via our Services, including but not limited to processing your payment transactions, sending you notifications and managing your account, and for other operational and administrative purposes;
- to update and manage the accuracy of our customer database and records;
- to send you information on our products, services, programs (e.g. loyalty programs where applicable) or transactions you have undertaken with us, and special promotional offers, programs (e.g. loyalty programs), newsletters or customer survey forms and questionnaires;
- to assess and analyse behaviour scoring, market, product and trend analysis and market research (where applicable);
- to conduct internal activities, administrative, operational, marketing, planning, product or service development, troubleshooting and research requirements;
- to administer your participation in contests or campaigns that we may run from time to time;
- to provide you with information our products and services and those of our related corporations, affiliates, subsidiaries, associates and business partners (where applicable) for cross selling, marketing and promotions including administering offers and competitions, driving engagement in respect of our Services and third-party products and services which may be of interest to you based on your interactions with us. Such communication may be in the form of postal mails, emails, text messages, social media channels, newsletters, brochures or other printed or digital communication;
- for communications and to ensure customer satisfaction, which may include to provide customer support, to contact you regarding any complaints, feedback, queries or requests or to generally resolve disputes, to conduct surveys for improvement of our products and services, or to enforce our terms and conditions relating to our Site, App, Card or Services;
- for security measures, including to prevent, detect or prosecute crime; to facilitate investigations into any suspicious or illegal activity on the Site or App or Card or relating to the use of our Services; and to otherwise comply with legal and regulatory obligations;
- to maintain your card account history for present and future reference (if any);
- for enabling an actual or proposed assignee of Paysol, or participant or sub-participant of Paysol to evaluate your transactions which are intended to be the subject of the assignment, participation or sub- participation (if any);
- to protect our interests and other ancillary or related purposes;
- for such other purposes as set out in any other terms and conditions (including product terms and conditions) and campaign terms and conditions (if applicable); and
- for any purpose made known to you at the time of collection of your Personal Data.
6.2 If we intend to use, handle or process your Personal Data in any manner that is not consistent with the Purposes, you will be notified in accordance with paragraph 2.2 above.
6.3 You may at any time opt-out of receiving marketing communications from us by contacting us (see paragraph 1.4 above) and we will ensure that your name is removed from our mailing list.
6.4 Please note that it is necessary for Paysol and/or Instapay to process your Personal Data for the Purposes without which Paysol and / or Instapay will not be able to provide the product and/or service that you have requested from us or to perform and/or carry out any of the Purposes. If you fail or decline to provide us with Personal Data as requested, we may not be able to perform and/or carry out any of the Purposes and may need to terminate any product and/or service provided to you. In some circumstances, you may have provided personal and financial information relating to others (e.g. joint- applicant, spouse, related parties and/or emergency contact persons, beneficiaries, payees) for the Purposes. In such cases, you represent and warrant that you had or have their consent or are otherwise entitled to provide their information to Paysol and/or Instapay.
- recognise your browser as a previous visitor and save any preferences that may have been set during your last visit to the Site / App;
- maintain your session and required details during the application, subscription, registration process and during transactions (session cookie);
- obtain information about your preferences, online movements and use of the Internet;
- rack website analytics and carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitors’ or customers’ requirements and interests;
- ustomise and target our marketing and advertising campaigns and those of our partners more effectively by providing personalised interest-based advertisements;
- easure and research the effectiveness of our interactive online content, features, advertisements, and other communications;/li>
7.2 Third-Party Cookies
Third-party cookies are set by third-party sites separate from the Site / App. We may work with third-party service providers who are authorised to place third-party cookies and may also set cookies on the Site / App. These third- party service providers are responsible for the cookies they set on the Site / App. If you want further information, please visit the website of the relevant third party. If you would like to opt-out of all other types of technologies we employ on the Site / App, you may do so by changing your browser settings to block, delete or disable these technologies as your browser or device permits.
7.3 Log Files
Log file information is automatically reported by your browser each time you access a web page. When you use the Site / App, our servers automatically record certain information your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
7.4 Clear GIFs Information (Web Beacons)
When you use the Site / App, we may employ clear GIFs (also known as web beacons or tracking pixels) to anonymously track online usage patterns. No personally identifiable information about you is collected using these clear GIFs. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information collected is used to enable more accurate reporting and make the Site / App better for users.
8. DISCLOSURE OF INFORMATION
8.1. We are not in the business of selling your information. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, such as with certain authorised persons or organisations, including but not limited to our related corporations, affiliates, subsidiaries, associates, contractors, licensees, advisors, vendors, service providers, merchants, strategic partners, payment network operators (including MasterCard) and third party contractors (whether located within or outside Malaysia, to help us develop, maintain, provide or facilitate our Site, App, Card and/or Services, or otherwise for the Purposes.
8.2. We may also share your Personal Data with our business partners with whom we have commercial relationships for the Purposes, for marketing, advertising and related purposes, unless you have indicated that you do not wish for us to disclose to such third parties for marketing and advertising purposes.
8.3. Our service providers provide us support for our Services, including, for example, website and application development, hosting, maintenance, security, backup, storage, virtual infrastructure, payment processing, analysis, identity verification, background and compliance reviews, banking services, and other services for us, which may require them to access or use Personal Data about you. These third parties are prohibited from using your Personal Data for purposes not relevant to their engagement or services.
8.4. We may also provide Personal Data to governmental agencies, regulatory authorities (including Bank Negara Malaysia) whether located within or outside Malaysia for the Purposes or as required or authorised under applicable laws or provided in co-operation with any governmental authority.
8.5 As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
8.6 We may also share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services or conduct independent research based on such anonymous usage data.
9. PERIOD OF RETENTION
Personal Data provided by you will be retained and stored as long as the purpose for which the data was required continues, unless you request that we remove your Personal Data in exercise of your rights. Thereafter, we will destroy or delete the information, or remove the means by which the data can be associated with you, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect our interests. We will however periodically review the data we hold, and erase or anonymise it when we no longer need it.
10.1 We use industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data from loss, misuse, and unauthorised access or collection, disclosure, alteration, or destruction. We limit access to your Personal Data to those employees who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We cannot, however, ensure or warrant the security of any information you transmit to us or guarantee that your information provided through our Site, App, Card and/or Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards. While we will use all reasonable efforts to safeguard Personal Data, you acknowledge that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Personal Data that are transferred from you or to you via the Internet.
10.2 By providing us with Personal Data or using otherwise using our Site, App, Card and/or Services, you consent to the transfer, storage and processing of Personal Data to where our servers, central database and system facilities are located and/or operated, which may be outside Malaysia, your country of domicile or the location where you access our Site, App, Card and/or Services to provide Personal Data.
11. MONITORING AND CHECKING
11.1 We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.
11.2 For the prevention of fraud and money laundering, we may search the files of credit reference from fraud prevention agencies (who will record the search). If you provide false or inaccurate information and we suspect fraud, we may disclose information about how your interaction with the Site, App, Card and/or Services to such agencies and if the situation warrants it, we may have to report to law enforcement authorities.
13. GOVERNING LAW AND JURISDICTION